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.
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,
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 appropriate 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 managers to verify that the health and safety policies and procedures produce 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 organization 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 concurrent SMSs in a congested work space must be clearly addressed in lease documents, bid submissions, contracts, individual employer SMSs, and perhaps 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.
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 properly 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 understanding, 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 requirement 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.
This section introduces important elements that are included in published 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 Environmental Management Program for Offshore Operations and Facilities, 3rd ed., May 2004;
2. International Maritime Organization (IMO), ISM Code and Guidelines, 2010 ed.;
3. International Labour Organization, OSH 2001, Guidelines on Occupational Safety and Health Management Systems, 2001;
4. American National Standards Institute (ANSI) Z10-2012, Occupational 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.
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 continual 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 authority 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, 220.127.116.11; 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.
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 during 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
(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
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
(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, personnel, 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)
Define potential emergency situations relevant to various operations, 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 maintained 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.
a. Communication (OHSAS 18001 18.104.22.168; 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 coordinating the SMS between the organization and contractors.
d. Incident investigation and reporting (OHSAS 18001 22.214.171.124; 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.
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 indicators (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 126.96.36.199; 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, management 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 important 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
TABLE 5-1 Common Elements Across SMSs, Identified by Document Section Number
|SMS Element||30 CFR 585||Current TRB Study (BSEE TA&R 686)||API RP 75||IMO–ISM||ILO–OSH 2011||MMS TA&R 633||Cape Wind SMS Description||ANSI/ AIHA/ ASSE Z10-2012||OHSAS 18001||OSHA PSM 29 CFR 1910||OSHA Safety and Health Guidelines||BSEE TA&R 709 (PMSS Sample SMS)|
|Emergency response and prevention||810(c)||2e||10||8||3.10.3||6.5.3||5.6||5.1.6||4.4.7||119n||c(2)(iii)||8|
|Qualifications, training, competency||810(f)||1c||7||6||3.4||6.4||10.17; 10.18||5.2||4.4.2||119g||b(4)||4|
|Organization chart, responsibilities, authority||1b||3||3.3||6.3||4.2||3.1.3||4.4.1||c(1)(v), (vi)||3|
|Management commitment, worker participation||1d||3.2||3.2||188.8.131.52||119c||b(1); c(1)(iv)||14|
|Hazards analysis||2a||3||3.10.1||11||5.1.1||4.3.1||119e||b(2); c(2)||5; 9|
|Design, mitigation, hierarchy of controls||2b||2||13||5.1.2||4.3.1||119d||b(3); c(3)||5|
|Safe work practices||2c||6||119k||8|
|Permit to work||2c||6.5.4||9|
|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 integrity, maintenance||2f||8||10||119j|
|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||184.108.40.206||119m||c(2)(iv)||14.3|
|Records and documentation||3g||13||11||3.5||220.127.116.11||4.6||5.4||4.4.4; 4.4.5|
|Performance monitoring, measurement, KPIs||3h||3.11||6.6||4.4||6.1||4.5.1||13|
|SMS Element||30 CFR 585||Current TRB Study (BSEE TA&R 686)||API RP 75||IMO–ISM||ILO–OSH 2011||MMS TA&R 633||Cape Wind SMS Description||ANSI/ AIHA/ ASSE Z10-2012||OHSAS 18001||OSHA PSM 29 CFR 1910||OSHA Safety and Health Guidelines||BSEE TA&R 709 (PMSS Sample SMS)|
|Corrective and preventive actions||3i||3.15||6.4||18.104.22.168|
|Continual improvement (includes program evaluation, management review)||3j||3.14; 3.16||5.1.2; 6.7||4.8.3||6.5; 7||4.6||c(1)(viii)||14|
|Objectives and programs||4.3.3||c(1)(ii)|
|Evaluation of compliance||4.5.2|
|Planning, risk management||4.5|
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.
SOURCE: Generated by the committee.
details of procedures, job direction, or supporting documentation. Such details will vary according to the organization’s policies and its project-specific tasks.
