5

Enhancing Health and Safety Through Safety Management Systems and Design

The oil and gas industry has operated on the U.S. outer continental shelf (OCS) for decades, but the U.S. offshore wind industry is only now becoming established. At the time of this writing, offshore wind projects have received preliminary approvals from relevant federal agencies, but construction has not yet started. As mentioned in Chapter 3, the Bureau of Ocean Energy Management (BOEM) issued basic requirements for a safety management system (SMS) in Subpart H of 30 CFR 585 in 2009 but has not fully defined the substance to be included in an SMS. Chapter 4 identified many hazards shared by land-based and offshore wind farms and relevant federal regulations and industry standards that may apply, and it discussed several hazards unique to offshore wind farms.

Chapter 5 examines the U.S. Department of the Interior’s current regulatory frameworks for offshore worker health and safety and presents other SMS models that could guide BOEM in developing its requirements and standards. The chapter discusses factors that shape and support the SMS, including the role of organizational culture in achieving the health and safety goals of an organization, the importance of performance indicators and monitoring for continued safe operations, the necessity of inspection and audits as important tools for both the regulator and operator, and the value of training. Finally, the role of design in providing the best foundation for safe operations and as a key component of a continuous improvement process for future models as part of the SMS is introduced.

SAFETY MANAGEMENT SYSTEMS

In general, a management system is a structured approach that an organization uses to accomplish its goals or objectives. The approach identifies hazards, manages risk through various tools and actions,



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5 Enhancing Health and Safety Through Safety Management Systems and Design The oil and gas industry has operated on the U.S. outer continental shelf (OCS) for decades, but the U.S. offshore wind industry is only now becoming established. At the time of this writing, offshore wind projects have received preliminary approvals from relevant federal agencies, but construction has not yet started. As mentioned in Chapter 3, the Bureau of Ocean Energy Management (BOEM) issued basic requirements for a safety management system (SMS) in Subpart H of 30 CFR 585 in 2009 but has not fully defined the substance to be included in an SMS. Chap- ter 4 identified many hazards shared by land-based and offshore wind farms and relevant federal regulations and industry standards that may apply, and it discussed several hazards unique to offshore wind farms. Chapter 5 examines the U.S. Department of the Interior’s current regu- latory frameworks for offshore worker health and safety and presents other SMS models that could guide BOEM in developing its requirements and standards. The chapter discusses factors that shape and support the SMS, including the role of organizational culture in achieving the health and safety goals of an organization, the importance of performance indicators and monitoring for continued safe operations, the necessity of inspec- tion and audits as important tools for both the regulator and operator, and the value of training. Finally, the role of design in providing the best foundation for safe operations and as a key component of a continuous improvement process for future models as part of the SMS is introduced. Safety ManageMent SySteMS In general, a management system is a structured approach that an organization uses to accomplish its goals or objectives. The approach identifies hazards, manages risk through various tools and actions, 108

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Enhancing Health and Safety Through Safety Management Systems and Design 109 and reflects the organization’s policies and processes in reaching its goals. A management system includes a process by which managers assess the outcomes of implemented programs and policies and take corrective action as needed. This cycle contributes to a continual improvement in organizational performance. The broad intent of a management system for occupational health and safety is to define an organization’s health and safety policies and the responsibilities of key personnel, to identify hazards that can lead to incidents, to determine the risk associated with each hazard, and to take appropri- ate precautions to decrease the likelihood of incidents and mitigate those that occur. An SMS can provide the framework for an effective safety culture, which is necessary in implementing the organization’s safety goals. The SMS must also provide a mechanism allowing man- agers to verify that the health and safety policies and procedures pro- duce the intended results and to take any necessary corrective action. Such a safety improvement cycle (such as the “plan-do-check-act” process) places the responsibility for safe operations on the organi- zation through measures of accountability. One of the challenges in implementing an SMS-based continuous improvement process in offshore wind farms is the relatively brief construction employment peak, which involves multiple employers, followed by intermittent maintenance. Communication and coordination of multiple concur- rent SMSs in a congested work space must be clearly addressed in lease documents, bid submissions, contracts, individual employer SMSs, and perhaps regulations. BOeM’s SMS RegulatiOnS This section characterizes the committee’s understanding of BOEM’s current SMS requirement before introducing important SMS concepts from other sources. As discussed in Chapter 3, the regulations in 30 CFR 585.810 state that the lessee must submit a description of the SMS along with the construction and operations plan (COP), site assessment plan (SAP), or general activities plan (GAP). The lessee must ensure that the SMS is fully functional before beginning any activities described in the COP, SAP, or GAP, but the lessee is not required to submit its SMS to BOEM for the agency’s review.

