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6 Findings and Recommendations
Pages 139-151

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From page 139...
... Chapter 3 discussed the jurisdictional issues involved in regulating worker health and safety for offshore and land-based wind farms. Given the history of regulating health and safety in the United States, overlapping -- and possible gaps in -- jurisdiction among multiple federal agencies has created confusion as to which regulations apply and 139
From page 140...
... develops and enforces safety and environmental regulations for oil and gas operations, but not for wind energy. During the drafting of this report, however, the sponsor reported to the committee that BSEE expects to conduct safety compliance inspections of offshore renewable energy facilities
From page 141...
... SMS standards that follow the typical "plan-do-check-act" process can be used as an effective model and provide the foundation for an effective safety culture, which is key to sustainable safety. This process is necessary but not sufficient for achieving safe operations, however -- a successful SMS also requires strong leadership that implements policies and promotes a positive safety culture at all levels of the organization.
From page 142...
... Some of the safety and environmental management sys tem (SEMS) requirements for the offshore oil and gas industry would be appropriate for offshore wind farm worker health and safety and could be adapted to regulations for offshore wind installations.
From page 143...
... Engaging wind energy stakeholders early in the rulemaking process can improve the chances of implementing a comprehensive and effective SMS rule. The development of Subchapter M of 46 CFR, discussed in Chapter 3, provides an example of a process under which the engagement between a regulator and stakeholders produced an SMS requirement that advanced worker health and safety while allowing industry flexibility in demonstrating compliance with regulations.
From page 144...
... , an effective SMS should cover all activities and operations for all project phases and for all facilities, even if those activities occur outside of BOEM's jurisdiction. A lessee's policies and procedures documenting worker health and safety for offshore wind farms do not begin 3 nautical miles offshore, and neither should the lessee's SMS.
From page 145...
... However, some regulations, such as those for diving, are out of date and in the committee's opinion require revision. The committee notes that OSHA has neither vessels nor resources for enforcing worker safety requirements for wind farms within state waters, on the Great Lakes, or on the OCS.
From page 146...
... Emphasizing the reduction of personal events through the introduction of HFE elements early in the design process could greatly improve worker health and safety in the operation of offshore wind farms. 1 The American Society for Testing and Materials, now known as ASTM International, develops and delivers international voluntary consensus standards.
From page 147...
... and do not adequately cover worker health and safety on OCS wind farms. The MOA between BOEM and USCG sets a framework for communication and cooperation throughout the OREI process by avoiding overlapping and duplicative regulations with regard to vessels servicing OREIs, but it does not adequately cover worker health and safety.
From page 148...
... As noted at industry conferences, however, companies may be cautious about releasing health and safety data because of concerns with regard to potential litigation or greater regulatory scrutiny, even though maintaining and sharing data on KPIs in sufficient detail are important goals for the wind energy industry. Standards for reporting indicators therefore need to be developed; furthermore, standards for keeping records of this information and appropriate collection and publication of the indicators are priorities.
From page 149...
... The committee supports AWEA's attempt to benchmark industry safety data through an anonymous survey and to share the results of the survey with its members. To track suc cess or problems in managing health and safety on OCS wind farms, BOEM should enlist the help of industry and industry stakeholders in researching and developing standards for KPIs and in collecting, storing, and publishing this information.
From page 150...
... As it updates the inspection process and devel ops complete audit procedures, BOEM should examine the holistic approach recommended in the recent SEMS report as a model for offshore wind energy. BOEM should evaluate the effectiveness of a lessee's SMS program on the basis of principles outlined in the SEMS report (TRB 2012)
From page 151...
... Proper training of government regulatory personnel will be necessary as new health and safety regulations are instituted and inspection and audit processes are better defined. Any training program will require scalability as the offshore wind industry grows, but the scope of the potential program remains unclear.


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