Training SEMS requirements

The Safety and Environmental Management System (SEMS) requirements to do with offshore training are described and discussed in Table 7.1 (some formatting changes have been made). Additional information to do with offshore training is provided by the American Petroleum Institute (API) (2001). 

The SEMS requirements to do with training are described and discussed below. 

With regard to SEMS, Subpart O requirements are still in effect, but they are considered as being one component of the overall SEMS-required training. However BOEMRE has stated that Subpart O will not disappear even though its functions are now mostly subsumed by SEMS (Levine 2011). 

With regard to SEMS, subpart O requirements are still in effect, but they are considered as being one component of the overall SEMS-required training. 

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. 

The interior of bulk samples can be revealed by fracture, freeze fracture, or (cryo-/ultra)microtoming. These techniques are well established in electron microscopy and require substantial training to ensure that the knives used do not introduce scratches and other artefacts. Unlike in SEM or TEM analysis, however, it is very well possible to analyze the trimmed specimen instead of the very thin sections removed (cryofacing). This loosens the constraint of ultrathin sections in many applications. Care has to be taken that the sample to be imaged is not significantly thicker or thinner than the calibration grating used for scanner calibration (see Sect. 2.2.5)... 

Other features require that the operator enable employee participation in mitigating or eliminating hazards, a feature missing from API s RP 75, and ensure that all employees have the right to report safety or environmental violations or unsafe work conditions to BSEE and request BSEE inspection. SEMS II also requires that operators specify one person on each facility who has Ultimate Work Authority for operational safety. Finally it requires enhanced training programs and audits of SEMS programs conducted by independent third parties who meet specified qualification criteria. 

Your SEMS program must require that emergency response and control plans are in place and are ready for immediate implementation. These plans must be validated by drills carried out in accordance with a schedule defined by the SEMS training program ( 250.1915). 

The ASP must meet or exceed the qualifications, competency, and training criteria contained in Section 3 and Sections 6 through 10 of Qualification and Competence Requirements for Audit Teams and Auditors Performing Third-party SEMS Audits of Deepwater Operations, COS-2-01, (incorporated by reference as specified in 250.198) or its equivaient ... 

The second column shows the man-days that is estimated will be required for completing each element. In the case of training, the estimate is for 580 man-days, i.e., the amount of time budgeted for bringing all workers into compliance with the requirements of the training element of SEMS. 

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. 

Compared to SEM, where reflecting electrons are utilized to examine a bulk material surface, TEM does not discern any topographic information because it examines thin films with transmitted electrons. The thin-film sample preparation is more complicated, and the TEM operation requires more training as well. The interpretation of a TEM image requires a good understanding of electron microscopy and the structure of the material. 

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