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110 Worker Health and Safety on Offshore Wind Farms The regulations state that the SMS description must include the following: (a) How you will ensure the safety of personnel or anyone on or near your facilities; (b) Remote monitoring, control, and shut down capabilities; (c) Emergency response procedures; (d) Fire suppression equipment, if needed; (e) How and when you will test your SMS; and (f) How you will ensure personnel who operate your facilities are prop- erly trained. This rule requires lessees to implement a risk-specific performance-based SMS; however, the lack of detail or specific guidance also may mean that an industry’s SMS does not have the rigor or detail that is warranted. The rule does not provide lessees with much detail or guidance and does not necessarily encourage or support technical health and safety understand- ing, and therefore capability, within the company or at the work site. The committee recognizes that the elements set forth in 30 CFR 585.810 do not represent the final detailed SMS requirement, but the current version falls short in several ways. First, it does not include many elements recognized as necessary for an SMS. Furthermore, BOEM does not explain what a “description” of the SMS is, what should be included in the description, and how the description of the SMS differs from a fully functioning SMS. Finally, some of the hazards, in the committee’s opinion, appear more relevant to oil and gas operations than to wind farms. Wind turbines are unmanned structures and pose less risk to worker health and safety than do manned offshore oil and gas platforms. For example, mandated fire suppression—such as carbon dioxide systems—may be appropriate for offshore electrical support platforms but may be an excessive require- ment for individual wind turbines. As reported to the committee, fire is a hazard in both an offshore wind turbine and an offshore substation. But a fire occurring on a wind turbine is an isolated event and usually will not pose a danger to the people and structures around it. At the request of an operator, turbine or third-party vendors will install fire prevention systems that sense and suppress fire in various areas of the turbine, but the decision is usually based on risk assessment.

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Enhancing Health and Safety Through Safety Management Systems and Design 111 Important ElEmEnts for smss This section introduces important elements that are included in pub- lished SMS standards and in other reports. The committee believes that these documents can provide guidance for the SMS requirements described in §585.810 and for additional elements that the committee believes are optimal for any SMS. In assessing the adequacy of BOEM’s current SMS requirements, the committee reviewed relevant reports and published SMS standards and guidelines. The review was not exhaustive but included documents often cited by various industries for developing management systems. The documents reviewed include the following: 1. American Petroleum Institute (API) Recommended Practice (RP) 75, Recommended Practice for Development of a Safety and Environ- mental Management Program for Offshore Operations and Facilities, 3rd ed., May 2004; 2. International Maritime Organization (IMO), ISM Code and Guide- lines, 2010 ed.; 3. International Labour Organization, OSH 2001, Guidelines on Occu- pational Safety and Health Management Systems, 2001; 4. American National Standards Institute (ANSI) Z10-2012, Occupa- tional Safety and Health Management Systems, American Industrial Hygiene Association, 2012; 5. Occupational Health and Safety Assessment Series (OHSAS) 18001: 2007, Occupational Health and Safety Management Systems— Requirements, July 2007; 6. Minerals Management Service Technology Assessment and Research (TA&R) Project 633, Template for a Safety Management System for Offshore Wind Farms on the OCS, October 2009; 7. Cape Wind Project Safety Management System, Rev. B1, October 2010; 8. The Occupational Safety and Health Administration’s (OSHA’s) Process Safety Management (see 29 CFR 1910.119); 9. OSHA’s Safety and Health Program Management Guidelines (see Federal Register, Vol. 54, pp. 3904–3916, January 26, 1989); and 10. Bureau of Safety and Environmental Enforcement (BSEE) TA&R Project 709, Sample Safety Management System, Draft, Version 1.

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112 Worker Health and Safety on Offshore Wind Farms The outline that follows contains common elements from many of these documents and, in the opinion of the committee, offers a base list of concepts needed for any SMS as mandated by 30 CFR 585.810. 1. Safety policy and organization a. Policy for ensuring worker health and safety (OHSAS 18001-4.2; ANSI Z10-3.1.2) Outline key principals and objectives to which the organization is committed, including protection of worker health and safety, compliance with applicable laws, worker participation, and con- tinual improvement. b. Authority and responsibilities for key positions (OHSAS 18001- 4.4.1; ANSI Z10-3.1.3) Develop an organization chart that identifies the key positions necessary for implementation of the SMS and defines their author- ity and responsibilities. c. Personnel qualifications, training, competency (OHSAS 18001- 4.4.2; ANSI Z10-5.2) Identify qualifications necessary for personnel in carrying out the various SMS activities, what training will be provided, and how competency of the personnel will be evaluated and documented. d. Management commitment and employee participation (OHSAS 18001-4.4.1, 4.4.3.2; ANSI Z10-3.1.3, 3.2) Provide sufficient resources to implement the SMS and ensure that employees have the time and resources to participate in all aspects of the SMS, including hazard identification, program evaluation, and corrective actions. 2. Planning a. Hazards analysis (OHSAS 18001-4.3.1; ANSI Z10-5.1.1; API RP 75 Section 3) A systematic process to identify hazards to health and safety dur- ing all phases of the project (from design to decommissioning) and assess the risks associated with those hazards. This analysis occurs initially during design and may be repeated in whole or in part during program updates. (1) Construction hazards including assembly yard and load-out- activities