During the drafting of this report, BSEE commissioned another study that is developing an example SMS with appropriate detail and an auditing framework (see TA&R Report 709).1 While the committee has only reviewed a draft version of the new study, it supports the objectives and believes that the study will provide additional guidance to lessees as they document their SMSs. In addition, a recently completed study (see Thomas 2012) on the effectiveness of SMSs was made available to the committee during the drafting of its final report. The committee was unable to review the report thoroughly but believes that it could be of great use to BOEM and BSEE as they enhance their SMS regulations.
The next section briefly discusses the relevant elements of the safety and environmental management system (SEMS) regulations for offshore oil and gas operations.
As discussed in Chapter 3, Subpart S of 30 CFR 250 requires the lessee to develop, implement, and maintain a SEMS for offshore oil and gas operations on the basis of API’s RP 75. 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) that tended to focus on preventing hardware-related mechanical failures. Previous reports indicated that most accidents occurring on the OCS were due to human factors or to not following proper procedures (Bea and Moore 1992; NRC 1990; TRB 2012). The rules in SEMS (for
additional proposed rules in SEMS II, see Federal Register 2011a, 56683) require that operators demonstrate that the documented procedures and processes in the management system plan achieve the goals and that the personnel are competent to accomplish the safety goals. Most of the SEMS elements (listed below) are similar to the SMS concepts mentioned in the previous section (see Table 5-1).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. General (30 CFR 250.1909)
Plan, implement, and manage all program elements discussed in API RP 75 (incorporated by reference) and to document the continued development, improvement, and success of SEMS plan.
2. Safety and environmental information (30 CFR 250.1910)
Establish written safety policies and processes and to document all hazards.
3. Hazards analysis (30 CFR 250.1911)
Conduct hazard analysis for each process.
4. Management of change (30 CFR 250.1912)
Set up a system that documents and manages any changes to the written policies and procedures.
5. Operating procedures (30 CFR 250.1913) and safe work practices (30 CFR 250.1914)
Develop written procedures and clear instructions to safely conduct all activities and hazardous operations.
6. Training (30 CFR 250.1915)
Ensure that employees and contractors are competent and properly trained to conduct activities and operations.
7. Mechanical integrity (30 CFR 250.1916)
Develop procedures for the integrity of process equipment.
2 A SEMS and an SMS are not totally different systems, but they are not interchangeable. From a safety standpoint, the two systems have a similar focus, and the processes involved and elements within each are similar. Both the SMS and the SEMS focus on continual improvement and apply processes already in use for International Organization for Standardization quality and environmental management programs.
8. Pre-start-up review (30 CFR 250.1917)
Confirm during the commissioning stage that the construction and equipment are in accordance with appropriate design specifications.
9. Emergency response and control (30 CFR 250.1918)
Develop and implement an emergency response plan.
10. Investigation of incidents (30 CFR 250.1919)
Investigate each incident, including near misses.
11. Auditing (30 CFR 250.1920)
Perform audits and evaluate program compliance.
12. Record keeping (30 CFR 250.1928)
Document and report results of audits and evaluations.
13. Stop work authority (proposed in SEMS II) (30 CFR 250.1930)
Stipulate that all personnel have the ability to stop unsafe or hazardous work.
14. Ultimate work authority (proposed in SEMS II) (30 CFR 250.1931)
Identify the person with ultimate authority for a facility.
15. Employee participation (proposed in SEMS II) (30 CFR 250.1932)
Involve employees at all levels when preparing the management plan.
16. Guidelines for reporting unsafe work conditions (proposed in SEMS II) (30 CFR 250.1933)
Establish procedures for reporting unsafe work conditions.
As noted above and in a recent Marine Board report, the operator is responsible for ensuring that its SEMS program is functioning properly and evolving as operating conditions and situations change (TRB 2012). 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). A well-documented safety management plan is a necessary but not a sufficient condition for achievement of safe operations. An SMS is the foundation for building and supporting an organizational culture of safety and health, not a substitute for organizational commitment to continued safety performance. All employees, from top management through lower-level workers, must choose the correct and safe option
in every situation. For employees to do this, a positive culture of safety must exist (TRB 2012, 15–16). 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.
