22 December 2011

Welcome!

Welcome to the SafetyRich blog! Please take a few minutes to browse the articles. Come back often as we will use this page to update you on the latest regulatory changes and our business activity. Feel free to leave thoughtful comments.

Email requested article subjects, discussions to: richard@jcgsafety.com

10 November 2011

Safety White Paper.

Download the recent White Paper on Safety Planning and Training we developed in partnership with David Argy at SAFETYTRAINING. Follow SafetyOnlineNetwork on Twitter:
See our Web site: SafetyRich

06 November 2011

SEMS Elements Condensed.


13 SEMS elements

1.  General – Principles & Scope
General: This is the overall definition of the Operator’s SEMS compliance program. This section includes requirements for management responsibilities, buy-in and support.
Format: Written documents.
2.  Safety & Environmental Information
General: Deals with process safety information which requires an employer to compile a complete list of all hazards and the plan to deal with those hazards. Employer must cause a SEMS program to be developed including: Information that provides the basis for implementing all SEMS program elements; process design information; and mechanical design information.
Format: Written Plan & supporting documents. Basis for writing this is Hazard Analysis (#3) Can be included in Safety Manual, Safe Work Practices (#6)
3.  Hazards Analysis
General: Employer must ensure the development and implementation of a hazards analysis (facility level) and a job safety analysis (operations/task level) for all of your facilities. Note: The Hazard Analysis must be completed by Operators before 15 November 2011.
Format: Inspections with findings included in a written plan. Job Safety Analysis (JSA) has an archival requirement of two to three years depending on the circumstance. JSA must be produced on demand.
4.  Management of Change
General: Employer must develop and implement written management of change procedures (MoC) for modifications associated with the following: (1) Equipment, (2) Operating procedures, (3) Personnel changes (including contractors), (4) Materials, and (5) Operating conditions.
Format: Written Document. Note: This is the most complex of all of the written documents. It is commonly believed that failure to manage changes was the root cause for the Macondo incident. See blog post on related failures – based on the final report on the Macondo incident: http://safetyrich.blogspot.com/2011/09/six-lessons-from-disaster.html
5.  Operating Procedures
General: Employer must develop and implement written operating procedures that provide instructions for conducting safe and environmentally sound activities involved in each operation addressed in the SEMS program.
Format: Written document.
6.  Safe Work Practices
General: Employer’s  SEMS program must establish and implement safe work practices designed to minimize the risks associated with operating, maintenance, and modification activities and the handling of materials and substances that could affect safety or the environment. The SEMS program must also document contractor selection criteria. When selecting a contractor, you must obtain and evaluate information regarding the contractor's safety and environmental performance. Operators must ensure that contractors have their own written safe work practices. Contractors may adopt appropriate sections of the operator's SEMS program. Operator and contractor must document their agreement on appropriate contractor safety and environmental policies and practices before the contractor begins work at the operator's facilities.
Format: Written document.
7.  Training
General: Employer’s SEMS program must establish and implement a training program so that all personnel are trained to work safely and are aware of environmental considerations offshore, in accordance with their duties and responsibilities. Training must address the operating procedures, the safe work practices, and the emergency response and control measures. You must document the qualifications of your instructors. Your SEMS program must address: Initial training, Periodic training, Communication of changes, verification of contractor’s personnel training.
Format: Learning Management System (LMS), training matrix, elearning, onsite training.
8.  Mechanical Integrity
General: Employer must develop and implement written procedures that provide instructions to ensure the mechanical integrity and safe operation of equipment through inspection, testing, and quality assurance. The procedures must address: design, procurement, fabrication, installation, calibration, and maintenance of equipment; training; inspections; correction of deficiencies; installation of new equipment; construction; verification of various equipment aspects; maintenance; parts; repairs. Note: This is the most Involved of all of the requirements. The Operators will take care of this and tell Contractors what they need to do to meet these requirements.
Format: Written documents. Extensive use of SMEs. Heavy archival requirements.
9.  Pre-Startup Review
General: This element of the SEMS program deals with the Operator’s commissioning process and includes a pre-startup safety and environmental review for new and significantly modified facilities that are subject to Subpart S to confirm that the specific criteria are met. This requirement has a significant training component.
Format: Primary: Procedures.  Partial: LMS, training matrix
10. Emergency Response & Control
General: The SEMS program requires 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. The SEMS emergency response and control plans must include: An Emergency Action Plan; Emergency Control Center(s) designated for each facility with access to the Emergency Action Plans, oil spill contingency plan, and other safety and environmental information; training and drills.
Format: Written documents with archival and immediate retrieval options. LMS, training matrix.
11. Investigation of Accidents
General: The Operator’s SEMS program must establish procedures for investigation of all incidents with serious safety or environmental consequences and require investigation of incidents that are determined by facility management or BSEE to have possessed the potential for serious safety or environmental consequences.
Format: Written documents describing action. Immediate retrieval is important.
12. Auditing the Program
General: The SEMS program must be audited by either an independent third-party or the Operator’s designated and qualified personnel* according to the requirements of this subpart and API RP 75, Section 12 within 2 years of the initial implementation of the SEMS program and at least once every 3 years thereafter. (*As defined by BSEE)
Format: Action with findings as written documents. Heavy archival requirements.
13. Records & Documentation
General: As required by 30CFR250.1928 (in Subpart S). Requires significant archiving of up to six years.
Shameless marketing note: SafetyRich specializes in written documents, training and Job Hazard Analyses as required in Elements (green). SafetyRich, our team of professionals and business partners provide expertise and Project Management to meet Elements (dark red).   