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Enhancing Health and Safety Through Safety Management Systems and Design 113 (2) Operational hazards including electric service platform activities (3) Decommissioning hazards including subsea cable activities b. Health and safety hazard mitigation, hierarchy of hazard controls (OHSAS 18001-4.3.1; ANSI Z10-5.1.2) Define the process by which hazards identified can be managed through a hierarchy of controls. (1) Design approaches to eliminate or mitigate hazards (2) Human factors engineering (HFE) to eliminate or mitigate hazards (3) Hierarchy of controls i. Elimination ii. Substitution iii. Engineering controls iv. Warnings, administrative controls v. Personal protective equipment c. Operating procedures [API RP 75 Section 5; IMO International Safety Management (ISM) 7] Establish procedures, plans, and instructions for key operations concerning the safety of the personnel and addressing human factors issues. (1) Permit to work (2) Security (3) Simultaneous operations (4) Marine operations (5) Safe work practices, written health and safety programs (6) Job safety analysis, detailed steps of health and safety program (7) Health and fitness for duty (8) Site safety, first aid d. Management of change (OHSAS 18001 4.3.1; ANSI Z10 5.1.3; API RP 75 Section 4; Process Safety 1910.1191) Establish processes to handle changes to the operations, person- nel, and facilities so that hazards are identified and mitigated and the SMS is updated. e. Emergency preparedness, prevention, response (OHSAS 18001 4.4.7; ANSI Z10 5.1.6)

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114 Worker Health and Safety on Offshore Wind Farms Define potential emergency situations relevant to various opera- tions, how to respond to those emergencies to protect health and safety, and how to test and drill the response plans. f. Quality assurance, mechanical integrity, maintenance (API RP 75 Section 8; IMO ISM Section 10) Establish procedures identifying critical equipment and ensuring that it is designed, fabricated, installed, inspected, and main- tained in an appropriate manner to provide for safe operations. g. Commissioning (API RP 75 Section 9) Establish procedures to define a safety review to take place during or before commissioning of new or modified facilities. 3. Implementation a. Communication (OHSAS 18001 4.4.3.1; ANSI Z10 5.3) Ensure that the SMS and its implementation are communicated to all levels of the organization and other interested parties and that feedback is encouraged. b. Procurement (OHSAS 18001 4.4.6; ANSI Z10 5.1.4) Ensure that risks to health and safety from procured items are evaluated, establish requirements to mitigate those risks, and ensure that those requirements are met. c. Contracting and contractors (OHSAS 18001 4.4.6; ANSI Z10 5.1.5) Assess and mitigate the impact of contractors’ activities on worker health and safety and vice versa and establish procedures for coor- dinating the SMS between the organization and contractors. d. Incident investigation and reporting (OHSAS 18001 4.5.3.1; ANSI Z10 6.2) Establish procedures for documenting and assessing incidents in a timely manner to identify deficiencies in the SMS or other factors leading to the incident. e. Audits (OHSAS 18001 4.5.5; ANSI Z10 6.3) Define intervals and processes for implementing internal audits of the SMS to identify whether it is being applied appropriately and is effective. f. Inspections (API RP 75 Section 8.6) Define what systems need to be inspected to protect worker health and safety, what inspections will be carried out and how often, acceptance criteria, and documentation.

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Enhancing Health and Safety Through Safety Management Systems and Design 115 g. Records and documentation (OHSAS 18001 4.4.4/4.4.5; ANSI Z10 5.4) Identify SMS records and documents that should be controlled to document the SMS and its effectiveness and support continual improvement. h. Performance monitoring, measurement, key performance indica- tors (KPIs) (OHSAS 18001 4.5.1; ANSI Z10 6.1) Define how to monitor the effectiveness of the SMS by using KPIs and measures of conformance. i. Corrective and preventive actions (OHSAS 18001 4.5.3.2; ANSI Z10 6.4) Define how to respond to deficiencies identified as part of the SMS, document the process, and track actions taken. j. Continual improvement (including program evaluation, manage- ment review) (OHSAS 18001 4.6; ANSI Z10 6.5/7) Establish a process of periodic evaluations of the SMS to identify and act on areas of improvement. The operator can use broadly grouped concepts in the outline above to supply the necessary details of the SMS. The individual concepts in the outline are more important than the categories themselves (e.g., planning or implementation) or their sequence, both of which can vary slightly depending on the standard or guidelines. Sections of appropriate standards are referenced in parentheses next to the concept, and a brief description is given. Table 5-1 shows the common SMS elements and relevant sections and compares them across management systems. The committee is not in a position to recommend the use of one SMS standard over another; however, the committee believes that an SMS can provide organizations with a mechanism for continually improving their health and safety performance. An SMS can provide a more expansive approach to worker health and safety by identifying hazards and risks and presenting mitigation measures for all aspects of the wind farm development process, such as management policy, personnel safety, structures, and training. The documents and impor- tant concepts listed above are to be used as one guiding reference. Like the standards from which they originate, these concepts refer to the processes that should be followed but do not provide the necessary

