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Recommended Practice for

Development of a Safety and


Environmental Management
Program for Outer Continental Shelf
(OCS) Operations and Facilities

API RECOMMENDED PRACTICE 75


SECOND EDITION, JULY 1998

COPYRIGHT 2000 American Petroleum Institute


Information Handling Services, 2000
API ENVIRONMENTAL, HEALTH AND SAFETY MISSION
AND GUIDING PRINCIPLES
The members of the American Petroleum Institute are dedicated to continuous efforts to
improve the compatibility of our operations with the environment while economically
developing energy resources and supplying high quality products and services to consum-
ers. We recognize our responsibility to work with the public, the government, and others to
develop and to use natural resources in an environmentally sound manner while protecting
the health and safety of our employees and the public. To meet these responsibilities, API
members pledge to manage our businesses according to the following principles using
sound science to prioritize risks and to implement cost-effective management practices:

● To recognize and to respond to community concerns about our raw materials, prod-
ucts and operations.
● To operate our plants and facilities, and to handle our raw materials and products in a
manner that protects the environment, and the safety and health of our employees
and the public.
● To make safety, health and environmental considerations a priority in our planning,
and our development of new products and processes.
● To advise promptly, appropriate ofÞcials, employees, customers and the public of
information on signiÞcant industry-related safety, health and environmental hazards,
and to recommend protective measures.
● To counsel customers, transporters and others in the safe use, transportation and dis-
posal of our raw materials, products and waste materials.
● To economically develop and produce natural resources and to conserve those
resources by using energy efÞciently.
● To extend knowledge by conducting or supporting research on the safety, health and
environmental effects of our raw materials, products, processes and waste materials.
● To commit to reduce overall emissions and waste generation.
● To work with others to resolve problems created by handling and disposal of hazard-
ous substances from our operations.
● To participate with government and others in creating responsible laws, regulations
and standards to safeguard the community, workplace and environment.
● To promote these principles and practices by sharing experiences and offering assis-
tance to others who produce, handle, use, transport or dispose of similar raw materi-
als, petroleum products and wastes.

COPYRIGHT 2000 American Petroleum Institute


Information Handling Services, 2000
Recommended Practice for
Development of a Safety and
Environmental Management
Program for Outer Continental Shelf
(OCS) Operations and Facilities
Exploration and Production Department

API RECOMMENDED PRACTICE 75


SECOND EDITION, JULY 1998

COPYRIGHT 2000 American Petroleum Institute


Information Handling Services, 2000
SPECIAL NOTES

API publications necessarily address problems of a general nature. With respect to partic-
ular circumstances, local, state, and federal laws and regulations should be reviewed.
API is not undertaking to meet the duties of employers, manufacturers, or suppliers to
warn and properly train and equip their employees, and others exposed, concerning health
and safety risks and precautions, nor undertaking their obligations under local, state, or fed-
eral laws.
Information concerning safety and health risks and proper precautions with respect to par-
ticular materials and conditions should be obtained from the employer, the manufacturer or
supplier of that material, or the material safety data sheet.
Nothing contained in any API publication is to be construed as granting any right, by
implication or otherwise, for the manufacture, sale, or use of any method, apparatus, or prod-
uct covered by letters patent. Neither should anything contained in the publication be con-
strued as insuring anyone against liability for infringement of letters patent.
Generally, API standards are reviewed and revised, reafÞrmed, or withdrawn at least every
Þve years. Sometimes a one-time extension of up to two years will be added to this review
cycle. This publication will no longer be in effect Þve years after its publication date as an
operative API standard or, where an extension has been granted, upon republication. Status
of the publication can be ascertained from the API Authoring Department [telephone (202)
682-8000]. A catalog of API publications and materials is published annually and updated
quarterly by API, 1220 L Street, N.W., Washington, D.C. 20005.
This document was produced under API standardization procedures that ensure appropri-
ate notiÞcation and participation in the developmental process and is designated as an API
standard. Questions concerning the interpretation of the content of this standard or com-
ments and questions concerning the procedures under which this standard was developed
should be directed in writing to the director of the Authoring Department (shown on the title
page of this document), American Petroleum Institute, 1220 L Street, N.W., Washington,
D.C. 20005. Requests for permission to reproduce or translate all or any part of the material
published herein should also be addressed to the director.
API standards are published to facilitate the broad availability of proven, sound engineer-
ing and operating practices. These standards are not intended to obviate the need for apply-
ing sound engineering judgment regarding when and where these standards should be
utilized. The formulation and publication of API standards is not intended in any way to
inhibit anyone from using any other practices.
Any manufacturer marking equipment or materials in conformance with the marking
requirements of an API standard is solely responsible for complying with all the applicable
requirements of that standard. API does not represent, warrant, or guarantee that such prod-
ucts do in fact conform to the applicable API standard.

