SEMS Element #10- Emergency Response and Control

It is amazing that after workers are seriously injured and/or killed in the industry that companies, and employees, do not take emergency response and control more serious. I am still finding the most neglected critical safety equipment is the emergency response and control equipment. I recently conducted an audit on a major drilling contractors rig, leased to a major oil company, where the life saving and firefighting equipment was the worse I had seen in years. For example, the escape capsule had a critical equipment maintenance backlog over 3 pages long and some of these items were 180 days overdue. The maintenance log actually indicated that these maintenance items were the responsibility of the medic. What? The secondary emergency evacuation station had capacity 5 personnel less than the rig POB capacity. The justification for this was the FRC (Fast Rescue Craft) would supplement for those extra persons. Before we start referencing SOLAS and MODU requirements, let me say that this was an older rig operating under the MODU 1979 guidelines which made this apparently possible.

Let’s read what the SEMS regulations for Emergency Response and Control. 30 CFR 250.1918 states:

§ 250.1918 What criteria for emergency response and control must be in my SEMS program?

Your SEMS program must require that emergency response and control plans are in place and are ready for immediate implementation. These plans must be validated by drills carried out in accordance with a schedule defined by the SEMS training program (§ 250.1915). The SEMS emergency response and control plans must include:

(a) Emergency Action Plan that assigns authority and responsibility to the appropriate qualified person(s) at a  for initiating effective emergency response and control, addressing emergency reporting and response requirements, and complying with all applicable governmental regulations;

(b) Emergency Control Center(s) designated for each facility with access to the Emergency Action Plans, oil spill contingency plan, and other safety and environmental information (§ 250.1910); and

(c) Training and Drills incorporating emergency response and evacuation procedures conducted periodically for all personnel (including contractor’s personnel), as required by the SEMS training program (§ 250.1915). Drills must be based on realistic scenarios conducted periodically to exercise elements contained in the facility or area emergency action plan. An analysis and critique of each drill must be conducted to identify and correct weaknesses.

As you can see, the SOLAS, MODU and BSEE regulations make it all possible for the above scenario to be legal. The regulators couldn’t force this company to do anything different. So they thought…

We have discussed numerous times in the blogs and SEMSinars ™ that your SEMS program is based on hazard analysis, which must be reviewed annually. Would you need a college degree or numerous years’ experience to determine that if guys are forced to disembark from a rig on fire in an open top FRC that their chance of survival would be negligible?

Employees at all levels need to identify problems and use the management system provided to them to force these changes. Initiate a MOC process stating safety concerns or something. You will not be able to do anything from the grave.