Promoting a Positive Safety Culture
Full implementation of the types of SMS described in the previous sections depends on the quality of an organization’s safety culture. An organization’s safety culture is viewed as its “shared values (what is important) and beliefs (how things work) that interact with an organization’s structures and control systems to produce behavioural norms (the way we do things around here)” (Uttal as quoted by Reason 1998, 294). Safety culture reflects an organization’s commitment to safe operations—how safety is regarded and valued within an organization. Safety culture can be thought of not only as what an “organization ‘is’”—its “beliefs, attitudes, and values” in its “pursuit of safety”—but also as what an “organization has”—its “structures, practices, and policies” that “enhance safety” (Reason 1998, 294). For Reason (1998, 294), safety culture is the driving force behind a system’s safety achievements.
A culture of safety does not just appear. It develops over time as the organization matures and encourages all those within an organization to question aspects of their jobs and to establish open lines of communication. An effective safety culture is established and maintained through many of the following traits:3
1. Leadership that demonstrates safety values and ethics and actions,
2. Personal accountability,
3. Problem identification and resolution,
4. Work processes,
5. Continuous learning,
6. Environment for raising concerns,
7. Effective safety communication,
3 For more detail on each trait, see TRB 2012, 17–18, and NAE and NRC 2012, 92–93.
8. Respectful work environment, and
9. Questioning attitude.
To ensure a culture of safety, the organization needs a mechanism describing and documenting safe operations (an SMS plan), and it must institute actions that establish safety norms and provide for accountability. Individual workers must be able to demonstrate competency, motivation, and implicit authority to recognize unsafe conditions and report them without retribution. Competency is built by developing knowledge and skills through training and experience, while motivation is achieved through a commitment that the individual will act according to the norms of the organization. To achieve safe operations, individuals at all levels of an organization must have this commitment to safety, and the organization, especially top management, must support this commitment through its culture. This is true of any organization, regardless of the regulatory system (TRB 2012, 19).
The wind industry has made the case for pursuing a safety culture at recent workshops and industry conferences. 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. Risk management has become more complex as sites and locations of projects are pushed farther out to sea into more extreme environments. Accordingly, the wind industry is trying to establish a balanced approach to safety that considers both occupational and system safety. An organizational culture of safety should exist throughout the entire life cycle of the project, and it starts with the commitment of the top leadership to implement policies that focus on reward, recognition, and organizational correction to motivate the entire workforce.5 Similarly, Wolf believes that
4 See D. Porter, GL Noble Denton, and T. Abbasi, Genesis Oil and Gas, presentations at the Offshore Energy Knowledge Exchange Workshop, Washington, D.C., April 11–12, 2012. http://www.wind.energy.gov/pdfs/offshore_energy_knowledge_exchange_workshop_report.pdf.
5 Chris Streatfeild, presentation at American Wind Energy Association Safety Conference, January 9–12, 2012.
leadership is critical.6 Leaders should communicate regularly with their employees, foster teamwork, and provide positive reinforcement of safety activity involvement. The organization should encourage employee participation in safety training and commit to continuous improvement.
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.
Key Performance Indicators
The safety management process aims for a cycle of continual improvement of safety performance. The successful interplay between an organization’s SMS and its safety culture requires the monitoring of KPIs, which are general measures used in assessing performance. They may be associated with many of an organization’s key activities and are not necessarily related to safety. KPIs can include leading indicators and trailing or lagging indicators. Leading indicators are proactive measures that can suggest the possibility of an incident or the presence (or lack) of safety culture. Examples of leading indicators include hazards identified and addressed, the number of safety meetings that involve management, the size of the organization’s safety budget, and the number of safety inspections conducted during a given time period. Trailing or lagging indicators are reactive measures after an event or accident and tend to gauge past trends or performance (e.g., lost work days or injuries per time period) or outcome assessments (ABS 2012). Any attempt to measure safety performance must ensure that results are both valid and reliable. Safety metrics are considered valid indicators if they accurately measure characteristics of safety performance, and reliable safety metrics will consistently predict results for safety performance over time.
