The Final Rule: Stop Work Authority (SWA) Requirements

What is Stop Work Authority (SWA)?

Stop Work Authority (SWA) gives personnel the responsibility and authority to require that all work be halted when a dangerous condition is observed.

Stop Work Authority has two levels:

• Level 1 – Immediate Correction – You see someone doing something unsafe and ask them to alter their behavior to avoid injury to themselves and/or others.
• Level 2 – Delayed Correction – When the safety concern can’t be immediately corrected, and the work must cease until an acceptable fix can be implemented.

STW and the Final Rule

The Final Rule requires operators to create and implement an SWA program that will ensure that all personnel are granted the authority and responsibility to halt work when they see an activity that poses an imminent danger to the health and/or safety of an individual, the environment, or the public.  The SWA must include the authority to stop any specific activity or task that poses such a risk or danger.  The Rule further states that those receiving notification to stop work must comply immediately.

Personnel who are exercising the SWA should have a discussion with their supervisors, co-workers, and/or safety representatives in an attempt to alleviate safety issues that might be causing the dangerous conditions.

When there is a stop in work, the Final Rule states that the person in charge of the task in question is the one responsible for making sure the work is halted in a safe and orderly fashion.  The Rule further states that the work can only be resumed when the person with UWA on the facility makes the determination that the danger no longer exists, or did not exist to begin with.

Training

With the Final Rule, the BSEE now mandates that the operator conduct training on their SWA procedures as part of orientation for all new employees performing activities on the OCS.  The SWA procedures must also be reviewed as part of all safety meetings related to facilities that are subject to SEMS.

Documentation

According to the Final Rule, when documenting SWA procedures, all records must be kept onsite for 30 days, or until such time when the operator releases the MODU.  While these documents, generally, must be maintained at an onshore location, the BSEE states that there are some JSA and SWA records that must be kept on the actual facility where the job or operation is being performed. If a facility cannot maintain onsite records for the period of time that the Final Rule specifies, that facility must be modified.  Records can be kept as hard copies or electronically.

Questions?  The attorneys at The Young Firm are ready to answer your questions and address any concerns about the Final Rule.  Call us today at 866-920-8471, or reach out to us on our webpage.