SEMS II – Are You Ready? MODERATOR: Greg Gordillo SEMS Product Manager SEMS Auditor: Dane Kennedy Bureau Veritas Sr. HSEQ Consultant: Brant Butler The Wood Group

Meet our Facilitators Greg Gordillo Brant Butler – Wood Group ODL Bob Moir – Wood Group ODL Jim Molloy (Guest Storyteller) – Wood Group ODL COS? BV Auditor? Each facilitator

Agenda Employee Participation JSA – Job Safety Analysis Reporting Unsafe Work Conditions Auditing SWA – Stop Work Authority UWA – Ultimate Work Authority Going Forward Vessels Contractors

Is your company prepared to meet the Standards of SEMS II? Poll Question #1 Is your company prepared to meet the Standards of SEMS II? Possible Responses: 1 YES 2 NO 3 NOT SURE How many members in the audience have some type of a supplier assessment program in place? 4

Poll Question #1 SHOW POLL RESULTS 5 How many members in the audience have some type of a supplier assessment program in place? 5

SEMS Elements (1) General (2) Safety and Environmental Information) (3) Hazards Analysis (4) Management of Change (5) Operating Procedures (6) Safe Work Practices (see § 250.1914) (7) Training (8) Mechanical Integrity (Assurance of Quality and Mechanical Integrity of Critical Equipment) (see § 250.1916) (9) Pre-startup Review (10) Emergency Response and Control (11) Investigation of Incidents Auditing (Audit of Safety and Environmental Management Program Elements) Recordkeeping (Records and Documentation) and additional BSEE requirements Stop Work Authority (SWA) Ultimate Work Authority (UWA) Employee Participation Plan (EPP) Reporting Unsafe Working Conditions Our topics of discussion today include the following. So let’s get started!

SEMS Milestones NEED TO FIX – PERHAPS WITH CALENDAR WITH DATE CIRCLED!!!!

SEMS Milestones

SEMS Milestones DATES: This rule became effective on June 4, 2013. You must comply with the provisions of this rule on or before June 4, 2014, except the auditing requirements under§ 250.1920. You must be in compliance with § 250.1920 by June 5, 2015.

SEMS II – Dates in History June 4 and 5 Some Very Important Dates in History 1892 – Oil City & Titusville PA destroyed by oil tank explosion – 130 dead 1940 – First synthetic rubber tire is unveiled 1965 – Rolling Stones release “Satisfaction” 1989 – 100 perish after gas explodes near passenger train in USSR 2014 – Compliant with § 250.1920 5 JUNE 2015 – I3P Audit Completed Brant

What does she have to do with SWA? Brant Multiple song references Novel by Dean Koontz refers to her Mentioned as an example in The Boondock Saints This woman and the events she was ultimately famous for have led to several movies, books, TV shows and documentaries.

Employee Participation Employee Participation Plan (EPP) - Provides an environment that promotes participation by employees and management in order to eliminate or mitigate hazards on the OCS. Your management must: (a) Consult with their employees on the development, implementation, and modification of your SEMS program. (b) Develop a written plan of action regarding how your appropriate employees, in both your offices and those working on offshore facilities, will participate in your SEMS program development and implementation. (c) Ensure that employees have access to sections of your SEMS program that are relevant to their jobs.

Hazard Analysis Criteria (§ 250.1911) BSEE now requires the operator to prepare, conduct, and approve JSAs for OCS activities identified or discussed in its SEMS program. Brant

JSAs JSA’s The JSA is a tool used to identify risks to personnel associated with their job activities. The JSAs are also used to determine the appropriate risk mitigation measures. Brant

New JSA Requirements People Involved Responsibility Signature Required? Workers Performing Job Being aware of and mitigating hazards YES Our topics of discussion today include the following. So let’s get started!

New JSA Requirements People Involved Responsibility Signature Required? Immediate Crew Supervisor Conduct JSA; Ensure All Workers Sign YES Our topics of discussion today include the following. So let’s get started!

New JSA Requirements People Involved Responsibility Signature Required? Person in Charge Approve JSA YES Our topics of discussion today include the following. So let’s get started!

History Channel documentary on History’s Mysteries Hint: Multiple episodes of Law & Order discuss her or is loosely based on her History Channel documentary on History’s Mysteries Numerous case study’s typically involving the notion of Altruism: the principle or practice of concern for the welfare of others Jim

Reporting Unsafe Work Conditions Reporting Unsafe Working Conditions - Empowers all personnel to report to BSEE possible violations of safety or environmental regulations and requirements and threats of danger.