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TABLE 5-1 Common Elements Across SMSs, Identified by Document Section Number Current TRB BSEE Study ANSI/ OSHA OSHA TA&R 709 (BSEE ILO– MMS Cape AIHA/ PSM Safety and (PMSS 30 CFR TA&R API RP IMO– OSH TA&R Wind SMS ASSE OHSAS 29 CFR Health Sample SMS Element 585 686) 75 ISM 2011 633 Description Z10-2012 18001 1910 Guidelines SMS) Safety policy 810(a) 1a 1 2 3.1 6.2 4.3 3.1.2 4.2 c(1)(i) 2 Remote monitoring 810(b) 7 7 Emergency response and 810(c) 2e 10 8 3.10.3 6.5.3 5.6 5.1.6 4.4.7 119n c(2)(iii) 8 prevention Fire suppression 810(d) 12 8 SMS testing 810(e) 14 Qualifications, training, 810(f) 1c 7 6 3.4 6.4 10.17; 5.2 4.4.2 119g b(4) 4 competency 10.18 Organization chart, 1b 3 3.3 6.3 4.2 3.1.3 4.4.1 c(1)(v), (vi) 3 responsibilities, authority Management commitment, worker 1d 3.2 3.2 4.4.3.2 119c b(1); 14 participation c(1)(iv) Hazards analysis 2a 3 3.10.1 11 5.1.1 4.3.1 119e b(2); c(2) 5; 9 Construction hazards 2a 11 9 Design, mitigation, hierarchy of 2b 2 13 5.1.2 4.3.1 119d b(3); c(3) 5 controls

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Operating procedures 2c 5 7 6.5 119f 13 Safe work practices 2c 6 119k 8 Permit to work 2c 6.5.4 9 Security 2c 6.5.12 8 8 Simultaneous operations 2c 6.5.13 Marine operations 2c 6.5.14 10 12 Health and fitness 2c 10.18.2 4 Site safety, first aid 2c 13 c(3)(iv) Management of change 2d 4 3.10.2 6.3.2 4.7 5.1.3 4.3.1 119l 6 Quality assurance, mechanical 2f 8 10 119j integrity, maintenance Commissioning 2g 9 119i 9 Communication 3a 3.6 6.5.9 6 5.3 4.4.3.1 10; 14 Procurement 3b 3.10.4 6.5.18 5.1.4 4.4.6 11 Contracting, contractors 3c App. A 3.10.5 6.5.20 9 5.1.5 4.4.6 119h 11 Incident investigation and reporting 830 3d 11 9 3.12 6.6.2 5.2 6.2 4.5.3.1 119m c(2)(iv) 14.3 Audits 3e 12 12 3.13 6.6.4 4.8 6.3 4.5.5 119o 14.4 Inspections 824 3f 8.6 4.8 Records and documentation 3g 13 11 3.5 6.3.1.2 4.6 5.4 4.4.4; 4.4.5 Performance monitoring, 3h 3.11 6.6 4.4 6.1 4.5.1 13 measurement, KPIs (continued on next page)

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TABLE 5-1 Common Elements Across SMSs, Identified by Document Section Number (continued) Current TRB BSEE Study ANSI/ OSHA OSHA TA&R 709 (BSEE ILO– MMS Cape AIHA/ PSM Safety and (PMSS 30 CFR TA&R API RP IMO– OSH TA&R Wind SMS ASSE OHSAS 29 CFR Health Sample SMS Element 585 686) 75 ISM 2011 633 Description Z10-2012 18001 1910 Guidelines SMS) Corrective and preventive actions 3i 3.15 6.4 4.5.3.2 Continual improvement (includes 3j 3.14; 5.1.2; 4.8.3 6.5; 7 4.6 c(1)(viii) 14 program evaluation, 3.16 6.7 management review) Environmental management 6.5.6 14 10 Objectives and programs 4.3.3 c(1)(ii) Evaluation of compliance 4.5.2 Planning, risk management 4.5 Trade secrets 119p Note: AIHA = American Industrial Hygiene Association; ANSI = American National Standards Institute; API = American Petroleum Institute; ASSE = American Society of Safety Engineers; ASTM = American Society for Testing and Materials; BS = British Standard; BSEE = Bureau of Safety and Environmental Enforce- ment; CFR = Code of Federal Regulations; ILO = International Labour Organization; IMCA = International Marine Contractors Association; IMO = International Maritime Organization; ISM = International Safety Management Code; MMS = Minerals Management Service; NFPA = National Fire Protection Association; OHSAS = Occupational Health and Safety Assessment Series; OSH = Occupational Safety and Health; OSHA = Occupational Safety and Health Administration; PMSS = Project Management Support Services; RP = Recommended Practice; TA&R = Technology Assessment and Research; TRB = Transportation Research Board. Source: Generated by the committee.