Not sure if you are compliant? Take the short survey here.

Questions? Email me richard@jcgsafety.com

23 October 2011

Scaffold problems

We have posted several pictures showing numerous violations of safety regulations. A few weeks ago, we posted an article here about scaffold safety: http://safetyrich.blogspot.com/2011/09/scaffold-safety.html. On Sunday 23 October, on my way to the office, I spotted this scaffold erected on the South side of a new high-rise condominium building at 2727 Kirby Drive in Houston.

Let’s see how many violations to scaffold safety regs (OSHA regulations in 29CFR1926.451) we can spot.
1. I doubt if you can see this on the small picture, but regulations require that a supported scaffold be first tied to the building at a 4:1 ratio of the base width, then every 26 feet thereafter. This structure is first tied on the 7th level – close to twice the required height.
2. Regulations call for 100% planking at the work levels with gaps between the planks no larger than 1”. Assuming only the top level is intended to be a “work level,” it is obvious in a picture taken from nearly 100’ away, that the planking does not meet the 1” nor does it likely meet the 100% planking requirement.
3. The front (building side) of the work platform is required to be a maximum of 14” from the face of work. From my vantage point, I estimated the distance between the work and the building far exceeded this limit.
4. All open sides are required to be enclosed or a fall arrest system is required. Since the ends of the work area are not protected, personal fall arrest systems (PFAS) would be required.
Assuming OSHA issues citations (if they catch these contractors at all) at the lowest level, the four citations would carry fines of $7,000 each for a total of $28,000. If the construction company has been cited before (I counted dozens of violations during the construction period), the fines could be enhanced upward one or more levels of severity. In any case, the solution (to build a safe scaffold!) would cost far less than $28K.
Now, let us imagine the scaffolding falling over and hitting the bank next door killing a construction worker and a bank employee while damaging several cars in the parking lot of the bank ....
I understand the construction company’s goal of maximizing profits, but this is completely indefensible.

See our Web site: SafetyRich

04 October 2011

Safety Plans / Safety Manuals

In May 2011 we wrote about Planning: http://safetyrich.blogspot.com/2011/05/planning.html. We discussed three types of plans: Emergency Plans, Contingency Plans and Safety Plans or Safety Manuals.

Federal law requires a written Emergency Plan or Emergency Action Plan that describes the various emergencies your company and workers could face, then how you plan to deal with these emergencies to minimize injuries and loss of life.
A Contingency Plan is usually required by your insurance company, but good business practice and common sense dictate that you plan for disasters.
Written Safety Plans are required by OSHA and most other federal agencies worldwide. Some agencies refer to Safety Plans as Safe Work Programs, Work Plans, Safety Manuals and other terms. We shall use the term Safety Plans here.
Although a federal agency requires a written Safety Plan, little guidance on writing the plans. Several methods of writing plans are available. As long as the plans cover a basic set of criteria, all methods are acceptable. We develop Safety Plans according to a specific process to ensure full coverage
Management Commitment. Every plan of every type should begin with a state of Management Commitment, preferably signed by CEO or another top manager. If workers see management commitment to safety, they are more inclined to adapt safe practices.
Safety Policy. The next item should be the corporate Safety Policy, a simple one or two page statement of the corporate policy regarding safety. A commitment by management, while important, is not enforceable. A Safety Policy, on the other hand, is enforceable. Many good safety policies are available. Our covers management, employees and contractors.
Safety Plan. The method we use is to write a series of plans – one plan for each type of hazard. We have small clients that use plans with as few as 25 plans and larger companies with as many as 50 or more individual plans. Each plan describes the hazard and what the company does to abate, mitigate, eliminate or minimize the danger of the hazard to worker’s health and lives. Be sure to read: http://safetyrich.blogspot.com/2011/05/four-levels-of-protection-from-hazards.html to get an understanding of the benefits of addressing hazards early in the process.
Ask questions, then answer them completely:
What is the hazard?
What could the hazard do in terms of injury and damage?
How do we train workers to recognize and avoid hazards, work safely?
How do we plan to mitigate harm to people, property and the environment?
How do we intend to protect workers and the facility from damage?
How do we plan to review and deal with the hazard?
We urge you to hire a professional, an expert on writing Safety Plans. You may save money in the short term by writing it yourself, but a single injury or fatality not only devastates a family, but costs could be extremely high.
“If you think hiring a professional is expensive, wait until you hire an amateur.” – Red Adair
However you address the issue. Be sure to do something in writing. The law requires it and your employees will be safer for you having done it.