All rights reserved. No part of this work may be reproduced, stored in a retrieval system, or
transmitted by any means, electronic, mechanical, photocopying, recording, or otherwise,
without prior written permission from the publisher. Contact the Publisher,
API Publishing Services, 1220 L Street, N.W., Washington, D.C. 20005.
Copyright © 1998 American Petroleum Institute

COPYRIGHT 2000 American Petroleum Institute


Information Handling Services, 2000
FOREWORD

API publications may be used by anyone desiring to do so. Every effort has been made by
the Institute to assure the accuracy and reliability of the data contained in them; however, the
Institute makes no representation, warranty, or guarantee in connection with this publication
and hereby expressly disclaims any liability or responsibility for loss or damage resulting
from its use or for the violation of any federal, state, or municipal regulation with which this
publication may conßict.
Suggested revisions are invited and should be submitted to the Director of the Exploration
and Production Department, American Petroleum Institute, 1220 L Street, N.W., Washing-
ton, D.C. 20005.

iii

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Information Handling Services, 2000
COPYRIGHT 2000 American Petroleum Institute
Information Handling Services, 2000
CONTENTS

Page

1 GENERAL. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.1 Purpose and Objective . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.2 Management Program Elements And Principles . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.3 Scope. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1.4 DeÞnitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
1.5 Standards, Regulations, And References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

2 SAFETY AND ENVIRONMENTAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . 3


2.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2.2 Process Design Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2.3 Mechanical and Facilities Design Information . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

3 HAZARDS ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.1 Application . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.2 Methodology. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.3 Initial Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.4 Periodic Analyses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.5 Analysis Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.6 Analysis Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

4 MANAGEMENT OF CHANGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
4.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
4.2 Change In Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
4.3 Change In Personnel. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
4.4 Managing the Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

5 OPERATING PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
5.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
5.2 Content Of Operating Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
5.3 Periodic Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

6 SAFE WORK PRACTICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9


6.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
6.2 Safe Conduct of Work Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
6.3 Control of Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
6.4 Contractor Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

7 TRAINING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
7.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
7.2 Initial Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
7.3 Periodic Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
7.4 Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
7.5 Contractor Training. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

8 ASSURANCE OF QUALITY AND MECHANICAL INTEGRITY OF


CRITICAL EQUIPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
8.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
8.2 Procurement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
8.3 Fabrication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

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CONTENTS

Page

8.4 Installation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
8.5 Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
8.6 Testing And Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

9 PRE-STARTUP REVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
9.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

10 EMERGENCY RESPONSE AND CONTROL. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14


10.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
10.2 Emergency Action Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
10.3 Emergency Control Center . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
10.4 Training And Drills. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

11 INVESTIGATION OF INCIDENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
11.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
11.2 Investigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
11.3 Follow-up . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

12 AUDIT OF SAFETY AND ENVIRONMENTAL MANAGEMENT PROGRAM


ELEMENTS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
12.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
12.2 Audit Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

