SEMS II is here. June 4 brings the implementation date for most of the SEMS II regulations. SEMS II adds some new requirements and changes some others. The parts that go into effect now affect how personnel work under SEMS. The second piece changes the audit process and goes into effect next summer.
The question is – What happens now that the big date has arrived? No one has said anything that would lead you to believe that June 4 is a drop dead date and the earth will stop if every operator and contractor isn’t fully in compliance.
Part of the reason for that is that there are still some fairly big questions about how to interpret the regulation, especially when it comes to the Ultimate Work Authority and Stop Work Authority provisions. The operators put together their thoughts on how those parts should be interpreted and sent it up to Washington for BSEE’s take, but BSEE hasn’t responded yet. (BSEE may not respond. It may take the position that it wrote the regulations and it is up to each operator to apply it to its unique operations.).
So what is the contractor’s role in all this? The regulations require crews to do Stop Work Authority and JSAs in specific ways and says everyone must be trained on those procedures. The regulation has three other provisions that must be set into procedures and crews need to be trained on all of it. When an operator tells you you need to be in compliance, it will expect you to be in compliance. So right now:
- Educate yourself on the changes. Don’t wait for BSEE to come out with some new guidance, because that may not happen. Don’t wait for your customer to spoon feed you the changes. If you are familiar with the changes, your customer’s direction will make more sense.
- Focus on incorporating the Stop Work Authority, JSA and Ultimate Work Authority changes into your procedures and training. Those are the areas that will most effect your activities offshore.
- Call if you need help. This is what Lifeline Strategies does. You can reach me at (985) 789-0577 of KenWells@LifelineStrategies.com.