SEMS Element #6- Safe Work Practices and Contractor Selection

This is a huge subject to try and cover in a blog set to average 500 words. So I will state in advance that I highly recommend you attend the SEMSinar™ scheduled for the 25^th at 1:PM. You can register to attend at https://www.360factors.com/webinars/.

However, we will cover some points for discussion in this blog as the majority of lease operators will have contractors performing a majority of the work for them. So let us look at what the 30CR 250.1914 says:

§ 250.1914   What criteria must be documented in my SEMS program for safe work practices and contractor selection?

Your SEMS program must establish and implement safe work practices designed to minimize the risks associated with operations, maintenance, modification activities, and the handling of materials and substances that could affect safety or the environment. Your SEMS program must also document contractor selection criteria. When selecting a contractor, you must obtain and evaluate information regarding the contractor’s safety record and environmental performance. You must ensure that contractors have their own written safe work practices. Contractors may adopt appropriate sections of your SEMS program. You and your contractor must document an agreement on appropriate contractor safety and environmental policies and practices before the contractor begins work at your facilities.

a)       A contractor is anyone performing work for you. However, these requirements do not apply to contractors providing domestic services to you or other contractors. Domestic services include janitorial work, food and beverage service, laundry service, housekeeping, and similar activities.

b)       You must document that your contracted employees are knowledgeable and experienced in the work practices necessary to perform their job in a safe and environmentally sound manner. Documentation of each contracted employee’s expertise to perform his/her job and a copy of the contractor’s safety policies and procedures must be made available to the operator and BSEE upon request.

c)        Your SEMS program must include procedures and verification for selecting a contractor as follows: 

1)       Your SEMS program must have procedures that verify that contractors are conducting their activities in accordance with your SEMS program.

2)       You are responsible for making certain that contractors have the skills and knowledge to perform their assigned duties and are conducting these activities in accordance with the requirements in your SEMS program.

3)       You must make the results of your verification for selecting contractors available to BSEE upon request.

d)       Your SEMS program must include procedures and verification that contractor personnel understand and can perform their assigned duties for activities such as, but not limited to:

1)       Installation, maintenance, or repair of equipment;

2)       Construction, startup, and operation of your facilities;

3)       Turnaround operations;

4)       Major renovation; or

5)       Specialty work.

e)       You must:

1)       Perform periodic evaluations of the performance of contract employees that verifies they are fulfilling their obligations, and

2)       Maintain a contractor employee injury and illness log for 2 years related to the contractor’s work in the operation area, and include this information on Form BSEE-0131.

f)        You must inform your contractors of any known hazards at the facility they are working on including, but not limited to fires, explosions, slips, trips, falls, other injuries, and hazards associated with lifting operations.

g)       You must develop and implement safe work practices to control the presence, entrance, and exit of contract employees in operation areas.

I can tell you this that the majority of lease operators I have conducted audits on fail miserably at managing their contractors. They just simply say that we use their safe work practices as they do the work. Well that is an acceptable way to conduct your operations. But then your responsibility shifts from conducting the work to managing the work. Sounds simple, but take a huge commitment from management. I believe that when we have the SEMSinar™, time management will be an issue on this subject.