APPENDIX A CONTRACTOR SELECTION CRITERIA. . . . . . . . . . . . . . . . . . . . 17


APPENDIX B INDUSTRY CODES, PRACTICES, AND STANDARDS . . . . . . . . 19
APPENDIX C GOVERNMENT CONVENTIONS, CODES, RULES, AND
REGULATIONS AND GUIDELINES . . . . . . . . . . . . . . . . . . . . . . . 21
APPENDIX D REFERENCES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
APPENDIX E DEFINITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

vi

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Recommended Practice for Development of a Safety and Environmental
Management Program for Outer Continental Shelf (OCS) Operations and Facilities

1 General c. Management of change (Section 4).


d. Operating procedures (Section 5).
1.1 PURPOSE AND OBJECTIVE
e. Safe work practices (Section 6).
This recommended practice is intended to assist in devel- f. Training (Section 7).
opment of a management program designed to promote g. Assurance of quality and mechanical integrity of critical
safety and environmental protection during the performance equipment (Section 8).
of oil and gas and sulphur operations on the Outer Continen- h. Pre-startup review (Section 9).
tal Shelf (OCS). This recommended practice addresses the i. Emergency response and control (Section 10).
identiÞcation and management of safety and environmental j. Investigation of incidents (Section 11).
hazards in design, construction, start-up, operation, inspec- k. Audit of safety and environmental management program
tion, and maintenance, of new, existing, or modiÞed drilling elements (Section 12).
and production facilities. The objective of this recommended
practice is to form the basis for a Safety and Environmental 1.2.2 Principles
Management Program (SEMP).
Management (owner and operator) should require that the This recommended practice is based on the following
program elements discussed in Sections 1 through 12 of this principles:
publication are properly documented and available at Þeld a. Management is responsible for the overall success of the
and/or ofÞce locations, as appropriate for each program ele- safety and environmental management program. Manage-
ment. It is recommended that each operator have a safety and ment provides leadership in establishing goals and
environmental management program for their operations. The performance measures, demands accountability for imple-
owner(s) should support the operator's SEMP. mentation, and provides necessary resources for carrying out
The offshore oil and gas industry uses a wide variety of an effective program.
contractors to assist in drilling, production, and construction b. Management has developed and endorsed a written
activities. Contractors typically are in one of the following description of the company's safety and environmental poli-
categories, but this is not an exhaustive list: drilling, work- cies and organizational structure that deÞne responsibilities,
over, well servicing, construction, electrical, mechanical, div- authorities, and lines of communication required to imple-
ing, boat and helicopter transportation, painting, operating, ment the management program.
and catering/janitorial. Operators expect contractors to pro-
c. Management utilizes the expertise of personnel in identi-
vide safe and reliable equipment as well as trained employees
fying hazards, optimizing operations, developing safe work
who are familiar with offshore oil and gas operations.
practices, and investigating incidents.
This recommended practice does not require contractors to
d. Owner, operator, and contractor management each have
develop a SEMP. However, contractors with signiÞcant oper-
their own responsibility to protect the environment and safety
ations and/or contractor-owned facilities (MODU, derrick
and health of their work forces.
barge, lift boat, etc.) may want to develop a complete SEMP.
e. The facilities are designed, constructed, maintained, moni-
Contractors with few operations and/or contractor-owned
tored, and operated in a manner compatible with applicable
facilities may want to develop safety and environmental poli-
industry codes, consensus standards, regulations, and gener-
cies and practices addressing elements of this recommended
ally accepted practice.
practice that are appropriate to the contractorÕs activities. In
all cases, contractors should have policies and practices in f. Management of safety and environmental hazards is an
place that are consistent with the operatorÕs SEMP. integral part of the design, construction, maintenance, opera-
tion, and monitoring of a facility.
1.2 MANAGEMENT PROGRAM ELEMENTS AND g. Suitably trained and qualiÞed personnel are employed to
PRINCIPLES carry out all aspects of the safety and environmental manage-
ment program.
1.2.1 Management Program Elements h. The management programs described herein are main-
tained and kept up to date by means of periodic audits to
The program elements described herein address the follow-
ensure effective performance.
ing 11 areas:
i. Process safety and environmental management enhances
a. Safety and environmental information (Section 2). operational performance, protection of personnel and prop-
b. Hazards analysis (Section 3). erty, and protection of the environment by reducing the
1