Reporting Unsafe Working Conditions Reporting Unsafe Working Conditions - Empowers all personnel to report to BSEE possible violations of safety or environmental regulations and requirements and threats of danger. Establish guidelines for workers to report unsafe working conditions directly to BSEE Violations of safety, environmental regulations and threats of danger Post notice to provide workers with BSEE contact information (found in 30 CFR 250.193) BSEE Toll-Free Safety Hotline 1-877-440-0173 www.bsee.gov All personnel are permitted, under § 250.193, to report to BSEE any hazardous or unsafe working conditions and any possible violations of an order, regulation, or any other provision of Federal law relating to offshore safety. Section 250.1933 of the final rule requires the operator to develop procedures for reporting unsafe working conditions. These procedures must take into account the existing USCG unsafe working conditions reporting requirements currently found at 33 CFR part 142.7 and 46 CFR part 109.419. All personnel are permitted, under § 250.193, to report to BSEE any hazardous or unsafe working conditions and any possible violations of an order, regulation, or any other provision of Federal law relating to offshore safety. Section 250.1933 of the final rule requires the operator to develop procedures for reporting unsafe working conditions. These procedures must take into account the existing USCG unsafe working conditions reporting requirements currently found at 33 CFR part 142.7 and 46 CFR part 109.419.

Do you have an SWA policy in place? Poll Question #2 Do you have an SWA policy in place? Possible Responses: 1 YES 2 NO 3 NOT SURE How many members in the audience have some type of a supplier assessment program in place? 21

Poll Question #2 SHOW POLL RESULTS 22 How many members in the audience have some type of a supplier assessment program in place? 22

How many of you would exercise your SWA if presented with a situation? Poll Question #2 How many of you would exercise your SWA if presented with a situation? Possible Responses: 1 YES 2 NO 3 NOT SURE How many members in the audience have some type of a supplier assessment program in place? 23

Poll Question #2 SHOW POLL RESULTS 24 How many members in the audience have some type of a supplier assessment program in place? 24

Hint: New York City – March, 1964

Do you have SWA? 97% polled stated that they have SWA in a recent study Would you speak up?

Auditing 2. Auditing - Requires that all SEMS audits must be conducted by an audit service providers (ASPs), accredited by a BSEE-approved accreditation body (AB). The Lead Auditor MUST be Accredited Audit Service Provider (ASP) The ASP must be accredited by a BSEE-approved Accreditation Body (AB) Other team members may be employees of the operator or ASP BSEE extended filing time for Audit Reports and CAPs

Auditing Requirements (§ 250.1920) Operators to conduct a comprehensive SEMS audit within a 3-year cycle. This final rule clarifies that the cycle begins on the start date of each audit (including the initial implementation audit) and ends on the start date of the next audit. An operator’s SEMS program must be audited by an accredited ASP Requirements of Subpart S. Operators must include the ASP’s qualifications in their audit plans. Operators must also provide BSEE with a copy of the audit report and their CAP within 60 days of the audit (previous CAP due within 30 days)

Audit Service Provider Rules The audit team lead must be an ASP employee, representative, or agent, and must not have any affiliation with the operator. The remaining team members may either be operator personnel or that of the ASP. Operators now have the flexibility to utilize in-house expertise on the audit team. This rule adopts the latest industry standards related to auditor qualifications.

Training Criteria (§ 250.1915) All personnel (contractors and employees) must be trained in their responsibilities, including: Assigned duties Work safely Environmental Impacts Facility-specific operating procedures (§ 250.1913), Safe work practices (§ 250.1914), Emergency response and control measures (§ 250.1918), SWA (§ 250.1930) UWA (§ 250.1931) EPP (§ 250.1932) Reporting unsafe working conditions (§ 250.1933) How to recognize and identify hazards (§ 250.1911) How to construct and implement JSAs (§ 250.1911). There are three (3) things I want you to remember about Element 7 under SEMS: Contractors and employees must not only understand their assigned duties, but they should understand how THEIR assigned duties affect those around them and vice versa A Trained employee or contractor is not enough to meet SEMS Element 7 criteria. ALL employees and contractors MUST be trained on how YOUR facility operates. Employees and contractors should know HOW to identify hazards, construct a detailed JSA, work safely, and IMMEDIATELY STOP WORK and report unsafe work conditions

Don’t Think This Doesn’t Apply to YOU! Not only your full time employees, but if you are a contractor working for an operator, these rules apply equally to you

SEMS Moving Forward – Competence More prescriptive approach for establishing worker qualifications and evidence of capabilities Observation s Interviews Simulation Assessment Recording Here we can go into a little more detail regarding competence. Unfortunately, for YEARS, the Oil and Gas Industry felt that after an employee or contractor earned a certificate during a training program, that was somehow a sheepskin pronouncing an individual’s competence. However, this is not the case. Competence is observable behavior of an individual performing to a defined standard. Period. Although a training program can help an individual acquire knowledge and skills, it is the safe, repeated, and successful application of those skills in the work environment over a prolonged period of time that defines whether or not someone is competent. As you can see from this slide, there are several ways to collect information to make a determination regarding a person’s competence. We recommend employing a variety of methods. Other methods include written reports from an Expert Witness, Analysis of Executed JSA’s, Successful Participation in Turnaround Teams, etc. You are encouraged to employ methods that are best suited for the individual’s role to safely demonstrate their competence.