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128 Worker Health and Safety on Offshore Wind Farms BOx 5-1 Examples of pInCs for renewable Energy T-101 DOES THE LESSEE CONDUCT ALL ACTIVITIES IN A SAFE MANNER? Authority: 30 CFR 285.105 Enforcement Action: W/C/S INSPECTION PROCEDURE: Observe all activities for unsafe and/or unworkmanlike practices, procedures, or operations covering safety. T-112 DOES THE LESSEE’S SAFETY MANAGEMENT SYSTEM (SMS) DESCRIBE HOW THEY WILL ENSURE SAFETY OF PERSONNEL OR ANYONE ON OR NEAR THEIR FACILITIES? Authority: 30 CFR 285.810(a) Enforcement Action: W/C/S INSPECTION PROCEDURE: 1. Verify that lessee’s SMS plan includes procedures, which directly address human factors issues associated with the interaction between facility and personnel. 2. Verify that these procedures address safe and environmen- tally sound operations. T-116 DOES THE LESSEE’S SAFETY MANAGEMENT SYSTEM (SMS) DESCRIBE HOW AND WHEN THE SAFETY MANAGE- MENT SYSTEM WILL BE TESTED? Authority: 30 CFR 285.810(e) Enforcement Action: W/C/S INSPECTION PROCEDURE: 1. Verify that Lessee’s SMS include a test program and procedures that covers: a. The activities and areas to be considered in tests b. The frequency of tests

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Enhancing Health and Safety Through Safety Management Systems and Design 129 c. The test team d. How test will be conducted e. Test reporting 2. Verify through records review that SMS is being tested. T-117 DOES THE LESSEE’S SAFETY MANAGEMENT SYS- TEM (SMS) DESCRIBE HOW LESSEE WILL ENSURE PER- SONNEL WHO OPERATE THEIR FACILITY ARE PROPERLY TRAINED? Authority: 30 CFR 285.810(f) Enforcement Action: W/C/S INSPECTION PROCEDURE: Verify that 1. Procedures are developed to ensure that persons assigned to operate and maintain the facility possess the required knowl- edge and skills to carry out their duties and responsibilities; 2. Lessee’s training plan includes procedures on verifying that employees received training once any alterations in facili- ties require new or modification of existing operating pro- cedures; and 3. Lessee’s training plan includes procedures on verifying that employees received training on operating procedures, safe work practices, and emergency response and control measures. The complete list of renewable energy PINCs is available at http:// www.bsee.gov/Inspection-and-Enforcement/GLT-pdf.aspx. compliance rather than a culture of safety” (NRC 1990; TRB 2012). The studies also note that inspection checklists can be useful mechanisms in combination with other means of enforcement. A checklist will deter- mine whether an item (e.g., proper documentation) corresponds cor- rectly with a specific requirement, but the inspector is also in a position to ask personnel more in-depth questions about safety procedures and their role in the process—information that could help identify problems proactively and guide audits and the assessment of the whole SMS.

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130 Worker Health and Safety on Offshore Wind Farms Self-Inspections Under the regulations in §585.824, each lessee is required to develop and conduct an annual self-inspection plan for all facilities and make the plan available to BOEM on request. The plan must include such details as the type, extent, and frequency of inspections to be conducted for relevant structures and components, as well as an assessment of structural integ- rity.15 The lessee must submit an annual report to BOEM listing all facili- ties inspected over the previous 12 months, the type of inspection, and a summary of actions. The requirements for self-inspections by lessees do not indicate other specific assessments (e.g., worker health and safety), and Annex 1 of the Process Guide restates that the lessee must develop a self-inspection plan, conduct an annual self-inspection, and submit an annual self-inspection report (BOEMRE 2011, 15). Other guidance on self-inspections from the agency refers lessees to TA&R Reports 627 and 650 (see Energo Engineering 2009, 2010).16 Certified Verification Agent Under 30 CFR 585, an approved certified verification agent (CVA) (or a company’s own project engineer if BOEM approves a waiver) must review and certify the facility design report and the fabrication and installation report. The CVA must independently assess and certify to BOEM that the facility is designed according to sound practices and that components are installed according to acceptable practices (Federal Reg- ister 2011b, 64771). However, the CVA neither assesses these reports for worker health and safety nor reviews the SMS submitted to BOEM. Audits BOEM Audits Although auditing is an important element in SMS stan- dards, the regulations set forth in 30 CFR 585 require neither internal audits nor audits by BOEM. According to Annex 1 of the Process Guide, BOEM will conduct “oversight inspections and audits of the company’s self-inspection program” (BOEMRE 2011, 15). BOEM has not developed a formal audit process but envisions the process having at least two elements: the audit of 15 Federal Register 2011b, 64775, assessment of the structure based on the platform assessment initia- tors listed in API RP 2A-WSD, which is incorporated by reference. 16 John Cushing, BSEE, e-mail communication, September 14, 2012.

