| Purpose: |
The purpose of this survey is to help BSEE update the Office of Management and Budget on the paperwork and cost burden associated with the SEMS regulations. Please fill in the white boxes below with the requested information. You can call Stan Kaczmarek (703-787-1612) if you have any questions. We request your response by February 6 if at all possible. |
Large |
Medium |
Small |
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| Company Name: |
Consolidated |
Contact Information: |
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Chevron |
Fieldwood |
DCOR |
Arena |
Eni |
Castex |
PetroQuest |
Whitney |
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numbers verified |
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numbers verified |
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numbers verified |
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numbers verified |
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numbers verified |
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numbers verified |
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numbers verified |
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numbers verified |
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| Type of Question |
Question |
Labor Hours associated with "Usual and Customary" business practices |
Additional Labor Hours due to BSEE requirements |
Recent Costs associated with "Usual and Customary" business practices |
Additional Costs due to BSEE requirements |
30 CFR 250 (Subpart S) Reference |
Labor Hours associated with "Usual and Customary" business practices |
Additional Labor Hours due to BSEE requirements |
Recent Costs associated with "Usual and Customary" business practices |
Additional Costs due to BSEE requirements |
Labor Hours associated with "Usual and Customary" business practices |
Additional Labor Hours due to BSEE requirements |
Recent Costs associated with "Usual and Customary" business practices |
Additional Costs due to BSEE requirements |
Labor Hours associated with "Usual and Customary" business practices |
Additional Labor Hours due to BSEE requirements |
Recent Costs associated with "Usual and Customary" business practices |
Additional Costs due to BSEE requirements |
Labor Hours associated with "Usual and Customary" business practices |
Additional Labor Hours due to BSEE requirements |
Recent Costs associated with "Usual and Customary" business practices |
Additional Costs due to BSEE requirements |
Labor Hours associated with "Usual and Customary" business practices |
Additional Labor Hours due to BSEE requirements |
Recent Costs associated with "Usual and Customary" business practices |
Additional Costs due to BSEE requirements |
Labor Hours associated with "Usual and Customary" business practices |
Additional Labor Hours due to BSEE requirements |
Recent Costs associated with "Usual and Customary" business practices |
Additional Costs due to BSEE requirements |
Labor Hours associated with "Usual and Customary" business practices |
Additional Labor Hours due to BSEE requirements |
Recent Costs associated with "Usual and Customary" business practices |
Additional Costs due to BSEE requirements |
Labor Hours associated with "Usual and Customary" business practices |
Additional Labor Hours due to BSEE requirements |
Recent Costs associated with "Usual and Customary" business practices |
Additional Costs due to BSEE requirements |
Internal Calculations |
| SEMS Design, Implementation and Maintenance |
How many labor hours per year does your organization spend creating and updating the policies and procedures that comprise your company's Safety and Environmental Management System (SEMS)? |
|
|
|
|
1900-1933 |
18,000 |
5,780 |
|
|
72 |
|
|
|
1,000 |
100 |
|
|
2,323 |
1,162 |
|
|
6,500 |
1,500 |
|
|
490 |
160 |
|
|
40 |
160 |
|
|
33 |
