Safety and Environmental Management Program

This chapter discusses overall safety analysis techniques lor evaluating production facilities, describes the concepts used to determine where safety shutdown sensors are required, and provides background and insight into the concept of a Safety and Environmental Management Program. 

American Petroleum Institute (API), RP 75. Recommended Practices for Development of a Safety and Environmental Management Program for Outer Continental Shelf (PCS) Operations and Facilities. API, Washington, D.C., 1993. 

RP 75—Development of a Safety and Environmental Management Program for Offshore Operations and Facilities (SEMP)... 

The MMS s Safety and Environmental Management Program (SEMP) was developed in response to the 1990 finding of the National Research Council s Marine Board that MMS s prescriptive approach to regulating offshore operations had forced industry into a compliance mentality. The Marine Board found further that this compliance mentality was not conducive to effectively identify all the potential operational risks or developing comprehensive accident mitigation. As a result, the Marine Board recommended and MMS concurred that a more systematic approach to managing offshore operations was needed. 

The operators [and contractors with Safety and Environmental Management Programs (SEMPs)] should establish and maintain an audit program and procedures for the periodic audit of the safety and environmental management program in order to determine if the program elements have been properly implemented and maintained and to provide information on the results of the audit to management... 

During each audit, at least 15% of the facilities operated, with a minimum of one facility, should be audited. The facilities included in the audit should not be the same as those included in the previous audit. When sufficient deficiencies are identified in the effectiveness of any safety and environmental management program elements, the test sample size shall be expanded for that program element. 

Petroleum Institute (API) developed their Recommended Practice 75 (RP 75), which recommended that offshore facilities develop a Safety and Environmental Management Program (SEMP). Like a safety case, RP 75 is mostly nonprescrip-tive. However, it makes extensive reference to industry standards (mostly from the American Petroleum Institute), and so it is perceived as being considerably more prescriptive then the safety case approach. Nor does RP 75 require that a formal assessment of acceptable risk (ALARP) be determined. 

In the United States, the response to The Cullen Report s recommendations was different. In the Gulf of Mexico there are thousands of platforms, many of them relatively simple, unmanned four-legged structures, often located in shallow water. To develop a Safety Case for each of these facilities would be impractical so it was decided to issue standards, generally under the auspices of the American Petroleum Institute. Safety management topics were collected under the umbrella of RP 75 (API 2004), which recommended that companies develop a Safety and Environmental Management Program, or SEMP. 

Audit of safety and environmental management program elements (Section 12). 

The elements of these recommended practices should be applied to these facilities, as appropriate. For simple and nearly identical facilities (such as well jackets and single-well caissons), certain elements of the safety and environmental management program, as applicable, need be addressed only once, after verifying that site-specific deviations have been evaluated. 

Various elements in the safety and environmental management program identify documentation requirements. In addition to those requirements, documentation should be sufficient to describe the core elements of the program and the interaction between the elements. 

The following are examples of related documentation that may be used in developing or implementing the safety and environmental management 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). 

American Petroleum Institute (API). RP 75L, Recommended practices for development of a safety and environmental management program for outer continental shelf (OCS) operations and facilities. Washington, DC API 2007. 

In the USA (principally the GoM) the response to the Piper Alpha incident was equally vigorous, but followed a different path. Rather than following the safety case approach, it was recommended that companies develop a Safety and Environmental Management Program (SEMP) as described in API Recommended Practice 75. Like... 

Auditof Safety and Environmental Management Program Elements... 

---