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2 API RECOMMENDED PRACTICE 75

probability and/or severity of uncontrolled releases and other c. Ammonia storage and refrigeration facilities.
undesirable events.
1.3.1.3 Due to their thermal, physical, or chemical proper-
j. Human factors are considered in the design and imple-
ties, other materials handled in offshore operations may con-
mentation of the companyÕs Safety and Environmental
stitute a safety or environmental hazard if released in an
Management Program.
uncontrolled manner. Such substances include steam, hot
water, certain chemicals, heat transfer ßuids, molten sulphur,
1.3 SCOPE
and naturally occurring radioactive material (NORM).
1.3.1 Applications
1.4 DEFINITIONS (SEE APPENDIX E)
1.3.1.1 This recommended practice is intended for applica-
tion to oil, gas, and sulphur facilities in the OCS and to asso- 1.5 STANDARDS, REGULATIONS, AND
ciated equipment handling ÒtoxicsÓ, ÒßammablesÓ, and REFERENCES
Òother materialsÓ described in Pars. 1.3.1.2 and 1.3.1.3. This
includes well drilling, servicing, production, and pipeline 1.5.1 Industry Codes, Practices, and Standards
facilities and operations that have the potential for creating a
safety or environmental hazard. The elements of these recom- Codes, practices and standards, useful in the design, fabri-
mended practices should be applied to these facilities, as cation, installation, layout, operation, inspection, testing, and
appropriate. For simple and nearly identical facilities (such as maintenance of facilities are listed in Appendix B. These ref-
well jackets and single well caissons), certain elements of the erences are not to be considered a part of this recommended
safety and environmental management program, as applica- practice except for those speciÞc sections of documents refer-
ble, need be addressed only once, after verifying that site spe- enced elsewhere in this recommended practice.
ciÞc deviations have been evaluated.
Operations that are not within the scope of this recom- 1.5.2 Government Codes, Rules, Conventions,
mended practice include facilities and pipeline operations and Regulations
regulated by the U.S. Department of Transportation Research
Federal regulatory agencies have established certain
and Special Programs Administration, except to the extent the
requirements for the design, fabrication, installation, layout,
operation or changes in the operation of such facilities or
and operation of facilities. These requirements may inßuence
pipelines may be expected to impact safety or environmental
the design, fabrication, installation, layout, testing, inspec-
protection on facilities subject to this recommended practice.
tion, maintenance, and operation of facilities. In addition to
When actions are taken in accordance with this recommended
federal regulations, certain state, municipal, and local regula-
practice, such actions should conform to the most current
tions, and conventions may be applicable.
requirements of applicable federal, state, local regulations, or
The documents in Appendix C may pertain to offshore
ßag State requirements.
operations and should be used when applicable. Additional
It is recognized that some safety and environmental man-
regulations exist that impact and control environmental qual-
agement systems may have been developed using guidelines
ity. These regulations can change frequently and should be
of other organizations which may be more appropriate for
monitored as part of the management program. Environmen-
certain applications (e.g., the International Maritime Organi-
tal management relies on compliance with these regulations
zationÕs (IMO) International Safety Management (ISM) Code
and understanding of the substances that are present in the
for vessel operations). In assessing these systems against this
process and associated discharge streams.
recommended practice the focus should be on assuring the
necessary program elements are addressed, not the format or
1.5.3 References
order of the system documentation.
Numerous textbooks, references, and technical articles
1.3.1.2 Toxic substances sometimes handled in OCS oper-
have been written on the design, fabrication, installation, lay-
ations include hydrogen sulÞde (H2S), chlorine (Cl2), and
out, and safety analysis of offshore production facilities. A
ammonia (NH3). The following are examples of facilities
partial list of the references that have substantial acceptance
other than oil, gas, and sulphur extraction facilities to which
by industry and governmental bodies are listed in Appendix
this recommended practice also may be applicable:
D. These references are not to be considered a part of this rec-
a. Hydrogen sulÞde and sulphur recovery facilities. ommended practice and are included only as they may pro-
b. Chlorine handling and storage facilities. vide a source of additional information for the reader.