230 |
|
|
183 |
6222 |
|
| How many labor hours per year does your organization spend conducting, signing, and ensuring adherence to Job Safety Analyses (JSA)? |
|
|
1911(b) |
43,800 |
|
69,000 |
69,000 |
10,000 |
5,000 |
93,338 |
- |
24,000 |
480 |
168 |
12 |
86 |
815 |
426 |
137 |
75,444 |
4,828,416.00 |
|
| How many labor hours per year does your organization spend maintaining data for and submitting the BSEE-0131 Form (Performance Measures), maintaining a contractor employee injury/illness log in the operation area (and retaining it for two years), and making this information available to BSEE upon request? |
|
|
1914(e); 1928(d),(e); 1929 |
225 |
|
208 |
208 |
200 |
200 |
700 |
30 |
7,150 |
40 |
12 |
0 |
40 |
174 |
15 |
2 |
9,204 |
589,056.00 |
|
| What is the estimated cost to your organization of a comprehensive SEMS audit conducted by an accredited audit service provider (ASP)? |
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|
1920(a), (b); 1925 |
|
|
not provided |
not provided |
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|
$200,000.00 |
$200,000.00 |
|
|
$50,000.00 |
$50,000.00 |
|
|
70,000 |
35,000 |
|
|
$- |
$200,000.00 |
|
|
43,000 |
0 |
|
|
$35,000.00 |
$35,000.00 |
|
|
0 |
49,500 |
|
405,000.00 |
|
| How many labor hours per year does your organization spend to develop and submit your audit plan to BSEE? |
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|
|
1920 (b) |
2,260 |
|
|
|
|
40 |
|
|
40 |
40 |
|
|
- |
200 |
|
|
|
340 |
|
|
120 |
0 |
|
|
0 |
16 |
|
|
0 |
20 |
|
|
3,076 |
196,864.00 |
1974 |
| How many labor hours per year does your organzation spend to develop and submit your audit report to BSEE? |
|
|
1920(c); 1925(a) |
100 |
|
|
40 |
40 |
40 |
- |
200 |
|
240 |
120 |
0 |
0 |
8 |
0 |
104 |
892 |
57,088.00 |
1890 |
| How many labor hours per year does your organization spend to provide BSEE information it requests during the ASP-conducted SEMS audit |
|
|
1920 |
15 |
|
|
40 |
8 |
8 |
- |
200 |
|
20 |
12 |
0 |
0 |
0 |
0 |
12 |
315 |
20,160.00 |
840 |
| How many labor hours per year does your organization spend to develop and submit your corrective action plan to BSEE? |
|
|
1920(d); 1925(b) |
220 |
|
|
80 |
8 |
8 |
- |
150 |
|
480 |
100 |
0 |
0 |
24 |
0 |
24 |
1,094 |
70,016.00 |
2289 |
| How many labor hours per year does your organization spend to provide BSEE with information to verify that you undertook the corrective actions and that they effectively addressed the audit findings? |
|
|
1920(e) |
170 |
|
|
80 |
16 |
16 |
- |
200 |
|
520 |
40 |
0 |
0 |
8 |
0 |
Audit in Progress, we are not currently to that part of the audit. (History from previous company was approximately 4 hours in 2016) |
1,050 |
67,200.00 |
2877 |
| How many labor hours per year does your organization spend making your SEMS documentation available to BSEE in response to inpsection findings (BSEE or USCG) or an incident? |
|
|
1924 |
4,000 |
4,000 |
|
640 |
2,500 |
2,500 |
- |
625 |
|
260 |
12 |
0 |
0 |
0 |
0 |
6 |
14,543 |
930,752.00 |
64256 |
| How many labor hours per year does your organization spend making your SEMS documentation avaialble to BSEE for BSEE review not associated with an audit, inspection finding or incident? |
|
|
1924 |
150 |
|
|
300 |
1,000 |
500 |
- |
4,935 |
|
100 |
372 |
0 |
0 |
160 |
0 |
10 |
7,527 |
481,728.00 |
54912 |
| How many labor hours per year does your organization spend maintaining documentation per the following requirements: |
Retaining SEMS audit documents for six years at an onshore location? |
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1928(a) |
5 |
|
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|
5 |
|
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|
1 |
1 |
|
|
1,200 |
|
|
|
|
32 |
|
|
62 |
0 |
|
|
|
|
|
|
0 |
1095 |
|
|
2,401 |
153,664.00 |
18048 |
| JSA documentation? |
|
|
1928(b) |
60 |
|
2,300 |
2,300 |
250 |