SEMS Moving Forward – Competence Company’s SEMS Plan Words written on a resume On-the-job Behavior This is one of my favorite slides. Basically, your company’s SEMS Plan is very much like words written on a resume. The words are there, but how do those words compare to what people are doing on the job when no one is looking? When your workers, whether they are employees or contractors are motivated by staying safe, following procedure, and doing what is right for themselves and their coworkers, we can achieve a state where “Everyone, everywhere, everyday [is] - safe home. Worker values, beliefs, and motivations Photo source: http://www.alaskasview.com/newsite/img/parallax.iceberg.png

What Percentage of Your Workers Have Been Assessed? Poll Question #3 What Percentage of Your Workers Have Been Assessed? Jim 34

Poll Question #1 SHOW POLL RESULTS 35 How many members in the audience have some type of a supplier assessment program in place? 35

Ongoing SEMS Updates Web Site: CenterForOffshoreSafety.org

Have you been audited against RP 75 SEMS? Poll Question #4 Have you been audited against RP 75 SEMS? Jim 37

Poll Question #3 SHOW POLL RESULTS 38 How many members in the audience have some type of a supplier assessment program in place? 38

Hint: Queens, New York City

Stop Work Authority (SWA) Stop Work Authority (SWA) - Creates procedures that establish SWA and make responsible any and all personnel who witness an activity that is creating imminent risk or danger to stop work. Create and implement a SWA program  All personnel – given responsibility and authority to stop work if they witness an activity that creates imminent risk to health or safety of an individual or to the environment  PIC of the activity - Stop work in an orderly/safe manner  Person with UWA allows work to resume after determining risk/danger does not exist (or no longer exists)  Include training during orientation  Include SWA procedures in all JSAs

Ultimate Work Authority Ultimate Work Authority (UWA) - Clearly defines requirements establishing who has the UWA on the facility for operational safety and decision-making at any given time. Designate one individual with UWA on facility for operational safety and decision-making Simultaneous Operations - UWA over entire operation clearly defined PIC at all times Keep everyone advised of person with UWA UWA is authorized to pursue the most effective action necessary in that individual’s judgment for mitigating and abating risk Add to SEMS training criteria

SEMS Scope Expanding to Contractors SEMS Moving Forward SEMS Scope Expanding to Contractors Bob

SEMS Moving Forward – Contractors BSEE is evaluating the possibility of requiring contractors to have a SEMS program while performing operations on the OCS. Currently, all personnel, which includes contractors, must be trained in accordance with the requirements of § 250.1915 prior to performing a job. In accordance with § 250.1914, operators must ensure that contractors have their own written safe work practices. Contractors may adopt appropriate sections of an operator’s SEMS program. Operators and contractors must document an agreement on appropriate contractor safety and environmental policies and practices before the contractor begins work at an operator’s facilities. Bob

Poll Question #3 How many Contractors in the audience have gone through more than 3 SEMS audits in the last year? 44

Poll Question #1 SHOW POLL RESULTS 45 How many members in the audience have some type of a supplier assessment program in place? 45

SEMS Scope Expanding to Vessels SEMS Moving Forward - Vessels SEMS Scope Expanding to Vessels

Hint: The event she is famous for, led to the creation of the terms: “Bystander Effect” “Diffusion of Responsibility” BRant

2010 Study of Safety Intervention SWA Behavior The Bystander Effect: Diffusion of Responsibility: Confirmation Bias: 39% Speak Up 61% Bystander 2010 Study of Safety Intervention Brant The Bystander Effect: The more people = Smaller chance of someone speaking up Diffusion of Responsibility: A person is less likely to take action when others are present, believing someone else is taking action or already done so Confirmation Bias: Justifying are previous conclusions “Somebody else will tell them” “The boss walked by and he didn’t say anything, it must not be a big deal” “He knows what he’s doing” “It’s not my job”

“Kitty Genovese” – The Genovese Effect/Syndrome Stabbed to death near her home on March 13, 1964 It was found out that somewhere between 12-38 people heard her screaming and some even saw her stumbling in the road after being stabbed the first time She stumbled and collapsed right outside her building, no one called the police or went to check on her even after she had been yelling for help and even screamed “Oh my God, he stabbed me! Help me! Help me! 10 minutes later the killer showed back up wearing a hat to shield his face from passerby and found her, still conscious – he then stabbed her several more times, raped her and took her money Social in-congruence and Confirmation Bias led to Kitty’s death and even today, we are told to shout “fire!” instead of “help!” because of this

If you would like more information, please contact me. Questions If you would like more information, please contact me. THANK YOU! Greg Gordillo Greg.gordillo@us.bureauveritas.com 281-310-3088 Brant Butler Brant.Butler@Woodgroup.com 281-647-8496 Eric Roan / Om Chawla RoanE@CenterForOffshoreSafety.org 832-495-4925