| SEMS: Operators and Contractors |
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Operator ResponsibilitiesThe SEMS rule states, It is the intent of this rule to hold the operator accountable for the overall safety of the offshore facility, including ensuring that all contractors and subcontractors have safety policies and procedures in place that support the implementation of the operator's SEMS program and align with the principles of managing safety set forth in API RP 75. The above statement is unequivocal: the responsibility for ensuring the SEMS is applied lies with the company that is operating the rig or platform. It is further supported by the following quotation from the rule, . . . the operator needs to include the following in its SEMS program: (3) Procedures to verify that contractors are conducting their activities in accordance with the operator's SEMS program and an evaluation to ensure that contractors have the skills and knowledge to perform their assigned duties; Bridging DocumentsIt is clear that it is incumbent on the operators to develop interfaces with the contractors who work for them. However, if there are say 150 operators on the Outer Continental Shelf (OCS), hundreds of large contractors, and thousands of smaller contractors and vendors, it is clear that the development and control of the interfaces between all these companies is going to be a mammoth task.Existing Safety Management System ProgramsTo further complicate matters, many companies, particularly the larger ones, have their own Safety Management Systems (SMS). Although these systems have the same goals and SEMP and SEMS, they may have a substantially different structure. Hence a map from company-specific programs (both operators and contractors) will be required. Bridging through SEMSIf each operator has to create a bridging document to each of its contractors, and if each contractor then has to do the same with it sub-contractors, the number of interfaces will be so high as to be unmanageable. One way of resolving this difficulty would be for each company to map its own systems to a SEMS template, as shown in Figure 1. Figure 1
The findings of the investigation should be retained for possible use in the next hazard analysis update, company audits, or for a minimum of 2 years, whichever is greater. Each company will then map its own Safety Management System (SMS) to the appropriate SEMS element. (If they find that their standard is less rigorous than SEMS, then they will have to update their own SMS.)This approach means that, instead of having to create an interface for each element in a SMS between each operator, contractor and sub-contractor, it will be sufficient simply for all parties to map to the SEMS standard, and then link to other companies from SEMS. Smaller ContractorsSmall contractors do not have the resources or need to create a full SMS. However, they will have to create links as required to the SMS programs of their clients (operators and larger contractors). One way of doing this is to Table 1
Table 1 has three columns. The first column lists the elements of SEMS (excluding 'General'). The second column shows whether or not this painting contractor believes that his company has to have a safety program to do with that element. If he does, then that safety program will have to be bridged to the operator’s SEMS. The letters shown have the following meaning:
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