In 2011, in an effort to measure safety performance, the American Wind Energy Association (AWEA) launched its first survey of worker
6 Gary Wolf, presentation at American Wind Energy Association Safety Conference, January 9–12, 2012.
safety and health to collect injury, illness, and fatality data specific to the wind energy industry. At the time, the wind energy sector did not have a dedicated North American Industry Classification System7 code to calculate injury and illness data from the Bureau of Labor Statistics. To resolve this issue, AWEA sought to benchmark industry safety data by implementing an anonymous survey based on the current OSHA 300 log. AWEA hopes to provide the data to its members as a way to compare themselves with peers. 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. Some manufacturers have used indicators such as the number of hazard reviews, emergency or safety drills, and corrective actions taken but tailor the measures to include items within the individual’s span of control. For example, indicators for managers might focus on activities including the number of safety meetings conducted or the number of corrective actions taken, while indicators for technicians might emphasize behaviors as an example to others—skill acquisition or near-miss reporting.10
Indicators are useful in identifying trends and areas on which to focus. For example, one company’s recent internal assessment reported that 40 percent of injuries were due to sprains or strains.11 This report initiated an internal ergonomic study that found the need for additional
7 The North American Industry Classification System is the standard used by federal statistical agencies in classifying business establishments for the purpose of collecting, analyzing, and publishing statistical data related to the U.S. business economy.
8 Michele Mihelic, AWEA, December 1, 2011, presentation to the committee.
9 Discussion at AWEA WindPower 2012, Safety Committee Meeting, Atlanta, Georgia, June 3–6, 2012.
10 Todd Karasek, presentation at AWEA WindPower 2012, Atlanta, Georgia, June 3–6, 2012.
11 Manny Sanchez, presentation at AWEA WindPower 2012, Atlanta, Georgia, June 3–6, 2012.
ergonomic training. A separate study conducted by the Electric Power Research Institute focused on ergonomics and worker health safety in the wind industry and collected and analyzed data on specific task requirements. 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. The next section reviews inspections and audits as currently required in 30 CFR 585 and discusses their importance in assessing and evaluating a program or activity.
Inspections and Audits
An inspection is a structured assessment of an activity or an item that includes measures and tests to determine whether it possesses certain characteristics compared with specified requirements or standards. An audit is a systematic evaluation of an activity or program to determine whether it is being managed or maintained according to a set of accepted standards. This section reviews the requirements for inspections and audits given in 30 CFR 585.
The regulations in §585.820, which were introduced in Chapter 3, allow BOEM to conduct scheduled and unscheduled inspections of a lessee’s facilities and vessels to verify that all project activities are being conducted in compliance with the terms of the lease. The lessee must provide access to all facilities and areas listed on the lease and provide all records of design, installation, operations and maintenance, repairs, or investigations on or related to the project area. Furthermore, the lessee must demonstrate compliance with its own SMS (Federal Register 2011b, 64774). To inspect an offshore wind facility, an inspector would need to
12 Richard Marklin et al., presentation at AWEA Safety Conference, January 9–12, 2012.
compare the facility against some minimum requirements. However, at the time of this report BOEM has not “developed a formal policy on our inspection process for offshore wind farms.”13 BOEM is considering the SEMS inspection process that is under development for oil and gas as a model, along with the inspection guidance from two other TA&R reports (see Energo Engineering 2009, 2010).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. However, little detail is provided. For example, Annex 1 of the Process Guide states that BOEM will conduct inspections of facilities and vessels engaged in renewable energy activities to ensure that operators comply with the regulations in 30 CFR 285, including the operator’s SMS. Furthermore, BOEM will conduct oversight inspections of a lessee’s self-inspection plan (described below), and the United States Coast Guard will continue to inspect and certify vessels under its jurisdiction.
In addition to its Process Guide, BOEM and BSEE have published a list of PINCs for renewable energy, developed in August 2009 after the release of the renewable energy regulations contained in 30 CFR 285. A sample of relevant renewable energy PINCs is shown in Box 5-1.
