Safety and Environmental Management Program 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... 

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 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... 

The Flixborough event is one of the three incidents in this chapter that occurred onshore. However, this event is extremely important to all types of process industry because it led to the creation of process safety management (PSM) systems—which in turn provided the foundation for many other similar systems, including safety and environmental management program (SEMP) and SEMS. 

In Chapter 1, it was noted that, following the Piper Alpha catastrophe of 1988, two approaches to the development of Safety Management Systems (SMSs) were followed. The first (shown in the top line of Figure 1.5) was the use of Safety and Environmental Management Program (SEMP and later SEMS) standards, mostly in the USA. The second approach, used initially in the United Kingdom, and later elsewhere, was that of Safety cases. This chapter discusses the first of these approaches SEMP and the use of industry standards. Safety cases are described in Chapter 6. 

RP 75 states, The objective of this recommended practice is to form the basis for a Safety and Environmental Management Program (SEMP). It goes on to say, Management (owner and operator) should require that the program elements are properly documented and available at field and/or office locations, as appropriate for each program element. ... 

The rule covers all oil and gas facilities on the OCS in US waters, and is based on the Safety and Environmental Management Program (SEMP) standard that was discussed in the Chapter 3 (The single letter change—from SEM P to SEM S —is significant.) SEMS is a system in which the parts link to one another. 

The first conclusion to be drawn from Table 5.1 is that high activity (usually the larger) companies should have litde trouble meeting the SEMS rule because they are all in 100% compliance with the Safety and Environmental Management Program (SEMP). This does not mean, however, that these companies do not have some make-up work to do. As discussed in the previous chapter, when it created SEMS, BOEMRE added a considerable amount of material to SEMP. It is possible that some of the high-activlty companies may find that there are areas in which they still do not meet the requirements of SEMS. 

The discussion then moves on to the Safety and Environmental Management Program (SEMP—the standard issued by the API in the early 1990s) and the newly published SEMS. These topics are front and center stage for any company operating in US waters. But they possess universal relevance. The principles and application of the elements of SEMS can be applied to any production platform or drilling rig anywhere in the world. 

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

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. 

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