SEMS Element #5- Operating Procedures

By now, as the previous SEMS blogs (particularly blog #11 and #12) and SEMSinar™ series have discussed, we should all know operating procedures are required for all hazards identified in our SEMS program using the hazard analysis methodology from API RP 14J. This API is also listed as a document incorporated by reference in 30CFR 250.198(h)(62). So the number and amount of detail required in the operating procedures will be based from the analysis. However 30CFR 250.1913 indicates the following minimums, which must be addressed in your procedures.

§ 250.1913 What criteria for operating procedures must my SEMS program meet?

a)       You must develop and implement written operating procedures that provide instructions for conducting safe and environmentally sound activities involved in each operation addressed in your SEMS program. These procedures must include the job title and reporting relationship of the person or persons responsible for each of the facility’s operating areas and address the following:

1)       Initial startup;

2)       Normal operations;

3)        All emergency operations (including but not limited to medical evacuations, weather-related evacuations and emergency shutdown operations);

4)       Normal shutdown;

5)       Startup following a turnaround, or after an emergency shutdown;

6)       Bypassing and flagging out-of-service equipment;

7)       Safety and environmental consequences of deviating from your equipment operating limits and steps required to correct or avoid this deviation;

8)       Properties of, and hazards presented by, the chemicals used in the operations;

9)       Precautions you will take to prevent the exposure of chemicals used in your operations to personnel and the environment. The precautions must include control technology, personal protective equipment, and measures to be taken if physical contact or airborne exposure occurs;

10)   Raw materials used in your operations and the quality control procedures you used in purchasing these raw materials;

11)    Control of hazardous chemical inventory; and

12)   Impacts to the human and marine environment identified through your hazards analysis.

b)       Operating procedures must be accessible to all employees involved in the operations.

c)         Operating procedures must be reviewed at the conclusion of specified periods and as often as necessary to assure they reflect current and actual operating practices, including any changes made to your operations.

d)       You must develop and implement safe and environmentally sound work practices for identified hazards during operations and the degree of hazard presented.

e)       Review of and changes to the procedures must be documented and communicated to responsible personnel.

1913(a) has a statement referencing job titles, reporting relationships and persons responsible. At the benefit of not regurgitating previous blog information where I may not adequately address all concerns, I would recommend reading the previous SEMS blogs related to those subjects (particularly blog two,four, five, six, seven, eight, nine, and). All of those blogs have vital information related to that simple statement 1913(a).

I will tell you that according to BSEE statistics, since 1998 35% of penalty cases are related to items in bypass, blocked valves/ lines or manipulation of sensors. Additionally, 20% of penalty cases resulted from inadequate inspection/ testing, leaking equipment, or failed equipment. From 2008 to 2012, 19% of penalty cases resulted from open holes or risk of falls and 10% from excessive corrosion or wear.  During this same time frame, 11% resulted from a fire risk, gas detection, tubing plug leakage, or no lock out/ tag out. Nearly 8% of penalty cases resulted from pollution incidents or gas releases. One can see that OSHA requirements are becoming more prevalent on the OCS. I have heard that OSHA and BSEE have held more meetings over the past few years than in history.

We will discuss many of these items in length during the SEMSinar™ scheduled for July 25^th. Registration as well as previous blogs and SEMSinars™ are available at https://www.360factors.com/webinars.