API Recommended Practice 75

Abstract

Guidance for the development and implement of safety management programs for offshore facilities.

Introduction

The defining event for offshore safety management was the Piper Alpha catastrophe that occurred in the North Sea in 1988. The loss of 147 lives and the destruction of the platform unequivocally showed that the offshore industry needed to make drastic improvements in its safety management practices. Just as the explosion at the Flixborough chemical plant in England in 1974 led to the development of Process Safety Management (PSM) programs for onshore facilities such as chemical plants and  refineries, so Piper led to a new generation of offshore safety management programs.

 

 

 

 

The approach to offshore safety management followed by companies working in European waters was to develop Safety Cases and then implement Safety Case Regimes. In the United States a different strategy was followed. The basic strategy was to follow the guidance provided by the American Petroleum Institute (API) in its Recommended Practice 75 - Development of a Safety and Environmental Management Program for Offshore Operations and Facilities. This standard was first issued in the year 1993; the latest update (the 3^rd edition) was published in May 2004.

 

The standard, which is a recommended practice, not a regulatory requirement, describes how offshore operators can create a Safety, Environmental Management Program, (details of which are provided at a separate SEMP page). RP 75 incorporates the input and experience from many organizations including the Minerals Management Service (now the Bureau of Safety and Environmental Enforcement or BSEE), the Coast Guard, the Offshore Operators Committee , the National Ocean Industries Association, the Independent Petroleum Association of America, and the International Association of Drilling Contractors.

API RP 75 and SEMP are likely to provide the foundation for the proposed rule SEMS rule from the BOE to do with the creation and management of a Safety and Environmental Management System (SEMS).

Like other types of PSM program (and also the safety case method), API RP 75 is performance based, although its extensive references to other standards (mostly from the API itself) do make it relatively prescriptive. Fundamentally, facilities are not judged on their direct compliance with a prescriptive standard – instead they are expected to operate in a safe and clean manner and to have a program for continuous improvement.

The RP 75 standard is broad in scope, covering new, existing and modified drilling and production facilities. It addresses the identification and management of safety hazards and environmental impacts in the following areas:

• Design; 
• Construction;
• Start-up;
• Operation;
• Inspection; and
• Maintenance

Management
 

RP 75 requires that the management of and offshore facility have a safety program based on the following principles:

1. A written program is required.
2. Leadership, accountability and resources must be provided.
3. Representatives must be appointed to establish, implement and maintain the SEMP.
4. There are also representatives who report to management on the performance of the SEMP.
5. The SEMP should be reviewed regularly.
6. A written description of the organization and lines of responsibility is required.
7. The expertise of personnel should be utilized in areas such as the identification of hazards, the development of safe work practices, the development of training programs and the investigation of incidents.
8. The owner, operator and contractor management have their own responsibility for assuring safe operations.
9. Industry codes should be used in the design, construction, maintenance, and operation of the facility.
10. The management of safety is an integral part of the design and operation of the facility.
11. All persons involved in SEMP must be properly trained.
12. The SEMP should be regularly audited.

Contractors and Bridging Documents

Although RP 75 does not require contractors to have their own SEMPs, it does require that they be familiar with the operator’s SEMP and that the contractor’s safety and environmental policies and practices be consisistent with the operator’s SEMP. If the contractor does have its own SEMP, say for drilling operations, then a bridging document is needed. The document will specify which SEMP requirements are relevant for specific operations.

The following non-exhaustive list of covered contractor activities is provided:  

• Drilling;
• Workover;
• Well servicing;
• Construction;
• Electrical;
• Mechanical;
• Diving;
• Boat and helicopter transportation;
• Painting;
• Operating; and
• Catering/janitorial

References to other Standards

As already noted, an important feature of RP 75 is that it makes reference to many other API standards, some of which are listed below. Those that are particularly important components of a SEMP program have been highlighted.