See our Web site: SafetyRich  

Watch for release of white paper on Planning. Check SafetyTraining and SafetyRich Web sites for posting in later half of October 2011. Follow @OSHAnetwork and @SafetyRich on Twitter for notifications.

Future white papers on Risk Management and Employee Behaviour before end of 2011.

20 September 2011

Six Lessons From A Disaster.

These six lessons were derived from the finding of the investigation of a major disaster. If we do not learn from them, we will repeat them – to the detriment to life, health, profits and the environment.

Failure to stop work after encountering multiple hazards and warnings. A stop-work policy should be written and enforced. Continuing to work while a problem “is being fixed” is an invitation to disaster.
Failure to fully assess the risks associated with operational decisions and to ensure all risks are as low as possible. Conduct at least a minimal risk assessment and management. Read our four-part series that starts here: http://safetyrich.blogspot.com/2011/06/risk-management-part-1-of-4.html
Failure to consider contingencies and mitigation while making cost- or time-saving decisions. Almost all cost- or time-reducing actions also reduce safety. Protecting the health and well-being of workers should always prevail.
Failure to have full supervision and accountability over all activities in a work area. Abdication of control is abdication of commitment to a safe environment.
Failure to document, evaluate, approve and communicate changes associated with personnel, equipment, process and operations. A complete change management program identifies what new hazards could be created with the change.
Failure of have a common integrated approach to safety with contractors and employees. Contractors, supervisors and employees may each have their own idea of what safe means.  A safety program not fully enforced or followed may be more hazardous that not having any program. Employees can be willing to take risks, but they should live and breathe safety.

See our Web site: SafetyRich

02 September 2011

SEMS Compliance for Contractors.


UPDATE: 11 November 2011. In a speech to IADC, Michael Bromwich announces that BSEE is moving toward enforcing the SEMS regulations on Contractors which are now only enforced for Operators. Watch here for news on this process. Expect enforcement action to begin late 2012. Contractors should act now to prepare.

Download the paper that condenses the 13 Elements of SEMS: http://goo.gl/R3tkY.

Contact SafetyRich for the full range valuable compliance services.

********************************
Original Post:

On 15 November 2011, US government regulations relating to offshore safety go into effect. Specifically, Operators of offshore facilities (Facility definition: 30 CFR 250.1700c) must be in compliance with 30 CFR 250, Subpart S which applies to Safety Environmental Management Systems (SEMS) administered by the Bureau of Energy Management, Regulation and Enforcement (BOEMRE) of the US Department of Interior. SEMS regulations closely resemble The American Petroleum Institute’s API RP75. See: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title30/30cfr250_main_02.tpl.

Note 1: In 30 CFR 250, readers will note references to MMS. MMS was the Minerals Management Service, which was the predecessor to BOEMRE. A good start is to read the FAQ here: http://www.boemre.gov/ooc/newweb/frequentlyaskedquestions/frequentlyaskedquestions.htm.
Note 2: BOEMRE will, at some time in the future be split into two parts: Bureau of Energy Management (BOEM) and Bureau of Safety & Environmental Enforcement (BSEE). The later will enforce the SEMS regulations. The change was to have taken place in August 2011, but was delayed.
Contractors are not required to comply directly with the regulations. Contractors are, however, required to fully comply with the Operator’s requirements as if they were a part of the Operator. Although a US Government agency will not be enforcing SEMS regulations with the Contractors, the Operators require the compliance.
SEMS consists of 13 elements or areas requiring specific compliance. We provide advisory services in all of the elements, with specific compliance services in 11, particularly:
Safe Work Programs (30 CFR 250.1909 & .1914)
Safety & Environmental Management Programs (SEMPS) (30 CFR 250.1910)
Training Compliance and Tracking (30 CFR 250.1915) ***
Management of Change – Process & Documentation (30 CFR 250.1912)
Hazard Analysis – Development & Authorization (30 CFR 250.1911)
Risk Assessment & Management (30 CFR 250.1909 & .1913)
Investigation of Incidents – Process, Documents, Tracking, Reporting (30 CFR 250.1919)
Compliance Management & Tracking ***
Safety Manuals

*** In partnership with International Human Resources Development Corporation (IHRDC – www.ihrdc.com)

After 15 November 2011 various auditing, reporting and compliance timetables begin.

See our Web site: SafetyRich