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More About the JSA in the SEMS Program

What is a “JSA”?

JSA stands for “job safety analysis”, and it is a tool that can be used to identify the risks to employees associated with their job responsibilities.  JSAs are also used to calculate appropriate risk mitigation practices.

Changes Under the Final Rule

With the Final Rule in place, the BSEE now requires operators to conduct and approve JSAs for Outer Continental Shelf (OCS) activities discussed in the company’s SEMS program.  Also added are phrases that relate to environmental hazards and impacts to both the human and marine environment.

The overall goal of SEMS in this section requires all operators/managers to include the impacts and hazards, environmentally, in their SEMS programs.  This addition is critical in order to explain the context under which a JSA might be utilized for recurring activities.  The manager or person in charge must consider multiple factors when making this decision, including changes in procedures, equipment, personnel, and/or environmental conditions associated with that activity.

The operator/manager must also provide training for all employees on how to identify hazards and how to implement JSAs before performing a job at the facility.

What is the Purpose of the Changes?

These proposed changes are designed to lead to safer OCS operations.  The training component focused on JSA development and implementation should improve operator/managers’ and contractors’ ability to perform duties safely, and training will give employees a better grasp of how an SEMS program addresses hazards.

The Final Rule requires that the JSA include all employees involved with the activity being conducted.  Employees performing each job must be made aware of the hazards and sign the JSA.  Immediate supervisors must conduct and sign the JSA, and also ensure that all employees sign the JSA as well.  The person in charge of the facility must approve and sign all JSAs.

With dual levels of approval in the JSA process, there is an added level of safety.  Additionally, providing signatures indicates that the individuals signing are aware of the hazards and will follow the recommended mitigations while supervising or performing the activities.  The requirement helps to minimize safety and/or environmental problems.

Can Signatures be Electronic?

In response to a recommendation, the BSEE has agreed that an electronic signature on the JSA is acceptable, provided that the operator/manager’s SEMS program states that such signatures are acceptable.

Check out our overview on the BSEE’s Final Rule by reading our first article on the subject.

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