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DEVELOPMENT OF A SAFETY AND ENVIRONMENTAL MANAGEMENT PROGRAM FOR OCS OPERATIONS AND FACILITIES 3

2 Safety and Environmental Information basis of the relief system, description of alarm, shutdown, and
interlock systems, description of well control systems, and
2.1 GENERAL design basis for passive and active Þre protection features and
The management program should require that a compila- systems and emergency evacuation procedures. If applicable,
tion of safety and environmental information be developed information on materials of construction, equipment and pip-
and maintained for any facility subject to this recommended ing speciÞcations, corrosion detection and prevention sys-
practice. This information will provide the basis for imple- tems, and design codes, regulations, and standard practices
menting succeeding program elements. Management should employed may also be included. API RP14J contains guid-
consider the requirements of Section 3, ÒHazards Analysis,Ó ance as to the mechanical design information recommended
in determining the extent and detail of required information. for offshore production facilities.
The information should include documentation on process
2.3.2 The mechanical and facility design for mobile off-
and mechanical design. The individual elements of the infor-
shore units should conform to the applicable requirements of
mation may exist in various forms and locations and should
the ßag State and classiÞcation society. The combination of
be referenced in the compilation. Process, mechanical, and
appropriate and valid ßag State certiÞcates (e.g., International
facilities design information should be retained for the life of
Load Line CertiÞcate, U.S. Coast Guard CertiÞcate of
the facility.
Inspection, IMO MODU code certiÞcate, or International Oil
For simple and nearly identical facilities within the same
Þeld (such as well jackets and single well caissons), a com- Pollution Prevention CertiÞcate) and classiÞcation society
mon compliance documentation package may be compiled, certiÞcates generally provide substantial evidence of con-
except that documentation must reßect site speciÞc deviations formance with these requirements.
from the norm for facilities within the Þeld. 2.3.3 The mechanical and facility design should be consis-
tent with the applicable consensus codes and standards in
2.2 PROCESS DESIGN INFORMATION effect at the time the design was prepared or, in the absence of
2.2.1 The process design information should include, as such codes and standards, recognized and generally accepted
appropriate, a simpliÞed process ßow diagram and acceptable engineering practices. When the mechanical design is not
upper and lower limits, where applicable, for items such as consistent with applicable consensus codes and standards or
temperature, pressure, ßow and composition. Where process when a hazards analysis or other review reveals that existing
design material and energy balances are available, these equipment is designed and is constructed in accordance with
should be included. API RP 14J, Recommended Practice for consensus codes, standards, or practices that are no longer in
Design and Hazards Analysis for Offshore Production Facili- general use, suitability of design for intended use should be
ties (latest edition), contains guidance as to the process design documented.
information required for offshore production facilities.
2.3.4 Where the original mechanical design information no
2.2.2 Where the original process design information no longer exists, suitability of equipment design for intended use
longer exists, information may be developed in conjunc- should be veriÞed and documented. This may be done on the
tion with a hazards analysis in sufÞcient detail to support basis of engineering analysis or documentation of successful
the analysis. prior operating experience.
2.3 MECHANICAL AND FACILITIES DESIGN 2.3.5 Design and installation of new facilities and major
INFORMATION modiÞcations should include consideration of human factors.
2.3.1 The mechanical design information should include, ASTM F1166-95, Standard Practice for Human Engineering
as appropriate, piping and instrument diagrams, electrical Design for Marine Systems, Equipment, and Facilities, is a
area classiÞcations, equipment arrangement drawings, design related resource.

