SEMS Element #3- Hazard Analysis- Methodology

 

I am frequently asked what I consider to be the element of SEMS the industry is struggling most with. I always answer Element #3- Hazard Analysis. 30CFR 250.198 references many standards, recommended practices, etc. On the surface, 250.198 tends to fall short when it comes to Hazard Analysis methodologies for anything but floating production facilities. You will see what I mean below:

§ 250.198   Documents incorporated by reference.

(h)(62) API RP 14J, Recommended Practice for Design and Hazards Analysis for Offshore Production Facilities, Second Edition, May 2001; reaffirmed: March 2007; incorporated by reference at §§ 250.800 and 250.901;

30CFR 250.800 deals with production safety systems and clearly states it applies to floating production systems (FPSs).

30CFR 250.901 states:

§ 250.901   What industry standards must your platform meet?

(a)     In addition to the other requirements of this subpart, your plans for platform design, analysis, fabrication, installation, use, maintenance, inspection and assessment must, as appropriate, conform to:

(14) API RP 14J, Recommended Practice for Design and Hazards Analysis for Offshore Production Facilities, (as incorporated by reference in § 250.198);

The table in 250.901(c) states that API RP 14J applies only to FPSs and there is no Hazard Analysis methodology requirement at this point for any other OCS operations.

Let’s see if we can get clarification from the incorporated by reference API RP 75. Before I reference API RP 75, I would like to remind you of 30 CFR 250.1904:

§ 250.1904   Documents incorporated by reference.

If any incorporated document uses the word “should”, it means must for purposes of these regulations.

API RP 75 Section 3.2 Hazard Analysis Methodology, in summary, states management must determine whether additional analysis techniques are warranted. It also states API RP 14J must be consulted for guidance. However, API RP 75 Section 3.2.2 deals with MODU’s and starts to confuse the clarification that section 3.2 seemed to clear up. To further confuse the issue, SEMS II 30CFR 250.1911 removed the clarification that SEMS I 30CFR 250.1911 provided. See below:

(SEMS I) § 250.1911 What criteria for hazards analyses must my SEMS program meet?

You must ensure the development and implementation of a hazards analysis (facility level) and a job safety analysis (operations/task level) for all of your facilities. For this subpart, facilities include all types of offshore structures permanently or temporarily attached to the seabed ( i.e., mobile offshore drilling units; floating production systems; floating production, storage and offloading facilities; tension-leg platforms; and spars) used for exploration, development, production, and transportation activities for oil, gas, or sulphur from areas leased in the OCS.

(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. You must document and maintain a current analysis for each operation covered by this section for the life of the operation at the facility. You must update the analysis when an internal audit is conducted to ensure that it is consistent with your facility’s current operations.

However, BSEE did provide clarification in 30CFR 250.105 for the definition of ‘Facility’ with the issuance of SEMS II;

§ 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.

So, now we know what Hazard Analysis methodology BSEE requires OCS operations of all types and levels to utilize.