• Bull. E2 Management of Naturally Occurring Radioactive Materials (NORM) in Oil and Gas Production
• Publ 510 Pressure Vessel  Inspection Code: Maintenance Inspection, Rating, Repair, and Alteration
• Publ 521 Guide for Pressure-Relieving and Depressuring Systems
• Publ 2004 Inspection for Fire Protection
• Publ 2007 Safe Maintenance Practices in Refineries
• Publ 2015 Cleaning Petroleum Storage Tanks
• Publ 2201 Procedures for Welding or Hot Tapping on Equipment Containing Flammables
• Publ 2207 Preparing Tank Bottoms for Hot Work
• Publ 2217A Guidelines for Work in Inert Confined Spaces in the Petroleum Industry
• Publ 2510 Design and Construction of Liquefied Petroleum Gas (LPG) Installations
• Publ 2510A Fire-Protection Considerations for the Design and Operation of Liquefied Petroleum Gas (LPG) Storage Facilities
• RP 1107 Pipeline Maintenance Welding Practices
• RP 2D Operation and Maintenance of Offshore Cranes
• RP 4G Maintenance and Use of Drilling and Well Servicing Structures
• RP 14C Analysis, Design, Installation and Testing of Basic Surface Safety Systems on Offshore Production Platforms
• RP 14E Design and Installation of Offshore Production Platform Piping Systems
• RP 14F Design and Installation of Electrical Systems for Fixed and Floating Offshore Petroleum Facilities for Unclassified and Class I, Division 1, and Division 2 Locations
• RP 14FZ Design and Installation of Electrical Systems for Fixed and Floating Offshore Petroleum Facilities for Unclassified and Class I, Zone 0, Zone 1 and Zone 2 Locations
• RP 14G Fire Prevention and Control on Open Type Offshore Production Platforms
• RP 14J Design and Hazards Analysis for Offshore Production Facilities
• RP 49 Drilling and Well Servicing Operations Involving Hydrogen Sulfide
• RP 53 Blowout Prevention Equipment Systems for Drilling Wells
• RP 54 Occupational Safety for Oil and Gas Well Drilling and Servicing Operations
• RP 55 Oil and Gas Production and Gas Processing Plant Operations Involving Hydrogen Sulfide
• RP 59 Well Control Operations
• RP 64 Diverter Systems Equipment and Operations
• RP 70 Security for Offshore Oil and Natural Gas Operations
• RP 70I Security for Worldwide Offshore Oil and Natural Gas Operations
• RP 76 Contractor Safety Management for Oil and Gas Drilling and Production Operations
• RP 500 Classification of Locations for Electrical Installations at Petroleum Facilities
• RP 505 Recommended Practice for Classification of Locations for Electrical Installations at Petroleum Facilities Classified as Class I, Zone 0, Zone 1 and Zone 2
• RP T-1 Orientation Program for Personnel Going Offshore for the First Time
• RP T-2 Qualification Programs for Offshore Production Personnel Who Work With Anti-Pollution Safety Devices
• RP T-4 Training of Offshore Personnel in Non-Operating Emergencies
• RP T-6 Training and Qualifications of Personnel in Well Control Equipment and Techniques for Completion and Workover Operations on Offshore Locations
• RP T-7 Training of Personnel in Rescue of Persons in Water
• Spec 2C Offshore Cranes
• Spec 4F Drilling and Well Servicing Structures
• Std 1104 Welding of Pipelines and Related Facilities

API RP 75 also refers to the following ASME (American Society of Mechanical Engineers) standards: 

• Boiler and Pressure Vessel Code
• F1166-95 Human Engineering Design for Marine

Program Elements

API RP 75 recommends that a SEMP be organized into the program elements listed below. For some of the elements one or more reference links are provided to sources of further information on that topic.

Safety and Environmental Information

The management program should require that a compilation of safety and environmental information be developed and maintained for any facility subject to this recommended practice. This information will provide the basis for implementing succeeding program elements.

Hazards Analysis

The management program should require that a hazards analysis be performed for any facility subject to this recommended practice. The purpose of this analysis is to identify, evaluate, and, where unacceptable, reduce the likelihood and/or minimize the consequences of uncontrolled releases and other safety or environmental incidents. Human factors should be considered in this analysis.

reference (PHA)
reference (HAZOP)

Management of Change

The management program should establish procedures to identify and control hazards associated with change and maintain the accuracy of safety information.
reference

Operating Procedures

The management program should include requirements for written facility operating procedures designed to enhance efficient, safe, and environmentally sound operations.
reference

Safe Work Practices

The management program should include requirements for written facility operating procedures designed to enhance efficient, safe, and environmentally sound operations.

Training

The management program should establish and implement training programs so that all personnel are trained to work safely and are aware of environmental considerations offshore, in accordance with their duties and responsibilities.

Assurance of Quality and Mechanical Integrity

The management program should require that procedures are in place and implemented so that critical equipment for any facility subject to this recommended practice is designed, fabricated, installed, tested, inspected, monitored, and maintained in a manner consistent with appropriate service requirements, manufacturer’s recommendations, or industry standards. Contractors should have programs in place to address their own critical equipment. Human factors should be considered.

Pre-Startup Review

The management program should require that the commissioning process include a pre-startup safety and environmental review for new and significantly modified facilities that are subject to this recommended practice.
reference

Emergency Response and Control

The management program should require that emergency response and control plans are in place and are ready for immediate implementation.
reference

Investigation of Incidents

The management program should establish procedures for investigation of all incidents with serious safety or environmental consequences. The program should also require investigation of incidents that are determined by facility management to have possessed the potential for serious safety or environmental consequences.

reference

Audit of Safety and Environmental Management Elements

The operators (and contractors with 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.

Records and Documentation

A documentation system for the safety and environmental management program should be established to ensure that records and documents are maintained in a manner sufficient to implement the management system.