Implementing Api Rp 75 "Recommended Practice For Development Of A Safety And Environmental Program For Outer Continental Shelf (Ocs) Operations And Facilities"
Authors: Easley L.D. , Stark J.E. , Bradford R.A. 
Published: October 2008

The Minerals Management Service (MMS) is watching industry's acceptance of API RP 75 so that they can evaluate the need for regulations which would impose a Safety and Environmental Management Program (SEMP) for Outer Continental Shelf (OCS) facilities. This paper demonstrates how one company (Phillips Petroleum Co.) developed a Process Safety Management (PSM) program to comply with the Occupational Safety and Health Administration (OSHA) PSM regulation and how this program was adapted to SEMP. This on-going effort has resulted in a reduction in the time to implement API RP 75 in offshore operations.

INTRODUCTION

In the late 1980's many facilities experienced events in which there were catastrophic results which caused loss of life and property. The publics' very vocal reaction to these incidents caused industry and government to look for a means to evaluate and reduce the risk of these catastrophic accidents occurring.

In 1992, the United States Occupational Safety and Health Administration (OSHA) issued 29 CFR 1910.119.1 This regulation published the requirements for preventing or minimizing catastrophic releases of toxic, reactive, flammable, or explosive chemicals which could result in hazards to human health or the environment. This regulation is the basis for Process Safety Management (PSM) of highly hazardous chemicals and applies to many facilities within the Oil and Gas Industry.

In order to comply with the OSHA PSM regulation, the upstream organizations formed a task force of managers, engineers and safety professionals. This task force had as its objective to write an Upstream PSM policy which would be consistent with 29 CFR 1910.119. Further, the task force was to prepare an implementation plan which outlined the way the PSM policy would be taken to each facility to give the time lines to be in compliance. Concurrent with this work, Corporate Reviews and Assessments staff prepared audit checklists. These checklists would be used by an audit team to assess whether a facility was in compliance with the PSM regulations. The checklists were available to the facilities for their use in self audits. Responsibility for the implementation schedule was shared between management and the facilities. This was done to maximize the involvement of each of the facilities' employees. The organization will be discussed later. However, it proved very successful and program acceptance was quite high.

Many questions arose during the public comment period for the OSHA PSM standard about the applicability of the OSHA PSM to Outer Continental Shelf (OCS) facilities. Both the Minerals Management Service (MMS) and OSHA made it clear that 29 CFR 1910.119 would not apply to these facilities. In July 1991, the MMS published a Notice of Proposed Rule Making (NPRM) of the Safety and Environmental Management Program SEMP) concept. Shortly thereafter, MMS approached the American Petroleum Institute (API) to revise API RP 7502 so that it could be applied, as SEMP, to the OCS. The API agreed and formed a Task Force which included MMS, U.S. Coast Guard and industry personnel to make the revision.