Hazards analysis, SEMS

The hazards analysis section of SEMS contains additional information as to what constitutes a covered facility. It states ... 

Information that provides the basis for implementing all SEMS program elements, including the requirements of hazard analysis ( 250.1911) ... 

Paragraph (b)(1) provides a basis for deciding which activities to carry out first. Given that many companies will not be able to meet all of the SEMS requirements within the time that they are allowed, they should develop a prioritization system through a high-level hazards analysis. 

SEMS requires that a hazards analysis be carried out. The purpose of the analysis is to identify and evaluate the risk associated with or environmental incidents. If the risk level is judged to be too high, then either the likelihood or the consequences of the hazard should be reduced to a point where the overall risk is acceptable. 

You must ensure that a hazards analysis (facility level) and a JSA (operations/task level) are developed and implemented for all of your facilities and activities identified or discussed in your SEMS. You must document and maintain a current analysis for each operation covered by this section for the life of the operation at the facility. You must update the analysis when an internal audit is conducted to ensure that it is consistent with your facility s current operations. 

You can apply this single hazards analysis to simple and nearly identical facilities after you verify that any site-specific deviations are addressed in each of your SEMS program elements. 

If a facility does not have a SEMP or SEMS program, one of the first steps in the development of such a program is to conduct a Major Hazards Analysis (MHA). The purpose of this analysis is to identify those areas of the facility that pose the greatest risk. This type of analysis, which will be qualitative in nature, will show, for example, that the risers present a greater risk than the platform s gas compressors. Therefore, the initial focus of the risk management program should be on the risers. An MHA can also be carried out in the early stages of a project. 

As discussed above, the Hazards Analysis section of the SEMS mle covers both process safety analysis and job safety analysis (JSA). 

The same principle can be applied to other areas of the SEMS program, particularly hazards analysis. Once one unit has been analyzed, the others can be reviewed by difference . It is important, however, to make sure that there reaiiy are not differences, particuiariy on oider faciiities where they may have been a good deai of midnight engineering. ... 

The SEMS requirements to do with hazards analysis are summarized and discussed below. 

This section outlines issues to consider when conducting a hazards analysis. In order to ensure formal compliance with the SEMS rule, the team leader or scribe should explicitly call out each one of these factors during the team... 

Flazards analysis requirements for simple and nearly identical facilities, such as well jackets and single-well caissons, may be fulfilled by performing a single hazards analysis which you can apply to all such facilities after you verify that any site-specific deviations are addressed in each of the elements of your SEMS program. ... 

The hazards analysis section in API RP 75 addresses the job task at the facility level. Therefore, BOEMRE is requiring JSAs as part of the SEMS program. 

The SEMS requirements for prestart-up safety reviews are described and discussed below. Guidance to do with prestart-up reviews is provided in API RP 75, Recommended Practice for Design and Hazards Analysis for Offshore Production Facilities. 

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