Hazards analysis, SEMS Section

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

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. 

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

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... 

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. 

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