250 |
15,556 |
|
|
400 |
62 |
0 |
0 |
272 |
10 |
70 |
|
- |
|
| MOC records? |
|
|
1928(c) |
22,500 |
|
200 |
|
250 |
125 |
600 |
|
|
200 |
62 |
0 |
0 |
87 |
4 |
4 |
|
- |
|
| SWA documentation? |
|
|
1928(f) |
- |
|
100 |
100 |
20 |
20 |
220 |
|
|
100 |
62 |
0 |
0 |
24 |
6 |
2 |
|
- |
|
| Employee participation plan documentation? |
|
|
1928(g) |
108 |
|
100 |
100 |
40 |
40 |
450 |
|
|
20 |
62 |
0 |
40 |
3 |
36 |
12 |
47,227 |
3,022,528.00 |
|
| Maintaining records in an orderly manner, readily identifiable, retrievalbe and legible,with dates of any and all revisions |
|
|
1928(h) |
1,080 |
|
2,000 |
|
1,200 |
600 |
7,750 |
|
15,330 |
5,720 |
62 |
0 |
10 |
1300 |
0 |
144 |
1,553 |
99,379.20 |
|
| SEMS Implementation (cont.) |
How many labor hours per year does your organization spend documenting decisions to resume SWA activities? |
|
|
|
|
1930(c) |
39 |
|
|
|
250 |
|
|
|
8 |
8 |
|
|
110 |
|
|
|
20 |
60 |
|
|
15 |
0 |
|
|
0 |
1 |
|
|
2 |
0 |
|
|
513 |
32,832.00 |
896 |
| How many labor hours per year does your organization spend on personnel reports of unsafe practices and/or health violations? |
|
|
1933(a) |
- |
- |
250 |
|
50 |
- |
750 |
|
1,989 |
40 |
40 |
0 |
0 |
0 |
12 |
0 |
7 |
426.67 |
|
| How many labor hours per year does your organization spend posting notice for personnel that displays their rights for reporting unsafe practices? |
|
|
1933(c) |
5 |
5 |
20 |
|
8 |
8 |
417 |
|
80 |
20 |
12 |
0 |
0 |
1 |
0 |
4 |
580 |
37,120.00 |
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Position |
Percent of work hours spent on SEMS documentation |
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Percent of work hours spent on SEMS documentation |
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Percent of work hours spent on SEMS documentation |
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Percent of work hours spent on SEMS documentation |
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Percent of work hours spent on SEMS documentation |
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|
Percent of work hours spent on SEMS documentation |
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|
Percent of work hours spent on SEMS documentation |
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|
Percent of work hours spent on SEMS documentation |
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|
|
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|
47,227 |
Percent of work hours spent on SEMS documentation |
|
| Please provide an estimate of the percent of time spent on SEMS data collection / documentation during the course of the year by a typical person in each of these positions |
HSE Engineer |
59% |
|
|
|
|
100% |
|
|
|
100% |
|
|
|
30% |
|
|
|
75% |
|
|
|
25% |
|
|
|
60% |
|
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|
55% |
|
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|
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|
59% |
26% |
|
| Production Engineer |
17% |
|
|
|
|
30% |
|
|
|
5% |
|
|
|
50% |
|
|
|
10% |
|
|
|
20% |
|
|
|
15% |
|
|
|
2% |
|
|
|
|
|
|
|
17% |
4% |
|
| Computer or Information Tech |
24% |
|
|
|
|
5% |
|
|
|
75% |
|
|
|
5% |
|
|
|
20% |
|
|
|
10% |
|
|
|
20% |
|
|
|
6% |
|
|
|
|
|
|
|
24% |
50% |
|
| Technician/Specialist/Support Staff |
54% |
|
|
|
|
30% |
|
|
|
100% |
|
|
|
50% |
|
|
|
65% |
|
|
|
100% |
|
|
|
60% |
|
|
|
25% |
|
|
|
|
|
|
|
54% |
4% |
|
| Supervisor/Superintendent/Lead |
22% |
|
|
|
|
10% |
|
|
|
50% |
|
|
|
15% |
|
|
|
25% |
|
|
|
15% |
|
|
|
80% |
|
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|
20% |
|
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|
|
|
|
|
27% |
3% |
|
| Operations Manager |
6% |
|
|
|
|
5% |
|
|
|
4% |
|
|
|
5% |
|
|
|
10% |
|
|
|
5% |
|
|
|
20% |
|
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|
0% |
|
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|
