Are You Ready For The Public To See Your OSHA Incident Reports?

On November 8, OSHA published a proposed rule that would require many, if not most, employers to submit their injury and illness reports electronically.  The agency intends to post that information online.

The proposal has three elements:

  1. Companies with 250 or more employees would be required to submit their data for injuries, illnesses and fatalities every quarter.
  2. Companies with 20 or more employees need to submit the information from their OSHA 300A form every year if they are part of an industry that is identified in the rulemaking as having incidents above a certain threshold.
  3. OSHA may also tell individual companies to submit specific information to OSHA.

Talk about a game changer!    Even though employers are already required to post this information where employees can see it, putting incident information online where the whole world can see it is opens up a lot of new issues.   Suddenly a company’s safety record becomes part of the public debate over siting facilities, the relative safety of the industry and the image of the company itself.  Every company must be prepared to publicly defend its record in an environment where any incident is too many incidents.

Of course, whether the government says it or not, that is part of the objective here.  There is a famous quote from Supreme Court Justice Brandeis: “Publicity is justly commended as a remedy for social and industrial diseases. Sunlight is said to be the best of disinfectants.”   OSHA clearly believes that public disclosure will be an incentive to reduce incidents.

For some companies this could be helpful.   If perspective employees start looking at incident rates when deciding where to work or customers gravitate to suppliers and contractors based on their public records, it could be a positive for companies that invest in their safety records and a stigma for those that don’t.

One interesting note – The proposed regulation lists the small employers (by NAICS code) that are required to file their annual OSHA 300A form electronically.  Oil and gas companies and oil and gas service companies are not included on the list.   However, that does not mean small companies in the energy sector are off the hook.    Many are listed under the NAICS code as being part of other industries, such as construction.  Also, OSHA has given itself the ability to target specific companies or sectors to report electronically.

This is still a proposed rule, so the public has a chance to comment. Comments are due by February 6, 2014.   OSHA held public hearings on an earlier version of the proposal and it doesn’t look like it will hold others.

What do you think of this proposal – positive or negative?

Honoring Veterans – Those We Know And Those We Don’t



The focus of this blog has been safety, but with Veterans Day coming up, I want to use this one to talk about my father-in-law.   Roscoe flew 33 missions as a B-17 navigator in World War II.  On Tuesday he took one more flight, this time as one of 70 veterans who flew to Washington, DC, as part of the Honor Flight program.  Over the last three years, the group that organizes the flights that leave from Mississippi has taken nearly 600 vets to DC where they tour WWII memorial, the tomb of the unknowns and the Iwo Jima memorial, among other sites.  There are other Honor Flight groups that have taken vets from other parts of the country

It is a moving and fitting honor for these men and women.    Roscoe called it one of the best moments of his life.

We should also honor the people who make these flights happen, including the volunteers who organize what amounts to a very old and a little bit creaky army on the move and the donors who have stepped up to fund the flights.   And we should  recognize the hundreds of people who show up in Washington to greet the vets and who line the corridors of the Gulfport-Biloxi airport to welcome them home again.   Most of these people don’t know any of the vets on the trip.  They just come to show respect.

And then there is my wife, who was so determined to make sure that Roscoe was healthy and ready to make the flight, I think she would have flown the plane if she needed to.

OCS Vessel Industry Has One Month To Comment On Vessel SEMS Proposal

The deadline is December 9th for industry and the public to comment on a Coast Guard proposal to create a SEMS rule for vessels that work in the oil and gas industry.   At last check, there were only five comments on the public docket, almost all of them against the proposal (and at least one of them not for polite company).

Coast Guard inspectors on the job

This is an Advanced Notice of Public Rulemaking, meaning the Coast Guard will still need to go through more steps if it really wants to require  SEMS on offshore vessels like MODUs, OSVs, liftboats, crewboats  and construction vessels.   However, many in industry believe there will eventually be some kind of SEMS regulation for vessels.   For boats that already have  International Safety Management (ISM) plans, the simplest solution would be an appendix that adds the parts that are in SEMS but not ISM.   For them the worst case scenario would be if they had to adopt ISM and SEMS as two separate plans.

Domestic service vessels that do not have ISM have much more to worry about.  Without any safety management system, they would have a hard time bridging to SEMS.   We are advising clients and working with them to develop a safety management system internally so they are prepared if the Coast Guard moves forward with a SEMS approach.   

You can (and should) read the Coast Guard proposal here.  The Coast Guard says it may affect 2200 vessels.

