Note whether the offshore file describes a SEMS program
Key facts
- Human involvement
- YellowClose supervision
- How AI is used
- From the offshore operations file the lawyer supplies, copy any passage that says a safety and environmental management system is in place, with the page. Do not list the program elements and do not say the program is adequate. Do not apply the section to an onshore lease.
- What the lawyer must review
- 30 C.F.R. 250.1900 provides that the operator addressed as "you" must develop, implement, and maintain a safety and environmental management system program, and that the program must address the elements described in section 250.1902, API Recommended Practice 75, and other requirements identified in that subpart. If those incorporated documents conflict with the subpart, the operator must follow the subpart. Nothing in the subpart affects safety or other matters under the jurisdiction of the Coast Guard. Section 250.1902 and API Recommended Practice 75 were not opened. The page opened does not define "you" beyond the section text. The lawyer confirms that 30 C.F.R. part 250 applies to the operation. The note does not decide that the program meets the subpart.
Who does what
| Role | What they do |
|---|---|
| Assistance | Consider narrowly defined preparation support after confirming the tool’s capability and permitted scope. |
| Lawyer | Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output. |
Checklist
- Confirm instructions and personal circumstances through appropriate direct engagement. Have the responsible lawyer assess safety, capacity or vulnerability concerns and escalation.
- Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
- Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
- Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.