6% |
1% |
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| Please provide any additional comments that can help us understand your answers to this information request |
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15951 |
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44,928 |
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| Citation |
Reporting and Recordkeeping Requirement+ |
Avg. Hour Burden |
Average No. of Annual Responses |
Annual Burden Hours (rounded) |
Internal Calculations |
| 30 CFR 250 Subpart S |
|
|
23120 |
|
|
|
Totals: |
|
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| 1900-1933 |
High Activity Operator: Have a SEMS program, and maintain all documentation and records pertaining to your SEMS program, according to API RP 75, ISO 17011 in their entirety, the COS-2-01, 03, and 04 documents as listed in § 250.198, and all the requirements as detailed in 30 CFR 250, Subpart S. Make your SEMS available to BSEE upon request. |
11,926 |
8 |
95,408 |
1,477,349 |
row 5 |
|
|
8 |
|
1,477,349 |
burdon hours |
|
|
(760,815) |
|
|
|
|
|
|
| 340 |
|
|
|
22 |
|
$3,259,723 |
non-hour cost burden |
|
|
$1,960,277 |
|
|
|
|
|
|
| 1900-1933 |
Moderate Activity Operator: Have a SEMS program, and maintain all documentation and records pertaining to your SEMS program, according to API RP 75, the three COS documents in their entirety, and all the requirements as detailed in 30 CFR 250, Subpart S. Make your SEMS available to BSEE upon request. |
4195 |
22 |
92,290 |
|
row 5 |
|
|
34 |
|
750 |
responses |
|
|
|
|
|
|
|
|
|
|
|
|
|
64 |
|
- |
|
|
|
|
|
|
|
|
22.42 |
|
| 1900-1933 |
Low Activity Operator: Have a SEMS program, and maintain all documentation and records pertaining to your SEMS program, according to API RP 75, the three COS documents in their entirety, and all the requirements as detailed in 30 CFR 250, Subpart S. Make your SEMS available to BSEE upon request. |
371 |
34 |
12,614 |
|
row 5 |
|
|
64 |
|
1,960,277 |
|
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8 |
|
|
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| 1911(b) |
Immediate supervisor must conduct a JSA, sign the JSA, and ensure all personnel participating sign the JSA. The individual designated as being in charge of facility approves and signs all JSAs before job starts. NOTE: If activity is repeated, the 1st signed JSA is allowed. |
9,431 |
64 |
603,552 |
|
|
|
|
22 |
|
|
|
|
|
|
|
|
|
|
|
225 |
|
|
|
|
34 |
|
|
|
|
|
|
|
|
|
|
|
416 |
| 1914(e); 1928(d), (e); 1929 |
Submit Form BSEE-0131. Maintain a contractor employee injury/illness log in the operation area, retain for 2 years, and make available to BSEE upon request (this requirement is included in the form burden). Inform contractors of hazards. |
1151 |
64 |
73,632 |
39270 |
|
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|
21 |
|
|
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|
|
|
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|
|
400 |
| 1920(a), (b); 1921 |
ASP audit for High Activity Operator |
8 operators x $400,000 audit = $3,200,000 / 3 = $1,066,667 |
|
|
1685224 |
|
21 |
|
Average Respondent Cost Table |
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|
730 |
| ASP audit for Moderate Activity Operator |
$1,066,667 |
400,000 |
|
|
21 |
|
Position |
Hourly Pay rate ($/hour estimate) |
Hourly rate including benefits (1.4* x $/hour) |
Percent of time spent on collection |
Weighted Average ($/hour/ rounded) |
|
|
|
|
|
7190 |
| ASP audit for Low Activity Operator |
22 operators x $135,000 audit = $2,970,000 / 3 = $990,000 |
$990,000 |
135,000 |
|
|
21 |
|
HSE Engineer |
$80 |
$113 |
59% |
$66 |
|
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|
|
|
12 |
| NOTE: An audit is done once every 3 years. |
34 operators x $54,167 audit = $1,841,678/3 = $613,889 |
$613,889 |
54,167 |
|
|
21 |
|