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3 Hazards Analysis essarily in prioritized order) may be considered when estab-


lishing priority ranking for performing hazards analyses:
3.1 APPLICATION
a. Areas with continuous offshore population, such as living
The management program should require that a hazards quarters on major platforms, and platform clusters or
analysis be performed for any facility subject to this recom- complexes.
mended practice. The purpose of this analysis is to identify, b. Inventory and ßow rate of ßammable, toxic, or other mate-
evaluate, and, where unacceptable, reduce the likelihood and/ rials that may constitute a safety or environmental hazard.
or minimize the consequences of uncontrolled releases and
c. Locations involving simultaneous operations such as pro-
other safety or environmental incidents. Human factors
ducing while drilling, or producing while constructing above
should be considered in this analysis.
or below the water line.
d. Facilities that remove natural gas liquids or handle hydro-
3.2 METHODOLOGY
gen sulÞde.
3.2.1 Hazards analysis should take an orderly, systematic e. Facilities with severe operating conditions, such as high
approach, following one or more methodologies such as those pressures, highly corrosive ßuids, or conditions such as
recommended in API RP 14J or References 1 and 2. As a abnormal sand production or high ßow rates that may cause
minimum, hazards analysis requirements for production severe erosion or corrosion.
equipment may be met by ensuring that the facility conforms f. Facilities in proximity to environmentally sensitive areas.
to the requirements of API RP 14C, Recommended Practice
for Analysis, Design, Installation and Testing of Basic Sur- 3.3.2 In performing a hazards analysis on a new or modiÞed
face Safety Systems on Offshore Production Platforms. Man- facility, special consideration should be given to the following:
agement should determine, dependent on risk, whether
a. Previous experience with a similar facility.
additional analysis techniques are warranted. API RP14J
should be consulted for guidance in selecting analysis tech- b. Design circumstances, such as changes in the design team
niques appropriate to the risk of each facility. Locations with or the design itself, after the project is underway.
clusters of structurally interconnected platforms should be c. Unusual facility location, design or conÞguration, equip-
analyzed together. For nearly identical well jackets and single ment arrangement, or emergency response considerations.
well caissons, a single hazard analysis may be applied to all d. Any Þndings that need to be brought to resolution before
such facilities within a Þeld, after verifying that site speciÞc startup or that require immediate attention should be clearly
deviations are addressed. identiÞed.
e. Operating procedures and practices, including simulta-
3.2.2 Hazards Analysis for Mobile Offshore Units neous operations guidelines.

a. For most mobile offshore units a marine hazards analysis


3.4 PERIODIC ANALYSES
is implicit in the ßag State and classiÞcation society certiÞca-
tion process, but may be supplemented by speciÞc Management should establish a program for updating haz-
instructions regarding conditions of operation, e.g., a stability ards analyses to verify that the most recent hazards analysis
letter, loading manual, or MODU Operations Manual. reßects the current process. Hazards analyses should be
b. It may be necessary to perform site-speciÞc hazard analy- reviewed periodically and updated as appropriate, with typi-
ses for certain operations to assure that the mobile offshore cal review intervals ranging between 5 years for high-priority
unit is not exposed to conditions beyond its designed limits. facilities and 10 years for low-priority facilities. The priority
Such analyses will often require an exchange of information factors listed in Paragraph 3.3.1 and changes in the facility
between the operator and the owner of the mobile offshore (refer to Section 4) should be considered in establishing
unit. Examples of information which might be required review frequency.
include results of surveys for seaßoor and seabed obstructions
or interferences, anticipated reservoir pressure and tempera- 3.5 ANALYSIS PERSONNEL
ture, drilling plans, casing plans, and any information
necessary to coordinate and integrate emergency response The hazards analyses should be performed by a person(s)
and control. knowledgeable in engineering, operations, design, process,
safety, environmental, and other specialties as appropriate. At
3.3 INITIAL ANALYSIS least one person should be proÞcient in the hazards analysis
methodologies being employed. If only one person performs
3.3.1 The hazards analyses for existing facilities should be the hazard analysis, that person should not have participated
performed in order of priority. The following factors (not nec- in the original design of or modiÞcations to the facility.

