The SEMS Program and Employee Involvement
A recently proposed amendment to the US regulation 30 CFR 250 Subpart S, which established Safety and Environmental Management Systems (SEMS) rules, requires that operators establish an action plan to ensure all personnel participate in implementing SEMS. OCS operators already rely on knowledgeable workers as an integral part of their safety efforts. To meet safety goals, operators need personnel knowledge and experience. Acting as eyes, ears, and hands, workers observe and report, make suggestions, and promote continuous improvement efforts. By participating in the SEMS process, they help make the workplace safer for everyone.
- General Provisions Operators work with all personnel, including contractors, to develop safety and environmental processes. Workers can observe and report issues, participate in safety analyses and investigations, and suggest improvements to equipment, procedures, and practices.
- Safety and Environmental Information Operators maintain safety and environmental information about all facilities. If employees see something has changed, they should report it so it can be documented.
- Hazards Analyses To manage workplace risk, operators carry out regular hazards analyses and job safety analyses. Personnel can contribute to both by sharing safety knowledge and identifying ways to improve worker and environmental safety.
- Management of Change Employees are encouraged to suggest changes to improve safety. To manage risks associated with making changes to equipment, procedures, personnel, and other conditions, operators use a written management of change process.
- Operating Procedures Operators need all personnel to participate in the development of safe, environmentally sound methodologies. They can help by making suggestions to improve readability and usability of written procedures.
- Safe Work Practices All personnel receive training about critical safe work practices. All should share what they know with their fellow workers, keep an eye open for the safety of themselves and others, and, as appropriate, use the Stop Work Authority program to halt an unsafe practice in progress.
- Training All personnel are trained to work safely and with awareness of environmental considerations. Operators need everyone to help identify any training inadequacies.
- Mechanical Integrity Part of providing a safe workplace is making sure equipment is working as designed. Personnel should report maintenance issues to their supervisors.
- Pre-Startup Review Before facilities are started up, operators make sure the system settings are correct and the equipment is ready to operate as designed. All personnel on hand for startup participate in this review.
- Emergency Response and Control Personnel must ensure they know what to do in case of an emergency, who is in charge, and who to notify. All workers must actively participate in all emergency response drills, know where their muster stations are, report as directed, and assist others who may need help.
- Investigation of Incidents Operators have procedures for investigating accidents, incidents, near-misses, and non-compliances. Personnel participate by reporting incidents when they occur and participating in investigations.
- Auditing Employees asked to participate in an audit must answer all questions truthfully and completely. Audits enable the creation of corrective plans that will help achieve safety and environmental goals.
- Records and Documentation As part of regulatory compliance activities, operators generate and retain SEMS records and documents. We also make SEMS publications available for personnel use and ongoing training.