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Enhancing Health and Safety Through Safety Management Systems and Design 131 the lessee’s self-inspection plan and report and the audit of the lessee’s SMS. Although the criteria for the audits are not developed, the agency indicates that both the TA&R Reports 627 and 650 (see Energo Engineering 2009, 2010) and the SEMS auditing process under development for the oil and gas industry will provide guidance for its audit process.17 Comprehensive audits by BOEM would be vital in verifying that the operator’s SMS audits are being conducted properly and that the lessee’s managers are reviewing SMS audit reports and taking any necessary cor- rective action. In combination with reports from BOEM inspectors and the lessee’s self-inspection plans and reports, BOEM audits would pro- vide another tool for determining whether the operator’s SMS improves health and safety. This view is echoed in the recent SEMS report, which recommended a “holistic combination of methods” for ensuring an effective and continuously improving safety program that includes com- pliance inspections and audits (TRB 2012). Internal Audits Internal or operator audits are critical because they determine whether an organization manages and maintains its SMS in accordance with accepted standards. The frequency of a lessee’s inter- nal audits should be sufficient to provide feedback to the organization’s planning process and should help in its continual improvement of per- formance. An audit should not merely focus on an organization’s writ- ten policies and procedures. It should ensure that the SMS program accurately reflects how personnel incorporate health and safety into everyday tasks and assess whether the organization continually supports safety and health, including identification of hazards and management of risks. As noted in a recent Marine Board study, an internal audit is more effective when it is performed by independent teams of the opera- tor that are not associated with the activities being reviewed because such an arrangement “reinforces ownership” of the process and of the organization’s “safety culture” (TRB 2012). If small organizations need to use third-party auditors, the audit team should include some inter- nal personnel who are not directly involved with the activities being 17 John Cushing, BSEE, e-mail communication, September 14, 2012.

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132 Worker Health and Safety on Offshore Wind Farms reviewed. Information on conducting an internal or operator audit is found in OHSAS 18001-4.5.5 and in ANSI/AIHA Z10-6.3, and Annex I of ANSI/AIHA Z10–2005 provides a sample audit plan (see pp. 46–50). Summary With the exception of a list of PINCs for renewable energy, BOEM’s pro- cedures and requirements for inspecting and auditing an offshore wind farm’s SMS are not yet well developed. As formal policies of inspections and audits are developed, BOEM will need to ensure that its inspection process places the responsibility of safety compliance on the lessee and not on BOEM itself through a checklist of PINCs. Internal or operator audits help a company internalize a safety culture and encourage “own- ership” of the company’s safety program. BOEM can ensure that the les- see’s internal audits are conducted appropriately through its own audits. The next section discusses the importance of properly trained personnel. training Several sections of the 30 CFR 585 regulations require that lessees use “properly trained personnel,” and in accordance with §585.810, lessees must describe how they will ensure that personnel who operate their facilities are properly trained. Information on processes for training, awareness, and competence is given in OHSAS 18001-4.4.2 and in ANSI/AIHA Z10-5.2. Determining the minimum training needs of the workforce is an ongoing process and depends on the roles, responsibilities, and associated risks of each posi- tion, and minimum training requirements can differ among organizations. The committee learned from presentations that many companies in the wind industry already have comprehensive health and safety training pro- grams, but the programs lack consistency among companies. Technicians often face redundant safety training and courses to receive certification to work on turbines from different manufacturers. Consistent guidelines for minimum training requirements and recognition of competency (compe- tent person qualification) could help address the issue of redundancy, and industry could collaborate in developing such guidelines. As mentioned in Chapter 3, the AWEA Training and Education Sub- committee is creating a course training manual for a qualified electrical

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Enhancing Health and Safety Through Safety Management Systems and Design 133 worker that presents basic guidelines and elements that all companies should include in their training. The subcommittee is developing intro- ductory safety training manuals for the wind industry. AWEA facili- tated a 3-day class through which OSHA compliance officers attended a training program at an AWEA member’s facility. In addition, the Global Wind Organisation, an association of wind turbine owners and manu- facturers, has the goal of standardizing the content of safety and pre- paredness training courses for personnel working in the wind industry and has drafted guidelines for a basic safety training course on the basis of input from its members. These initiatives suggest proactive attempts to address industry’s need for safety training that have implications for the training of BOEM personnel as well. As for government inspectors and auditors, at present neither BOEM nor BSEE has established training programs for offshore wind inspec- tors. To carry out its mandate to conduct health and safety inspections of wind farms, BOEM will require well-trained personnel who understand the hazards and risks of the industry they are regulating. As BOEM works toward clarifying its SMS requirements, the agency will need to hire per- sonnel and ensure that they are adequately trained. Until the scope of offshore wind farm development is understood, any training program will require scalability as the offshore wind industry develops and grows. BSEE, which enforces safety and environmental regulations on the OCS, operates the National Offshore Training and Learning Center (NOTLC). NOTLC’s mission is to enhance the capabilities of BSEE inspectors in enforcing safety and environmental regulations through evolving technical curricula and specialized training that adapts to emerg- ing technologies and processes. The next section provides a brief overview of how human factors engineering (HFE) and prevention through design (PtD) could provide an important resource for improving worker health and safety. ROle Of deSign in WORKeR health and Safety Previous research has shown that people have measurable capabilities and limitations that affect their ability to perform their jobs in a safe and efficient manner. If facilities were designed to match such capabilities

