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Posts Tagged ‘SEMS’

Important BSEE safety alert – barricades and fall protection

hazardous grating

I never liked the label “slips, trips, and falls” because it trivializes serious safety incidents. Falls don’t get headlines, but they kill workers. In the 10 years prior to Macondo, falls were the leading cause of Gulf of Mexico fatalities. 17 workers died from fall incidents during that period. Related incidents associated with falling or moving equipment (15) and lifting operations (5) accounted for another 20 fatalities. There was only one fire related fatality.

Unfortunately, BSEE’s posted incident data are incomplete, so more detailed, company specific analysis is difficult. No incident summaries whatsoever are posted for 2001-2012 and 2021, and 2020 fatalities are only described as “occupational” or “non-occupational.”

BSEE does do a very good job with their safety alert program, and has repeatedly expressed concerns about chronic grating and fall issues. 2022 Safety Alerts 438 and 427, and 8 other BSEE alerts issued within the last 3 years (nos. 353, 365, 378, 389, 399, 409, 416, 423) addressed grating and falls. BSEE has also conducted blitz inspections to identify problem facilities, and the Coast Guard has repeatedly raised concerns about grating and fall protection.

Per BSEE Safety Alert 365, grating, open hole, and fall prevention safety measures were seriously deficient at many of the facilities visited during their blitz inspections in 2019. The prevention of fall incidents requires the full commitment of management. Some companies are clearly not making that commitment.

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Safety and Environmental Management Systems

This rulemaking will incorporate in its entirety and make mandatory the AmericanPetroleum Institute’s Recommended Practice 75, Development of a Safety andEnvironmental Management Program for Offshore Operations and Facilities, with respectto operations and activities under the jurisdiction of BOEMRE. This final rule will applyto all OCS oil and gas and sulphur operations and the facilities under BOEMREjurisdiction including drilling, production, construction, well workover, well completion,well servicing, and DOI pipeline activities.

The rule will become effective on November 15, 2010.

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Today, BOEM released fact sheets describing the Drilling Safety and Safety and Environmental Management (SEMS) rules. The complete documents will be available for review as soon as they are published in the Federal Register.

Based on the fact sheet, the Drilling Safety Rule does not appear to include any significant surprises.  The rule seems to be generally consistent with the recommendations in Secretary Salazar’s 27 May Safety Measures Report to the President (the “30-Day Report”).  This is an Interim Final Rule that will be effective upon publication.

According to the fact sheet, the SEMS Rule will incorporate all elements of API RP 75 into BOEM regulations.  This is an improvement, in my opinion, from the proposed rule which incorporated only 4 elements of RP 75.  The effective date for this rule is not indicated in the fact sheet.

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