Each PINC is numbered and corresponds to a specific requirement in 30 CFR 585. Inspection procedures for renewable energy projects are listed in the PINC document, and inspectors use a checklist of procedures to verify that each component of the regulation is in place or in compliance. If an incident of noncompliance (INC) is determined, the inspector issues one of three enforcement actions: warning [(W) INC], component shut-in [(C) INC], or facility shut-in [(S) INC].
Relying on PINCs for enforcement can create problems. As previous Marine Board studies have pointed out, using a checklist of PINCs to determine compliance with a set of safety regulations could encourage companies to adopt a passive attitude that equated safety with passing the inspection (NRC 1990; TRB 2012). Instead of identifying and correcting safety issues proactively and assessing performance over time, companies would wait for a regulator to detect the violation and to explain the required corrective action, which would lead “to a culture of
13 John Cushing, BSEE, e-mail communication, September 14, 2012.
14 John Cushing, BSEE, e-mail communication, September 14, 2012.
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
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
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 environmentally sound operations.
T-116 DOES THE LESSEE’S SAFETY MANAGEMENT SYSTEM (SMS) DESCRIBE HOW AND WHEN THE SAFETY MANAGEMENT SYSTEM WILL BE TESTED?
Authority: 30 CFR 285.810(e)
Enforcement Action: W/C/S
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
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 SYSTEM (SMS) DESCRIBE HOW LESSEE WILL ENSURE PERSONNEL WHO OPERATE THEIR FACILITY ARE PROPERLY TRAINED?
Authority: 30 CFR 285.810(f)
Enforcement Action: W/C/S
1. Procedures are developed to ensure that persons assigned to operate and maintain the facility possess the required knowledge 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 facilities require new or modification of existing operating procedures; 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 determine whether an item (e.g., proper documentation) corresponds correctly 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.
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 integrity. 15 The lessee must submit an annual report to BOEM listing all facilities 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 Register 2011b, 64771). However, the CVA neither assesses these reports for worker health and safety nor reviews the SMS submitted to BOEM.
BOEM Audits Although auditing is an important element in SMS standards, 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
15Federal Register 2011b, 64775, assessment of the structure based on the platform assessment initiators listed in API RP 2A-WSD, which is incorporated by reference.
16 John Cushing, BSEE, e-mail communication, September 14, 2012.
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 corrective action. In combination with reports from BOEM inspectors and the lessee’s self-inspection plans and reports, BOEM audits would provide 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 compliance 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 internal audits should be sufficient to provide feedback to the organization’s planning process and should help in its continual improvement of performance. An audit should not merely focus on an organization’s written 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 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). If small organizations need to use third-party auditors, the audit team should include some internal personnel who are not directly involved with the activities being
17 John Cushing, BSEE, e-mail communication, September 14, 2012.
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).
With the exception of a list of PINCs for renewable energy, BOEM’s procedures 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 “ownership” of the company’s safety program. BOEM can ensure that the lessee’s internal audits are conducted appropriately through its own audits. The next section discusses the importance of properly trained personnel.
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 position, 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 programs, 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 (competent 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 Subcommittee is creating a course training manual for a qualified electrical
worker that presents basic guidelines and elements that all companies should include in their training. The subcommittee is developing introductory safety training manuals for the wind industry. AWEA facilitated 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 manufacturers, has the goal of standardizing the content of safety and preparedness 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 inspectors. 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. 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 emerging 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.
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
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 participation, 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 labeling 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), cannot 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 incidents 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 petrochemical 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 facilities 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.
age, account for a significant number of injuries on offshore oil and gas structures. Large events occur infrequently but are usually major accidents with many fatalities and significant damage and loss. Considerable 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 Deepwater 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. 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. 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 criteria 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 develops and delivers international voluntary consensus standards. More information is available at http://www.astm.org/index.shtml.
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 associated 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 Occupational 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 recognized 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.
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. 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
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 differently from how it is applied to the oil and gas industry. 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. 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 reinforcing 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 process, 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.
|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.
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, Equipment, 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.
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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 Environmental 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 Petrochemical Projects, Part I. Petroleum Technology Quarterly, Summer.
Van Uden, M. E. J., and H. J. T. Rensink. 1999. Human Factors Engineering in Petrochemical Projects, Part II. Petroleum Technology Quarterly, Spring.