Safety and Environmental Management Program (SEMP) Case Study
Authors: Hoyle Jay T. , Dykes J. David 
Published: October 2008

The Minerals Management Service and Department of Energy sponsored a case study project with Taylor Energy Company and Paragon Engineering Services, Inc., to demonstrate how small and medium-sized OCS operators might develop andimplement a Safety and Environmental Management Program (SEMP). The approaches used in the development andimplementation of each element of Taylor's SEMP program are presented in this paper. Also presented are the time and costs required to develop and implement this program. The plans and procedures used to develop Taylor's SEMP can beused by other small and medium-sized operators as a model as they institute SEMP in their operations.

Introduction

On June 30, 1994, the Minerals Management Service (MMS) published a Federal Register notice requesting that industry voluntarily adopt the American Petroleum Institute (API) RP75: Recommended Practices for Development of a Safety and Environmental Management Program for OuterContinental Shelf(OCS) Operations and Facilities (Reference I). API RP75 presents recommendations for the identification and management of safety and environmental hazards in the design, construction, startup, operation, inspection, and maintenance of drilling and production facilities located in theOCS.

In response to the MMS request, some small and medium sized independent operators have raised questions regarding the efforts and costs required to successfully implement a safety and environmental management program (SEMP). The MMS and Department of Energy (DOE) determined that acase study could demonstrate the development and implementation of a SEMP program. As a result, the MMS and DOE entered into a 30-month study with Taylor EnergyCompany (Taylor) and Paragon Engineering Services, Inc. (Paragon) to demonstrate how small and medium-sized operators could develop and implement a SEMP program.

The SEMP program developed in this case study was based on the recommendations of API RP75; however, the program does not specifically comply with each point contained in API RP75. Rather, the program reflects thepolicies, programs, and procedures developed to meet Taylor's operating philosophy and organizational structure. As such, Taylor's SEMP program demonstrates the structureand implementation of a cost-effective SEMP specifically tailored to a small-sized independent Gulf of Mexico operator.

Development of the Safety and Environmental Management Program Manual

As the starting point, this project used a system for implementing SEMP which had been previously developed byParagon (Reference 2). This plan recognizes that the elements and requirements of SEMP can be categorized based on whether or not they are site-specific. Most of thoserequirements which are not site-specific can be developed and maintained in a Safety and Environmental Management Program Manual (SEMP Manual) which then applies to all facilities subject to the company's SEMP program. Additionally, safe work practices are applicable to all facilities and can be contained in generic company-wide manuals as discussed in detail below. Finally, those requirements which are site-specific requirements must be prepared for each facility covered by the SEMP program.