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134 Worker Health and Safety on Offshore Wind Farms and limitations, injuries could be reduced or eliminated. HFE improves the interface between workers and the systems and equipment they operate and maintain by incorporating elements of management par- ticipation, workplace design, environmental control, and job aids into the design and operation of a safe and efficient work site. In the offshore oil and gas industry, HFE is associated with the design, layout, and label- ing of equipment and control panels and with the establishment of the working physical environment and design requirements. The HFE discipline identifies what humans can do (capabilities), can- not do (limitations), and will do (motivations and rewards) and attempts to minimize occurrences of “human error” through design and other controls.18 The involvement and support of management in HFE ensure the establishment of effective safety policies and procedures (including those for a safe workplace) and training programs and the creation of an overall corporate safety culture. Without the interest, commitment, and support of management, the prospects for designing and operating a safe and efficient work site diminish. Incorporating HFE elements into the design of offshore structures is important for reasons of safety and cost. One study reports that 80 percent of all offshore oil and gas incidents in U.S. waters were due to human error, and more than half of those errors occurred during operations (Bea and Moore 1992). Another study found that human- induced incidents outnumber machinery and structural failure inci- dents and that by addressing human-induced incidents through HFE, overall worker safety would improve and protection of the environment would increase.19 Van Uden and Rensink (1998, 1999) reported that incorporation of HFE elements into the design of a $400 million petro- chemical facility reduced operational and maintenance costs by 3 to 6 percent over the life cycle of the project and reduced the total number of engineering hours required for the project by 1 percent. For the oil and gas industry, incidents that occur on offshore facil- ities are one of two types: personal events and large events. Personal events, which involve a limited number of people and amount of dam- 18 G. E. Miller, presentation to the committee, May 31, 2012. 19 G. E. Miller, presentation to the committee, May 31, 2012.

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Enhancing Health and Safety Through Safety Management Systems and Design 135 age, account for a significant number of injuries on offshore oil and gas structures. Large events occur infrequently but are usually major acci- dents with many fatalities and significant damage and loss. Consider- able experience indicates that the introduction of HFE elements into the design and operating process could reduce the number of personal events on offshore facilities.20 Because of their nature, large events are more likely to be system safety issues and are less likely to be reduced by the introduction of HFE elements alone. The conditions that cause large, catastrophic events in the oil and gas industry, such as the Deep- water Horizon explosion, are not present on offshore wind farms. Wind turbines are unmanned and are spread over a large area, so a limited number of workers are exposed to hazards at any one time. Emphasiz- ing the reduction of personal events through the introduction of HFE elements could greatly improve worker health and safety for offshore wind farms.21 As mentioned above, Subpart S of 30 CFR 250 is the SEMS based on API RP 75, and the oil and gas industry is encouraged to plan, imple- ment, and manage all of the elements listed in RP 75. Section 2 of RP 75 states that human factors should be considered in designing and installing new facilities or completing major modifications and points to ASTM22 F1166-95, Standard Practice for Human Engineering Design for Marine Systems, Equipment, and Facilities (ASTM 2007) as a good resource for HFE design elements. The ASTM F1166 standard (updated in 2007, with the next revision planned for 2013) is a well-known HFE design standard document in the U.S. offshore oil and gas industry and provides engineers and designers the specific human-based design crite- ria that can eliminate or reduce the likelihood of the identified hazard. Another important resource is the PtD initiative led by the National Institute for Occupational Safety and Health (NIOSH) of the U.S. Centers for Disease Control and Prevention. PtD is based on the premise that the design process is the best place to “design out” hazards and risks. Address- 20 G. E. Miller, presentation to the committee, May 31, 2012. 21 G. E. Miller, presentation to the committee, May 31, 2012. 22 The American Society for Testing and Materials now uses the name ASTM International. It devel- ops and delivers international voluntary consensus standards. More information is available at http://www.astm.org/index.shtml.

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136 Worker Health and Safety on Offshore Wind Farms ing hazards and risks early in the process is a key strategy for reducing workplace injuries and fatalities. According to the NIOSH website, PtD is defined as “addressing occupational safety and health needs in the design process to prevent or minimize the work-related hazards and risks associ- ated with the construction, manufacture, use, maintenance, and disposal of facilities, materials, and equipment.”23 The PtD initiative has also helped in the development of the voluntary consensus document ANSI/ASSE Z590.3-2011, Prevention Through Design Guidelines for Addressing Occupa- tional Hazards and Risks in Design and Redesign Processes (ANSI and ASSE 2011). The ANSI/ASSE Z590.3 standard is a design approach that offers direction on how to identify health and safety hazards and quantify the severity of the risks during the process of design and redesign; however, it does not replace other design standards, such as ASTM F1166. Instead, the ANSI/ASSE document complements the performance objectives of design standards. The ANSI/ASSE standard describes a design approach and recommends a general solution for preventing hazards, while the ASTM F1166 design standard provides specific human-based design criteria that can help reduce or eliminate the likelihood of the hazards. Addressing hazards and risks early in the design process is recog- nized as a key strategy for reducing or eliminating workplace injuries and fatalities. Both the HFE discipline and the PtD initiative provide opportunities to identify hazards and reduce their likelihood during the design phase, and, in the opinion of the committee, are a vital element for any submitted SMS. SuMMaRy diScuSSiOn An SMS can be an effective approach for ensuring worker health and safety if the organization embraces it and if the SMS reflects a posi- tive safety culture. BOEM has a general SMS requirement in §585.810 that contains a limited number of necessary elements to guide opera- tors. Although this committee is not in a position to recommend the use of one SMS standard over another, SMS standards often follow the plan-do-check-act process and provide a starting point for developing 23 http://www.cdc.gov/niosh/topics/ptd/.

