Contractors SEMS requirements

Activities and areas for the audit should be defined in the SEMS Management Document. It is important to give this topic sufficient consideration. It will include physical boundaries (for example, whether subsea pipelines are included), and organizational issues such as the relationship with contractors. The requirement for 15 percent coverage is substantial. 

Aii Contractor empioyees are knowiedgeabie of Operator SEMS requirements appiicabie to the Contractor s assigned work ... 

Contractors are required to train their personnel. Although contractors are responsible for training their people, the ultimate SEMS responsibility for safe operations rests with the facility operator. 

Security requires looking more closely into hiring and training practices. Companies are getting much better on this front, particularly in contractor hiring, which had been a real Achilles heel two years ago, Sem says. 

DOI and BSEE have developed additional safely requirements in the form of Notices to Lessees and Operators or NTLs, which, for example, require corporate-level affirmation of operator compliance (NTf io) and operator demonstration that it is prepared to deal with a blowout and worst-case discharge (NTL-06). A DOI official has also promised that BSEE s regulatory reach will he extended to include application of SEMS to contractors without detracting from the principle of holding operators fully responsible for contractor performance. Thus, step hy step, DOI and BSEE are trying to address the root causes of the Macondo accident, remedy deficiencies in the prior MMS approach, and thereby improve key aspects of industrial safety performance. 

The responsibility for implementing SEMS lies with the operator, although, as discussed below, recent guidance from BSEE requires that contractors also have a SEMS program. 

You are responsibie for making certain that contractors have the skiiis and knowiedge to perform their assigned duties and are conducting these activities in accordance with the requirements in your SEMS program. 

A discussion to do with the management of contractors is provided on page 63639 of the SEMS rule and is shown in Table 6.4. The first column shows the BSEE requirements the second column provides some discussion as to what needs to be done to meet those requirements. 

The operator will have to show explicitly how his SEMS program, the bridging documents and the contractor s Safety Management System address the requirements of SEMS and RP 75. This is not a trivial task. 

All activities performed by the Contractor will be conducted in accordance with the requirements in the Operator s SEMS program and the Contractor s Safe Work Practices ... 

Operator has obtained and reviewed the Contractor s HSE Management System, and/or safe work practices, as applicable, and related documentation and has found it meets the requirements of the Operator s SEMS.Contractor has reviewed, as applicable, and understands Operator s SEMS as it applies to all work performed hereunder. Contractor further confirms that it can and will perform its duties and conform to all applicable elements of Operator s SEMS. 

RP 75 does not require that contractors develop their own SEMP, but it does recommend that the contractors be familiar with the operator s SEMP (this recommendation becomes a requirement imder SEMS, as discussed in the next chapter. Ultimately, it is the operator of a lacility who is responsible for the SEMP. 

Incidents/Incident Investigation are virtually the same. Probably, the two bluest differences are to do with Employee Participation and Contractors. The Employee Participation element is not found in SEMP, although some of the requirements under the General Provisions of SEMP could be construed as covering the topic. (Also, there are some suggestions that Employee Participation may be incorporated into SEMS 11.) The success of the Employee Participation element is absolutely ... 

Table 4.3 SEMS Contractor Requirements. BOEMRE Requirement...

Before work starts it will be necessary for management of both the operator and the contractor to compare their safety management plans. They will need to ensure that the contractor s program is aligned with that of the operator and that it meets the requirements of the SEMS rule. 

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