In the meantime, there is another Coast Guard proposal out that is a bit of a mystery.   On October 25th, the Coast Guard sent a proposal to the White House for review titled  Training of Personnel and Manning on Mobile Offshore Units and Offshore Supply Vessels Engaged in U.S. Outer Continental Shelf Activities.    However, there was no explanation of what that might cover or when the Coast Guard hopes to have it out.

If your company needs help creating a safety management system, contact us.

Special SEMS Workshop For Contractors Just Around The Corner

Only a few more chances to register for a special SEMS workshop aimed just at Contractors.


Now that the first round of Operator audits are ending and SEMS II is coming up, your customers will be expecting you to comply with new requirements.  Are you ready?

On Thursday, November 7th, Lifeline Strategies and the Association of Diving Contractors International will be holding a workshop that focuses on giving Contractors the tools they need to meet their customer expectations.    The session will offer commonsense explanations of

  1. How the existing rules impact Contractors;
  2. Lessons learned from audits and;
  3. What the SEMS II changes mean to you.

This half-day workshop will be held at Houston’s Hilton Garden Westchase from 9 a.m. to 1 p.m.

Click here for details.

To register, call ADCI at (281) 893-8388.

BSEE’s New Boss Weighs In

The Director of  the Bureau of Safety and Environmental Enforcement (BSEE), Brian Salerno, took over the job in late August, but with the government shutdown, he hasn’t had much of a chance to outline his priorities.   In the last week, he did give a speech at an international regulator’s forum, where he talked about BSEE’s approach under his watch.

His approach seems to be very much in line with his predecessor, Jim Watson.   That should be no surprise.  Both were admirals in the Coast Guard and both cut their teeth in the maritime safety space.   So it should also be no surprise that Director Salerno’s approach to industry looks a lot  like the Coast Guard’s approach.   Just as BSEE was shaped by the aftermath of the Macondo disaster, the modern Coast Guard was shaped by the Exxon Valdez spill.   The Coast Guard’s approach of working with (rather than against) industry to address spill prevention and response has produced exceptional results.   Salarno’s speech reflects that:

We will continue our outreach efforts, and I am personally committed to four key principles in our interactions: clarity, consistency, predictability, and accountability. We will continue to work closely with the industry to reduce risks, while never forgetting that we work for, and are accountable to, the American people.

He talked a lot about safety culture, saying the regulations are just the “basic ground rules” and industry needs to go beyond the regulations:

So what do we mean by “safety culture” and how should we measure “safe?” Is it merely the absence of accidents? Is it compliance with regulations? Is it how you approach complex activities? I believe it is how you approach risk. How do you balance risk to your employees and the environment with the need to stay on schedule, to complete the well, or to start production? It goes far beyond management decisions. How do your people approach risk? Are they afraid to speak up when they see something wrong? Will they immediately halt operations if their colleagues are in danger? Or, do they only pay attention to the missing handrail when they see the helicopter with a BSEE inspector approaching their facility? How much risk – to themselves – are they willing to accept?

One clear message of the speech was that BSEE is searching for reliable leading indicators.  As Salerno put it: “Past incidents or accidents are a consideration, but this also may not be the best indicator of risk mitigation when you are dealing with low probability – high risk events.”

Click here to read the full test of Director Salerno’s speech.

Work/Life Balance: 100 Percent Tie-Off



I saw this sign at the exit to one company’s parking garage today.   Now, I know there was construction going on at the site and that “100% Tie Off Required Beyond This Point” refers to the need for workers  to tie of fall protection to an anchor.   But I couldn’t help but think, talk about a perfect message to send employees at the end of a long day at work:    “No ties past this point! 100% required.”     Its all about life balance and its a rule worth following.

Seats Still Available For SEMS Workshop for Contractors

Big changes are coming to SEMS.  If you are a Contractor, are you ready to meet your customer’s requriements?

Please join us for a special workshop focused on helping Contractors sort through the offshore SEMS requirements and prepare for the SEMS II changes that are on the way.   We are partnering with the Association of Diving Contractors International to present this half-day workshop on Thursday, November 7th at Houston’s Hilton Garden Westchase from 9 a.m. to 1 p.m.

In addition to helping you understand this important safety regulation and how to meet your customer’s SEMS requirements, we will look at how the first round of audits have turned out and what it means to you, as well as what will change as the SEMS II requirements kick in.

You can find more information on the session here.   To register, call ADCI at (281) 893-8388.