Production Engineer |
$78 |
$109 |
17% |
$19 |
|
|
|
|
|
214 |
| 1920(b) |
Notify BSEE with audit plan/schedule 30 days prior to conducting your audit. |
385 |
21 |
8,075 |
|
|
|
|
1 |
|
Computer or Information Tech |
$75 |
$105 |
24% |
$25 |
|
|
|
|
|
17 |
| 1920(c); 1925(a); |
Submit to BSEE after completed audit, an audit report of findings and conclusions, including deficiencies and required supporting information/ documentation. |
112 |
21 |
2,342 |
|
|
|
|
1 |
|
Technician/Specialist/Support Staff |
$62 |
$87 |
54% |
$47 |
|
|
|
|
|
|
| 1920 |
Submit to BSEE information it requests during the ASP-conducted SEMS audit |
39 |
21 |
827 |
|
|
|
|
64 |
|
Supervisor/Superintendent/Lead |
$107 |
$150 |
27% |
$40 |
|
|
|
|
|
|
| 1920(d); 1925(b); |
Submit/resubmit a copy of your CAP that will address deficiencies identified in audit within 60 days of audit completion. |
137 |
21 |
2,872 |
|
|
|
|
64 |
|
Operations Manager |
$135 |
$189 |
6% |
$11 |
Stan sees a salary for this position of $280,420, cannot find that, but used 280,420 / 2080 |
|
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| operators |
|
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|
3 |
|
Weighted Average ($/hour) |
$209 |
|
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|
|
|
|
| 1920(e) |
Submit to BSEE information to verify operator undertook the corrective actions and that they effectively addressed audit findings |
131 |
21 |
2,756 |
|
|
|
|
64 |
|
|
|
|
|
|
|
|
|
|
|
|
| 1922(a) |
Labor hours spent by AB meeting ISO 17011 (or equivalent) requirements |
420 |
1 AB |
420 |
1160 |
|
|
|
64 |
|
|
|
|
|
308,765,915 |
|
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|
|
| 1500 |
|
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|
64 |
|
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|
| 1922(b) |
Make available to BSEE upon request, AB activity details and conflict of interest procedures. |
234 |
1 AB |
234 |
|
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|
|
64 |
|
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|
Average Government Cost Table |
|
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|
|
|
|
|
|
|
| 1924(b) |
Make available to BSEE upon request, evaluation documentation and supporting information relating to your SEMS. |
941 |
64 |
60,216 |
|
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|
Position |
Grade |
Hourly Pay rate ($/hour estimate) |
Hourly rate including benefits (1.5* x $/hour) |
Percent of time spent on collection |
Weighted Average ($/hour) |
|
|
|
|
|
| 1924 |
Make available to BSEE SEMS documentation in response to inspection findings (BSEE or USCG) or an incident. |
1,818 |
64 |
116,344 |
|
|
|
|
|
|
Clerical |
GS-7/5 |
$22 |
$33 |
15% |
$5 |
|
|
|
|
|
| 1925(a); |
Pay for all costs associated with BSEE directed ASP audit approximately 10 percent per operator per category: 1 required audit for high operator ($100,000 per audit x 1 audit = $100,000); 2 required audits for moderate operator ($95,000 per audit x 2 audits = $190,000; and 4 required audits for low operator ($28,167 per audit per 4 audits = $112,668) = 7 required audits per year. |
3 BSEE directed ASP audits – for a total of $589,167 |
$589,167 |
|
|
large |
$400,000 |
|
|
Petroleum Engineer/Geologist/Geophysicist |
GS-12/5 |
$45 |
$68 |
75% |
$51 |
|
|
|
|
|
|
|
200000 |
medium |
$135,000 |
|
|
Supv. Petroleum Engineer/Geologist/Geophysicist |
GS-14/5 |
$63 |
$95 |
25% |
$24 |
|
|
|
|
|
| 1928 |
(1) Document and keep all SEMS audits for 6 years (at least two full audit cycles) at an onshore location. |
300 |
64 |
19,208 |
|
95000 |
small |
$54,167 |
|
|
Regulatory/Program Analyst |
GS-12/5 |
$40 |
$60 |
35% |
$21 |
|
|
|
|
|