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Enhancing Health and Safety Through Safety Management Systems and Design 137 an effective safety regimen. The committee has included a base list of common SMS concepts and believes that any SMS would benefit from following the indicated processes. The SEMS regulations in 30 CFR 250 for the oil and gas industry based on API RP 75 are also an important goal-based model for BOEM’s SMS. Although many of the SEMS elements are similar to those of other SMS standards, SEMS would need to be applied to the wind industry differ- ently from how it is applied to the oil and gas industry. Regulations for wind farm workers relying on a SEMS framework would require less over- sight than for the oil and gas industry and would depend on the amount of associated risk. Regardless, any proposed SMS will need a positive safety culture to reinforce an organization’s safety goals, which BOEM can assess through inspections and audits. Organizations also need valid and reliable indicators to assess their safety performance and monitor their continued improvement. Properly conducted inspections and audits are a necessary part of enforcing an effective SMS but need appropriately documented procedures and training to be successful. Internal audits are critical in rein- forcing ownership of an operator’s SMS process and its culture of safety. Finally, by encouraging the use of HFE and PtD elements in the design pro- cess, industry can help to reduce human factor incidents, which, research has shown, contribute to more accidents and incidents in the maritime and offshore industries worldwide than any other single factor. RefeRenceS Abbreviations ABS American Bureau of Shipping ANSI American National Standards Institute ASSE American Society of Safety Engineers ASTM American Society for Testing and Materials BOEMRE Bureau of Ocean Energy Management, Regulation, and Enforcement NAE National Academy of Engineering NRC National Research Council TRB Transportation Research Board ABS. 2012. Guidance Notes on Safety Culture and Leading Indicators of Safety. Houston, Tex. http://www.eagle.org/eagleExternalPortalWEB/ShowProperty/BEA%20Repository/ Rules&Guides/Current/188_Safety/Guide.

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138 Worker Health and Safety on Offshore Wind Farms ANSI and ASSE. 2011. Prevention Through Design Guidelines for Addressing Occupational Hazards and Risks in Design and Redesign Processes. ANSI/ASSE Z590.3-2011. Des Plaines, Ill. ASTM. 2007. Standard Practice for Human Engineering Design for Marine Systems, Equip- ment, and Facilities. ASTM F1166-07. West Conshohocken, Pa. Bea, R. G., and W. H. Moore. 1992. Operational Reliability and Marine Systems. In New Challenges to Understanding Organizations (K. H. Roberts, ed.), Macmillan, New York. BOEMRE. 2011. Process Guide: Offshore Renewable Energy Installations, and Annexes 1–4, Version 1.0. July 27. Energo Engineering. 2009. Inspection Methodologies for Offshore Wind Turbine Facilities. MMS TA&R No. 627, Jan. Energo Engineering. 2010. Offshore Wind Turbine Inspection Refinements. MMS TA&R No. 650, June. Federal Register. 2011a. Oil and Gas and Sulphur Operations in the Outer Continental Shelf—Revisions to Safety and Environmental Management Systems. Vol. 76, No. 178, Sept. 14, pp. 56683–56694. Federal Register. 2011b. Reorganization of Title 30: Bureaus of Safety and Environmental Enforcement and Ocean Energy Management. Vol. 76, No. 201, Oct. 18, pp. 64432– 64780. NAE and NRC. 2012. Macondo Well–Deepwater Horizon Blowout: Lessons for Improving Offshore Drilling Safety. National Academies, Washington, D.C. NRC. 1990. Alternatives for Inspecting Outer Continental Shelf Operations. National Academy Press, Washington, D.C. Reason, J. 1998. Achieving a Safe Culture: Theory and Practice. Work and Stress, Vol. 12, No. 3, pp. 293–306. http://www.raes-hfg.com/reports/21may09-Potential/21may09- JReason.pdf. Thomas, M. J. W. 2012. A Systematic Review of the Effectiveness of Safety Management Systems. Australian Transport Safety Bureau Final Report. Dec. http://www.atsb.gov. au/publications/2012/xr-2011-002.aspx. TRB. 2012. Special Report 309: Evaluating the Effectiveness of Offshore Safety and Envi- ronmental Management Systems. Transportation Research Board of the National Academies, Washington, D.C. http://www.trb.org/Publications/Blurbs/167249.aspx. Van Uden, M. E. J., and H. J. T. Rensink. 1998. Human Factors Engineering in Petro- chemical Projects, Part I. Petroleum Technology Quarterly, Summer. Van Uden, M. E. J., and H. J. T. Rensink. 1999. Human Factors Engineering in Petro- chemical Projects, Part II. Petroleum Technology Quarterly, Spring.