3 nautical miles and on the Great Lakes. BOEM will regulate worker health and safety for offshore wind farms on the OCS, although during committee deliberations, the sponsor reported that BSEE is expected to obtain authority to conduct health and safety compliance inspections for offshore renewable energy facilities by 2014. BOEM has jurisdiction, but its SMS requirements are unclear and incomplete. While the committee is not in a position to recommend a model SMS standard or guideline, it believes that a well-developed SMS, supplemented by details governing the control of specific hazards, is an important mechanism that allows an organization to improve its health and safety performance continually.
The committee has also examined the adequacy of DOI regulations and offers recommendations for enhancing them. The committee agrees that DOI should separate the energy management and health and safety compliance functions between BOEM and BSEE, as it has for offshore oil and gas. To enhance the SMS requirement for offshore wind, BOEM, with the help of stakeholders, should undertake rulemaking and adopt a full SMS rule at a level of detail that includes the baseline elements identified in Chapter 5 of this report or at a level comparable with that of the safety and environmental management system (SEMS) for the oil and gas industry. Moreover, BOEM should investigate the appropriateness of adapting SEMS for offshore wind on the basis of risk and of applying many of the recommendations from a recent 2012 Marine Board study (see Chapter 5). Any enhanced SMS rule should require the use of human factors engineering elements in the design process and should encompass all activities that the lessee and its contractors undertake. In addition, an enhanced SMS and a positive safety culture are closely linked: the SMS must consider all possible safety factors, while the safety culture will shape how an SMS is expressed within an organization.
In collaboration with other regulatory agencies and industry stakeholders, BOEM should lead development and implementation of a comprehensive health and safety program for workers on offshore wind farms. Through new or updated memoranda of understanding with OSHA and USCG, BOEM should clearly define roles and responsibilities and indicate which standards could apply for all phases of wind