Safety and Environmental Management Program elements

During each audit, at least 15% of the facilities operated, with a minimum of one facility, should be audited. The facilities included in the audit should not be the same as those included in the previous audit. When sufficient deficiencies are identified in the effectiveness of any safety and environmental management program elements, the test sample size shall be expanded for that program element. 

Audit of safety and environmental management program elements (Section 12). 

Auditof Safety and Environmental Management Program Elements... 

The operators [and contractors with Safety and Environmental Management Programs (SEMPs)] should establish and maintain an audit program and procedures for the periodic audit of the safety and environmental management program in order to determine if the program elements have been properly implemented and maintained and to provide information on the results of the audit to management... 

The elements of these recommended practices should be applied to these facilities, as appropriate. For simple and nearly identical facilities (such as well jackets and single-well caissons), certain elements of the safety and environmental management program, as applicable, need be addressed only once, after verifying that site-specific deviations have been evaluated. 

You must develop, implement, and maintain a safety and environmental management system (SEMS) program. Your SEMS program must address the elements described in 250.1902, American Petroleum Institute s Recommended Practice for Development of a Safety and Environmental Management Program for Offshore Operations and Facilities (API RP 75) (incorporated by reference as specified in 250.198), and other requirements as identified in this subpart. 

Various elements in the safety and environmental management program identify documentation requirements. In addition to those requirements, documentation should be sufficient to describe the core elements of the program and the interaction between the elements. 

In order to manage a process safety and environmental risk program element like pre-startup safety review (PSSR), it is essential to understand the work process. As we have discussed, different facilities have different levels of risk, levels of resources, and organizational cultures to consider. If covered under OSHA PSM or EPA RMP, each facility must be able to demonstrate compliance, but how it is specifically accomplished is open to interpretation. 

RP 75 states, The objective of this recommended practice is to form the basis for a Safety and Environmental Management Program (SEMP). It goes on to say, Management (owner and operator) should require that the program elements are properly documented and available at field and/or office locations, as appropriate for each program element. ... 

The discussion then moves on to the Safety and Environmental Management Program (SEMP—the standard issued by the API in the early 1990s) and the newly published SEMS. These topics are front and center stage for any company operating in US waters. But they possess universal relevance. The principles and application of the elements of SEMS can be applied to any production platform or drilling rig anywhere in the world. 

Will this redesign affect the process safety implementation and effectiveness of the facility process safety program or specifically any of its elements as follows not already covered in the Health, Safety, and Environmental Management System ... 

A SEMS and an SMS are not tolaUy different systems, but they are not interchangeable. From a safety standpoint, the two systems have a similar focus, and the processes involved and elements within each are similar. Both the SMS and the SEMS focus on continual improvement and apply processes already in use for International Organization for Standardization quality and environmental management programs. 

Overall plant-wide maintenance is an element of fire prevention. It is shared with the business need to maintain the production process, as well as with Process Safety Management and other health, safety, and environmental programs. 

The second phase of the program will be more concerned with achieving quantified improvements in the facility s safety and environmental results. This phase is likely to emphasize elements such as Incident Investigation and Process Hazards Analysis in order to identify weak spots in the management systems. 

Critical safety elements are elements that include environmental and anployee factors and which need to be controlled constantly to prevent losses occurring from, for example, injuries, disease, damage, production delays, and environmental harm. These elements form the ongoing safety program or, more aptly termed, safety and health management system. 

DOE O 450.1, sec. 4.1.(l)(b), CRD sec.l(a) and 3 4.2.2 All DOE elements (see definition) must ensure that sites Integrated Safety Management System (ISMS (see definition) includes an Environmental Management System (EMS, see definition) that provides for the systematic planning, integrated execution and evaluation of programs for pollution prevention. 

The other program mentioned in this section of Act is The Healthy School Environments Assessment Tool (HealthySEATv2). It was adapted from a database tool originally developed by the Los Angeles Unified School District to conduct self-assessment inspections in its approximately nine hundred school facilities and substantially modified by EPA to make it widely available to the more than fourteen thousand school districts nationwide. It is free software that can be customized and helps school districts evaluate and manage their school facilities for key environmental, safety, and health issues. EPA has also included critical elements of all of its regulatory and voluntary... 

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