Environmental management completion operations

BOEMRE is incorporating by reference, and making mandatory, the American Petroleum Institute s Recommended Practice for Development of a Safety and Environmental Management Program for Offshore Operations and Facilities (API RP 75), Third Edition, May 2004, reaffirmed May 2008. This recommended practice, including its appendices, constitutes a complete Safety and Environmental Management System (SEMS) program. 

Also in 2010, the Bureau of Safety and Environmental Enforcement (BSEE), part of the US Department of Interior, published the Final Rule for 30 CFR Part 250 Subpart S—Safety and Environmental Management Systems (Ref. US Federal Register, 75 FR 63610). The BSEE enforces safety and environmental protection on the 1.7 billion-acre US Outer Continental Shelf (affecting offshore oil and gas development). This Final Rule incorporates by reference, and makes mandatory, the American Petroleum Institute s Recommended Practice for Development of a Safety and Environmental Management Program for Offshore Operations and Facilities (API ILP 75),Third Edition, May 2004, reaffirmed May 2008.This recommended practice, including its appendices, constitutes a complete Safety and Environmental Management System (SEMS). 

Procedures should be established to periodically monitor all operations that may have an environmental impact, and similar scheduled periodic checks should be made to ensure that procedures and operations are still in line with regulatory and other requirements. If equipment is involved in the monitoring process then procedures should also be in place to ensure correct calibration. Procedures are also needed to record any preventative or corrective actions identified and to ensure that they are completed to schedule. The whole EMS should be audited periodically to check that it is consistent with the planned policy and has been properly implemented. The details of audits should be discussed and reviewed by management at the highest level with a view to continuous improvement through the modification of both policy and procedures. 

The management of contractors is important. Frequently, contract workers are involved in activities that have a high potential for injury, loss of life, environmental releases, and economic loss. In most cases, the contractor company is on site for a relatively short period of time. This means that the contractor s managers, supervisors, and workers are not likely to be completely familiar with the operating company s way of doing things. 

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