Now that we have discussed what BSEE expects to be some of the Management of Change (MOC) initiating actions, let’s discuss how your MOC process should be structured. In my opinion, the steps I have outlined below will help drive yo...

I get asked frequently, “What is the definition of periodic?”. Well the actual definition of periodic, in relation to training, is located in the 30 CFR 250.1500 Subpart O- Well Control and Production Safety Training:  § 250.15...

§ 250.1915 What criteria for training must be in my SEMS program? Your SEMS program must establish and implement a training program so that all personnel are trained to work safely and are aware of environmental considerations...

For this blog subject, I would like to discuss how to verify an understanding and adherence to the current operating procedures. This can be done by initiating a competency assessment program that contains procedures for educating you...

This blog topic is related to a previous blog named Demand Accountability.  However, I wanted to get a little more specific with this one as I am seeing issues with the industry adequately addressing this requirement. I hear all of t...

In this blog #6 of the series, I would like to discuss resources that your company through its management must provide to ensure that all personnel are complying with the policies and procedures of your SEMS. Blog #5, among other thin...

We know SEMS requires an audit to be conducted within 2 yrs. of your SEMS implementation date of 15 Nov. 2011 as per 30CFR 250.1920(b)(6). That means you must have your 1st audit completed by 15 Nov. 2013. § 250.1920 What are the au...