SEMS Element #2- Safety and Environmental Information

 

The importance of this SEMS element is not indicated by the section size in 30CFR 250.1910. If you have not yet read my blog on Hazard Analysis Methodology, I recommend you read it. These two SEMS elements are intertwined. Let’s take a look at section 250.1910 in its entirety.

§ 250.1910   What safety and environmental information is required?

(a) You must require that SEMS program safety and environmental information be developed and maintained for any facility that is subject to the SEMS program.

(b) SEMS program safety and environmental information must include:

(1) Information that provides the basis for implementing all SEMS program elements, including the requirements of hazard analysis (§ 250.1911);

(2) process design information including, as appropriate, a simplified process flow diagram and acceptable upper and lower limits, where applicable, for items such as temperature, pressure, flow and composition; and

(3) mechanical design information including, as appropriate, piping and instrument diagrams; electrical area classifications; equipment arrangement drawings; design basis of the relief system; description of alarm, shutdown, and interlock systems; description of well control systems; and design basis for passive and active fire protection features and systems and emergency evacuation procedures.

We see that section (b)(1) above references (SEMS I) § 250.1911. Below are the revisions which occurred when SEMS II was issued earlier this year:

(SEMS II) § 250.1911  What hazards analysis criteria must my SEMS program meet?

You must ensure that a hazards analysis (facility level) and a JSA (operations/task level) are developed and implemented for all of your facilities and activities identified or discussed in your SEMS.

We clarified the definition of facility in the previous Hazard Analysis Methodology blog. However, because it contradicts a common statement in API RP75 about MODUs not requiring a hazard analysis, see below from 30CFR 250.105:

§ 250.105   Definitions.

Facility means:

(5) As used in Subpart S of this part, all types of structures permanently or temporarily attached to the seabed ( e.g., mobile offshore drilling units (MODUs); floating production systems; floating production, storage and offloading facilities; tension-leg platforms; and spars) that are used for exploration, development, and production activities for oil, gas, or sulphur in the OCS. Facilities also include DOI-regulated pipelines.

To address section (b)(2) and (b)(3), chances are you already have many of these items already. These items are common in the industry and used frequently as a method for conducting the hazard analysis.

In reference to MODUs and other foreign flagged facilities, much of this information can be pulled from the requirements set forth by your flag state and classification society.

The NTL 2011- N09 SEMS Guidance states that your environmental review must follow requirements set forth in regulations, clarifying NTL’s, lease stipulations, mitigations, and conditions of approvals. The reference to NTL’s is huge as industry has referred to these documents as “not the law” in the past. This NTL further clarifies that you must address environmental requirements throughout all phases including planning, implementation, operation, verification, corrective actions, management review and continual improvement. While this NTL section doesn’t mention safety, only environmental, it should be obvious that both safety and environmental shall be addressed.

Also worth pointing out is sect 2.3.5 of the API RP 75 which requires ASTM F1166-95 Human Engineering Design for Marine Systems, Equipment and Facilities to be considered when designing and installing new facilities or in the modification of existing facilities. As this document is not referenced in 30CFR 250.198, it can easily be missed and therefore get you on that BSEE radar.