Assessment of Voluntary Compliance with API RP 75 "What Industry is Doing"
Authors: Rullman J.D. 
Published: October 2008

In 1992 and 1993, API developed RP 75 (Safety and Environmental Management Program [SEMP] for Outer Continental Shelf [OCS] Oil and Gas Operations) in cooperation with the Minerals Management Service (MMS). MMS currently supports API and Offshore Operators Committee (DOC) suggestions that compliance with RP 75 should be voluntary versus regulatory. However, MMS will examine progress and success of industry wide voluntary implementation of RP 75 and after wo years decide whether to continue with voluntary implementation or to proceed with rulemaking.

Additionally, MMS participated with API and DOC to develop an API RP 75 implementation status assessment process including an assessment form.

This paper describes the industry-wide assessment process and explains how the data will be summarized.

The first industry-wide assessment was performed during January and February 1995. Results of this assessment were not available when this paper was written.

WHY ARE ASSESSMENTS NECESSARY?

After MMS agreed that voluntary implementation of API RP 75 was acceptable, an API/OOC/MMS committee formed to determine how to measure the level and pace of voluntary implementation. This committee determined that an industry-wide self assessment was the most reliable method and it should be pursued. Additionally, the committee determined that the self-assessment should be standardized and repeated annually to measurechanges in the level of voluntary implementation from year-to-year. MMS will also monitor progress of voluntary implementation of RP 75 by solicitinginformal information directly from operators and making general onsite inquiries.

MMS plans to review the overall industry-wide voluntary implementation status of RP 75 after two years and if MMS deems voluntary implementation to be unsuccessful they may promulgate SEMP regulations.

WHAT WILL BE ASSESSED?

RP 75 has 12 sections. Each section contains elements with recommended action and these elements were concisely paraphrased on two pages of the survey form. Altogether there are 31 elements.

To facilitate standardization and to make the survey easy to complete, a six point implementation status was defined from "No action taken to-date" to "Reassessing RP 75 Implementation for Continuous Improvement". Figures 1 and 2 are copies of the two page assessment form containing the six point implementation status for the 12 sections and 31 elements. Each element is assessed by checking the appropriate implementation status box. At the bottom of Figure 2 is a request for the daily average gross operated OCS oil equivalent production. This information will be used for production weighting of the assessment results.

WHEN WILL THE ASSESSMENTS TAKE PLACE?

The first industry-wide assessment was performed in January and February 1995. Follow-up assessments will take place annually at about that same time. MMS plans to thoroughly review the overall status of voluntary implementation after two years to determine what additional action they will take, if any. However, the assessments will most likely continue beyond two years.

Upon completion of each annual assessment API and OOC will meet with MMS to present the results and discuss possible action needed to enhance SEMP on the OCS, if any.

The first industry-wide assessment results were not available when this paper was written.