Worker Health and Safety on Offshore Wind Farms - Special Report 310 (2013) / Chapter Skim
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5 Enhancing Health and Safety Through Safety Management Systems and Design
5 Enhancing Health and Safety Through Safety Management Systems and Design
Pages 108-138
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From page 108... ...
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.
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From page 109... ...
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 managers to verify that the health and safety policies and procedures produce the intended results and to take any necessary corrective action.
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From page 110... ...
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.
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From page 111... ...
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.
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From page 112... ...
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.
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From page 113... ...
Operating procedures [API RP 75 Section 5; IMO International Safety Management (ISM)
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From page 114... ...
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.
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From page 115... ...
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 important concepts listed above are to be used as one guiding reference.
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From page 116... ...
7 7 Emergency response and 810(c)
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From page 117... ...
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)
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From page 118... ...
(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 Enforcement; 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.
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From page 119... ...
This goal-based SMS became effective on November 15, 2011, and moved the regulations for offshore oil and gas operations from a primarily prescriptive system to a more risk-based system under which operators were required to demonstrate that the health and safety procedures described in the SEMS plan accomplished the stated goals. The shift away from a more prescriptive system was due in part to the inadequacy of an inspection process that encouraged compliance with checklists of potential incidents of noncompliance (PINCs)
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From page 120... ...
.2 As discussed in Chapter 2, the risk profiles of the offshore oil and gas and the offshore wind industries differ widely, so any adaptation of SEMS to the offshore wind industry would need to be risk-specific and require less oversight. Nevertheless, SEMS, like many SMSs, requires the following of operators: 1.
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From page 121... ...
. Nevertheless, how BSEE decides to enforce the SEMS program, or any safety management program, will determine its success: if BSEE only requires the submission of a SEMS program and enforces operators' compliance with a checklist of PINCs, operators will be less likely to take ownership of their safety programs (TRB 2012)
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From page 122... ...
. An 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.
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From page 123... ...
As discussed at a recent workshop, making a culture of safety a vital element of all phases of offshore development should be a top priority across the wind industry, and the use of best practices from the oil and gas industry is one approach for achieving this goal.4 Some wind industry representatives are attempting to manage risk more systematically while promoting a positive safety culture. In the United Kingdom, the risks involved in each offshore wind project become more noticeable as the size and scale of projects increase.
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From page 124... ...
As noted above, well-documented procedures contained in safety management plans are a necessary condition for achieving safe operations, but strong leadership that implements policies promoting a positive safety culture at all organizational levels is critical for the success of those plans. The importance of measuring safety performance, reporting outcomes, and implementing corrective actions is discussed in the next section.
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From page 125... ...
Just over one-third of its members participated in the first injury and illness data collection survey, and AWEA hopes to encourage more of its members to share data.8 If participation rates increase, AWEA plans to expand its survey collection efforts. However, some company representatives noted at a recent conference that individual companies may be less willing to share health and safety data because of concerns with regard to potential litigation or greater regulatory scrutiny.9 The wind industry has generally urged the use of leading indicators as a way of assessing the effectiveness of safety performance and preventing injuries.
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From page 126... ...
The study suggested that changes in engineering controls, such as tools and equipment (lighter manual impact wrenches and better knee pads) , as well as in structural design, such as larger hatch openings and more head clearance in the nacelle, could decrease the likelihood of injuries.12 Developing metrics and collecting data are important tools for management in reporting outcomes, setting strategy, supporting decision making, and implementing corrective actions to improve safety performance.
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From page 127... ...
.14 In the absence of detailed requirements, BOEM has published a Process Guide (see BOEMRE 2011) to clarify the offshore renewable energy process, including inspections.
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From page 130... ...
. However, the CVA neither assesses these reports for worker health and safety nor reviews the SMS submitted to BOEM.
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From page 131... ...
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 operator 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)
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From page 132... ...
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 "ownership" of the company's safety program.
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From page 133... ...
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 personnel and ensure that they are adequately trained.
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From page 134... ...
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.
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From page 135... ...
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. Emphasizing 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, implement, and manage all of the elements listed in RP 75.
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From page 136... ...
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 positive safety culture. BOEM has a general SMS requirement in §585.810 that contains a limited number of necessary elements to guide operators.
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From page 137... ...
Regulations for wind farm workers relying on a SEMS framework would require less oversight 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.
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From page 138... ...
2012. A Systematic Review of the Effectiveness of Safety Management Systems.
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