BSEE Safety Alert 469: Emergency Hazards Response
Today (2023-10-20) the U.S. Bureau of Safety and Environmental Enforcement (BSEE) issued Safety Alert No. 469 — BSEE Identifies Medical Evacuation and Emergency Hazards During Risk-Based Inspections. (The link is here.)
This Alert makes for serious reading. As time permits, we will work though it in more detail.
Here is what we wrote in our book Offshore Safety Management regarding the Emergency Response and Control paragraph of SEMS (the agency’s Safety and Environmental Management System rule).
10.1 General
The management program should require that emergency response and control plans are in place and are ready for immediate implementation. These plans should be validated by drills carried out to a schedule defined by the management program. The drills should address the readiness of personnel and their interaction with equipment.
10.2 Emergency Action Plan
Written action plans should be established to assign authority to the appropriate qualified person(s) at a facility for initiating effective emergency response and control. These plans should also address emergency reporting and response requirements and comply with all applicable governmental regulations.
10.3 Emergency Control Center
An emergency control center(s) should be designated for each facility and have access to the following:
Emergency action plans that address events such as:
Spills of hazardous substances
Collisions
Fire and/or blowouts
Oil spill contingency plan.
Safety and environmental information.
10.4 Training and Drills
Training incorporating emergency response and evacuation procedures should be conducted periodically for all personnel (including contractor’s personnel), as required by the management program.
Drills based on realistic scenarios should also be conducted periodically to exercise elements contained in the facility or area emergency action plan. An analysis and critique of each drill should be conducted to identify and correct weaknesses, as appropriate.
The following comments apply to the above requirements.
First, a clear line of command should be established for emergency operations. The line of command may differ from the normal management structure.
It is critical that all emergency situations are reported to the appropriate authorities in a timely and proper manner.
It is very important that drills are carried out frequently. Many incidents — most notably Piper Alpha — were made much worse because the people involved did not know what to do.
The Emergency Control Center (ECC) will often be located in the same general area as the Temporary Refuge. The Center should provide emergency response personnel with the capability of operating the control systems that are critical to the safety of the facility.
Personnel working in the ECC should have access to the emergency plans.
The training should consider the requirements of those crew members who are off duty, and who may be asleep in the Living Quarters.
Drills can present safety problems of their own. For example, many offshore organizations do not permit live drills with respect to lifeboats. There have fatal accidents during these drills, so they are not considered to be worth the risk.