| (2) JSAs must have documented results in writing and kept onsite for 30 days or until release of the MODU; retain records for 2 years. (3) All MOC records (API RP Sec 4) must be documented, dated, and retained for 2 years. (4) SWA documentation must be kept onsite for 30 days; retain records for 2 years. (5) Documentation of employee participation must be retained for 2 years. |
5903 |
64 |
377,816 |
|
28167 |
|
$589,167 |
|
|
Weighted Average ($/hour) |
$100 |
|
|
|
|
|
| 1930(c) |
Document decision to resume SWA activities. |
64 |
64 |
4104 |
|
323167 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 1933(a) |
Personnel reports unsafe practices and/or health violations. |
Burden covered under 30 CFR 250, Subpart A 1014-0022. |
0 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| 1933(c) |
Post notice where personnel can view their rights for reporting unsafe practices. |
73 |
64 |
4640 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| TOTAL SUBPART S |
750 |
1,477,349 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Responses |
Hours |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| $3,259,723 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
| Final table in Word document: hours associated with submittals or making info available to BSEE upon request. |
|
|
|
Internal Calculations |
| Citation |
Requirement |
Industry’s Burden Hour |
Government’s Burden Hour |
|
|
|
|
|
Stan's Gov hours |
|
| §§ 250.1900-1933 |
High, Moderate, and Low Activity Operator – Maintain SEMS, make available to BSEE upon request. |
200,312 |
5,000 |
200,312 |
95,408 |
92,290 |
12,614 |
|
5,000 |
1/ |
| §§ 250.1900(b); 1914(d); 1928(d), (e); 1929 |
Submit Form BSEE-0131. |
73,632 |
130 |
73,632 |
|
|
|
|
130 |
2/ |
| § 250.1920 |
Notification of audit schedule. |
8,075 |
450 |
8,075 |
|
|
|
|
450 |
3/ |
| §§ 250.1920(c); 1925(a), (c); |
Submit audit reports. |
2,342 |
500 |
2,342 |
|
|
|
|
500 |
4/ |
| §§ 250.1920(d), 1925(c) |
Submit/resubmit CAP. |
5,628 |
900 |
5,628 |
2,872 |
2,756 |
|
|
900 |
5/ |
| § 250.1922 |
Submit documentation and relevant info about ASP. |
420 |
6 |
420 |
420 |
|
|
|
6 |
|
| § 250.1922 |
Make available to BSEE upon request, conflict of interest procedures. |
234 |
1 |
234 |
|
|
|
|
1 |
|
| § 250.1924(b) |
Upon request make available evaluation documentation and supporting info about SEMS. |
60,216 |
125 |
60,216 |
|
|
|
|
125 |
6/ |
| § 250.1924 |
Provide SEMS information per BSEE requests in response to INCs or an incident. |
116,344 |
1,000 |
1,818 |
|
|
|
|
1,000 |
7/ |
| § 250.1928 |
Documentation/recordkeeping |
397,024 |
3,500 |
397,024 |
19,208 |
377,816 |
|
|
3,500 |
|
| Total |
864,226 |
11,612 |
749,700 |
|
|
|
|
11,612 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
(189,646) |
|
|
|
|
1,163,522 |
|
|
|
|
|
2,078,700 |
|
|
|
|
|
|
|
|
|
|
1161200 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Stan's comments: |
|
|
|
|
|
|
|
|
|
| 1/ |
2700 hours of inspector time looking at JSA’s and Mechanical Integrity records, which would be 1 hour per production and drilling / well work inspection (data on # inspections from inspections group for 2017) |
|
| 2/ |
Assumes 65 submittals and 2 hours per company for Gabe to handle it |
|
|
|
|
|
|
|
|
|
| 3/ |
This line deals with receipt and handling of Audit Plans, assuming 25 plans received per year on average and 16 hours to review and comment on it, plus 50 hours to chase down late submittals |
|
| 4/ |
Assumes 25 reports per year, and 20 hours per report for BSEE to review it, request changes, accept report, and extract data for analysis |
|
|
|
|
|
|
|
|
|
| 5/ |
Assumes 300 hours per year reviewing 30 Corrective Action Plan submittals, and 600 hours per year verifying the CAP |
|
|
|
|
|
|
|
|
|
| 6/ |
Assumes 15 random reviews /yr of different company’s SEMS information at 8 hours per review |
|
|
|
|
|
|
|
|
|
| 7/ |
Assume 40 hours per incident to review SEMS related documentation, with 25 incidents per year receiving this level of review |
|
|
|
|
|
|
|
|
|