MMS Perspective on API RP 75 and API RP 14J

ABSTRACT In response to the evolution of the Outer Continental Shelf (OCS) oil and gas program in the United States, the Minerals Management Service (MMS) is shifting its regulatory emphasis from a regulation-driven inspection system toward performancebased requirements. The MMS is placing more responsibility for safety and environmental protectionon the operators and less reliance on prescriptive government rules. In response to the MMS publication of a proposed Safety and Environmental Management Program (SEMP), the American Petroleum Institute (API) developed and issued itsown Recommended Practice (RP) 75 to be used by companies who want to set up their own SEMP plan. The MMS agreed to delay issuing regulations for a 2-year period to allow industry to voluntarily adopt RP 75. The API is conducting an operator survey. The MMS will examine the survey resultsto determine the progress of voluntary implementation and decide whether regulation is necessary. BACKGROUND In 1989 and 1990, the Minerals Management Service (MMS) conducted intensive reviews of its own and the offshore industry's safety practices. Thereports following these reviews showed, in part, thatOCS operators need to improve the human and organizational aspects of their safety programs, andMMS should refocus its regulatory program toemphasize the role of human, organizational, and management influences on offshore safety. The response to this has been the Safety and Environmental Management Program concept"or SEMP. Central to this concept is the recognition that responsibility for safety on the OCS rests with the operators. The MMS cannot inspect safety intothe operations; it must become an integral part of the way the industry does business by making a commitment to safety throughout the organization from deck floor to corporate board room. To implement this idea, MMS announced its intention to investigate alternative strategies to promotesafety and environmental protection on the OCS. Published in 1991, the Federal Register noticeoutlined the SEMP concept. Numerous respondents asked MMS to defer publishing SEMP regulations and to allow industry to develop a voluntary approach. To this end, the American Petroleum Institute (API) developed and published with MMS participation RP 75- Recommended Practices for Development of a Safety and Environmental Management Program for Outer Continental Shelf (OCS) Operations and Facilities' and its companion document RP 14J. THE REGULATORY ENVIRONMENT Since the publication, the MMS has worked to promote the voluntary adoption of RP 75. Workshopswere held in New Orleans, Louisiana, and Houston, Texas, in conjunction with API and Offshore Operators Committee (OOC). In addition, the MMS Director met with the Independent Petroleum Association of America (lPAA), which represents smaller independent producers. The MMS has also focused attention on the drilling community, having made presentations at the International Association of Drilling Contractors' (IADC) Annual Meeting and the Well Control Conference of the Americas. The MMS approach to safety and environmentalManagement is not surprising when viewed in the context of regulation generally. Several domestic and international regulatory efforts with similar characteristics have evolved simultaneously. All of them do or can potentially affect the offshore oil.