GCEAG Meeting January 12, 2012

 NPR Issued September 14, 2011  Comments were due November 14, 2011  Focuses on six new or expanded items  Stop work provision  Definition of authority  Employee participation  Reporting of unsafe work conditions  Use of independent third party auditors  Additional requirements of Job Safety Analyses

 Stop Work Authority (SWA) ◦ Give responsibility and authority to stop any activity that creates an imminent risk or danger to individual, public or environment to all employees and contractors for any BSEE regulated activity  PIC of activity must ensure work is stopped (orderly and safe manner)  Person with ultimate work authority makes decision to resume activities and documents his decision ◦ SWA Policy must be reviewed as part of all safety meetings and JSAs ◦ Training and review records must be kept on the facility for 30 days

 Ultimate Work Authority (UWA) ◦ Identify one person on facility with final responsibility for making decisions ◦ Everyone on facility must know this person by name and be readily identifiable and accessible (post notice) ◦ Assumes key role in assuring SEMS program is implemented ◦ In emergency, UWA is authorized to pursue action to mitigate and abate conditions

Employee Participation  Requires management to: ◦ Consult with employees (office and field) on the development and implementation of company's SEMS program ◦ Develop action plan outlining how employees will participate in development and implementation of program  Each employee and contractor employee required to have access to SEMS program and other API RP 75 info

Reporting Unsafe Work Conditions  Procedures for all personnel to report unsafe work conditions ◦ In writing or by telephone to a BSEE hotline ◦ Must contain sufficient credible information for BSEE to determine that legal or regulatory violations have occurred or that an unsafe working conditions exist ◦ Include USCG unsafe working conditions reporting requirements

 Reporting Unsafe Work Conditions ◦ Post a notice explaining personnel rights and remedies ◦ Train personnel on the unsafe work conditions policy  Within 30 days of employment  Every 12 months thereafter ◦ Provide each person with the BSEE hotline number

Job Safety Analysis – Additional Requirements ◦ JSAs must be developed and implemented for each BSEE-regulated activity identified in SEMS program  Immediate supervisor:  Prepares and signs JSA  Ensures all personnel participating in job sign JSA  Onsite PIC of facility:  Approves, signs and documents results of JSA  Conduct training for all personnel on how to recognize and identify hazards  w/n 30 days of employment  Every 12 months thereafter

 Auditing Requirements  Requires SEMS programs to be audited ◦ An independent third party must perform the audit ◦ Requires BSEE approval of the third party auditor ◦ Nominate the third party auditor in writing at least 30 days prior to the audit  Identify the individual  Describe specific qualifications  Include a statement by the management that the nominated auditor is "not owned or controlled by, or otherwise affiliated with, the operator's company"

11  Training must address:  Operating procedures  Safe work practices  Emergency response and control measures  You must document the qualifications of your instructors

Your SEMS program must address:  (a) Initial training: ◦ For the basic well-being of personnel and protection of the environment ◦ Ensure persons assigned to operate and maintain the facility possess the required knowledge and skills to carry out their duties and responsibilities, including startup and shutdown

 Periodic training to maintain understanding of, and adherence to, the current operating procedures, using periodic drills, to verify adequate retention of the required knowledge and skills.

 Communication requirements to ensure that whenever a change is made to operating procedures, the safe work practices, or the emergency response and control measures, personnel will be trained in or otherwise informed of the change before they are expected to operate the facility

 How you will verify that the contractors are trained in the work practices necessary to perform their jobs in a safe and environmentally sound manner, including training on operating procedures (§ ), the safe work practices (§ ), or the emergency response and control measures (§ ).

Safety and Environmental Management Systems Potential Incident of Noncompliance (PINC) List 63 New PINCs From Warnings to Shut-ins

 General Element ◦ Management’s General Responsibilities ◦ Three PINCs  Safety & Environmental Information ◦ Three PINCs  Environmental ◦ Twelve PINCs!  Hazards Analysis ◦ Four PINCs

 Management of Change ◦ Four PINCs  Operating Procedures ◦ Two PINCs  Safe Work Practices ◦ Nine PINCs  Training ◦ Three PINCs

 Assurance of Quality and Mechanical Integrity of Critical Equipment ◦ Five PINCs  Pre-Startup Review ◦ One PINC  Emergency Response and Control ◦ Two PINCs  Investigation of Incidents ◦ Three PINCs

 Audit of SEMS Elements ◦ Six PINCs  Records and Documentation ◦ Six PINCs

 Contact us: Jodie Connor, Ken Smith or Rebekka Milton