SEMS Skills and Knowledge Part 3: What The Offshore Industry is Doing About It

Under SEMS,  offshore Operators must verify that Contractor personnel have the skills, knowledge and experience to do their jobs safely and correctly.  So far the results have been sketchy at best.    The industry doesn’t have standard skills or training requirements.  For many jobs there aren’t even standard job descriptions or paths to competency.   This month we have been looking at the challenge this faces for industry.  Today let’s look at what two industry groups are doing to solve it.

The Center for Offshore Safety (COS) represents large Operators and a few Contractors.  Its focus is on deepwater operations, but what starts in deepwater has a way of migrating onto the shelf.   For nearly a year now, a COS volunteer group has been working on guidelines for verifying offshore skills and knowledge.   I have participated as a member of that group and its recommendations still need to be approved by the COS Board, but there have been presentations at public forums that give you an idea of the direction they are headed.

The COS group supports a concept it calls the Skills and Knowledge Management System (SKMS).  In a nutshell, Contractors would need to:

  1. Figure out the critical tasks a worker performs that address specific safety needs(or, for those who are familiar with a Bow Tie Hazard Analysis, act as a barrier  to a safety or environmental hazard);
  2. Determine what training and skills workers need to perform that task;
  3. Regularly evaluate them to on those tasks; and
  4. Create a records system so Operators can verify the worker skills and knowledge.

To put it simply, what does a guy need to know to do his job safely and how do we make sure he knows it.

Again, this is a 10,000 foot view of a detailed process and the COS Board will determine what the final version looks like, but the take-away is that Contractors really need to look at a competency/evaluation process for their workers. Some Operators already require them, but look for that number to jump.

The second initiative comes from the International Association of Drilling Contractors (IADC).   While limited to the drilling side of offshore operations, IADC is tackling both what a good system is and what tasks should be evaluated.   On the system side, IADC has an accreditation process where it reviews a company competency program and gives it a seal of approval if it meets IADC’s criteria.   On the task side, the association has been involved for some time in what it calls the Knowledge, Skills & Abilities (KSA) Project.   This is a massive undertaking to determine critical tasks for a number of drilling positions.  The project started in 2000 and had developed competency guidelines for 12 positions.  Now the program has been stepped up to expand the number of jobs covered and to put more meat into the specific competencies.   While still a work in progress, this process will give the drilling sector new tools to standardize positions and evaluate workers from a common view.

So, two groups with two very valuable approaches to the skills and knowledge challenge.   In the meantime, Contractors still have a lot of work to do in developing systems that work for their companies and the jobs they do.  In a future post, we will look at one program that may help.

Special SEMS Workshop For Contractors – November 7th in Houston



Are you a Contractor trying to get your arms around SEMS?   Lifeline Strategies is partnering with
the Association of Diving Contractors International to hold a special half-day workshop on November 7th in Houston.

Click here to access the details:  SEMS for Contractors Workshop Announcement – 7 November 2013.

Call the ADCI offices at (281) 893-8388 for registration and information.

This workshop will cover:

  1. Commonsense explanations of the SEMS rules
  2. Lessons learned from the first round of SEMS audits –  As the first round of audits winds up, we will cover  some  of the early trouble spots that are sure to be on the minds of oil and gas customers.
  3. What to expect from SEMS II:  The new revisions to SEMS kick in in June of 2014.   The workshop will  help contractors stay ahead of the changes.
  4. Bridging to SEMS: Contractors may not adopt a formal SEMS plan, but they do need to have a safety management approach that allows them to prove to customers how their safety program matches their customer’s requirements.

Evolving Safety Culture: Leading Indicators to Look For


Interesting article on growth of safety culture in the Marcellus Shale area in the east.    It was based on a presentation given by Laura Helmrich-Rhodes, an associate professor of safety sciences at Indiana University of Pennsylvania.   Dr. Rhodes looks at seven signs of an emerging safety culture within a company.   She says these indicators are taking hold in the Marcellus.   How does your company match up?


  • Is there true top management commitment to safety?
  • Are employees really empowered to stop work if they see an unsafe situation? Are employees involved?
  • Is there an effort to choose contractors that emphasize safety — even vendors for noncore activities like janitorial or catering services?
  • Is there an instant investigation into any near-miss scenarios so that change can be made.
  • Are near-miss and incidents reported not just to management but to all employees so lessons can be learned?
  • Are risk takers terminated and not celebrated?
  • Is safety given its share of the budget?

Two things that make this notable –  First, drilling in the Marcellus only started about five years ago.  There have been growing pains and a steep learning curve for companies and workers.   The second thing is that Dr. Rhodes believes the safety culture that is taking hold in the Marcellus drilling fields could hold important lessons for other industries, like construction.