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3.6 ANALYSIS REPORT communication of all identiÞed hazards and follow-up actions
to the appropriate personnel. When resolution before startup is
The management program should require that the Þndings
stipulated, or when immediate action is required, the manage-
of a hazards analysis are presented in a written report. This
ment program should mandate that such action is taken or that
report should describe the hazards that have been identiÞed
the hazardous conditions are otherwise remedied. A complete
and recommended steps to be taken to mitigate them. Qualita-
hazards analysis report, including any updates, should be kept
tive assessments of the severity of the Þndings may be made as
on Þle for the life of the facility.
appropriate. The management program should require the

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4 Management of Change addition of equipment that might contribute to greater pres-


sure relief requirements.
4.1 GENERAL h. Bypass connections around equipment that is normally in
service.
The management program should establish procedures to
i. Operations outside the scope of current written operating
identify and control hazards associated with change and
procedures, including procedures for start-up, normal shut-
maintain the accuracy of safety information. A facility is sub-
down, and emergency shutdown.
ject to continual change to increase efÞciency, improve opera-
j. Changes made in the process or mechanical design or in
bility and safety, accommodate technical innovation, and
operating procedures that result from a hazards analysis per-
implement mechanical improvements. On occasion, tempo-
formed as described in Section 3, ÒHazards Analysis.Ó
rary repairs, connections, bypasses, or other modiÞcations
k. Introduction of new or different process chemicals (for
may be made out of operating necessity. Any of these changes
example, corrosion control agents, anti-foulants, anti-foam
can introduce new hazards or compromise the safeguards
agents).
built into the original design. Care must be taken to under-
l. Change in facilities may include mechanical changes that
stand the process, facility, and personnel safety and environ-
would not necessarily appear on a process and instrument
mental implications of any changes. Two types of change
diagram, including drilling and construction equipment and
should be addressed: change in facilities and change in per-
temporary connections or replaced components that are Ònot
sonnel. Although some changes may be minor with little like-
in kind,Ó such as:
lihood of compromising safety or environmental protection,
1. Replacement equipment or machinery that differs in
all changes have the potential for disruption, injury, or busi-
speciÞcations from the original equipment or previously
ness loss.
approved modiÞcation.
2. Temporary piping, connections, pipe repairs, or hoses.
4.2 CHANGE IN FACILITIES 3. An alternate supply of process materials, catalysts, or
Change in facilities arises whenever the process or reactants, such as temporary tanks or drums located
mechanical design, as described in Section 2, is altered. within the facility.
Change in facilities may also occur as a result of changes in 4. Temporary electrical equipment or utility connections,
produced ßuids, process additives, product speciÞcations, by- other than for emergency situations.
products or waste products, design inventories, instrumenta- 5. Changes to drilling diverter system.
tion and control systems, or materials of construction. Typical 6. Changes to blowout preventers (BOPs).
instances in which change in facilities would likely occur 7. Changes to drilling top drives.
include the following:
4.3 CHANGE IN PERSONNEL
a. Construction of new production or process facilities.
Change in personnel, including contractor personnel, as
b. New facility projects that involve production or process appropriate, occurs whenever there is a change in the organi-
tie-ins to existing facilities, equipment reconÞguration, or zation or in personnel that supervise or operate the facility.
modiÞcation of existing facilities/ equipment. Routine personnel vacancies and replacements, rotation, and
c. ModiÞcation of existing facilities that result in changes to shift or tour changes are addressed in operating procedures,
facility or equipment design, structural support, layout, or safe work practices, and training established in accordance
conÞguration. with Sections 5, 6, 7, and 10 and should not require additional
d. Projects to increase facility throughput or accommodate management of change action.
different produced ßuids. Organization changes, particularly those brought about by
e. SigniÞcant changes in operating conditions, including acquisition or sale of a facility, may necessitate a thorough
pressures, temperatures, ßow rates, or process conditions dif- review of the facilityÕs safety and environmental management
ferent from those in the original process or mechanical program. Upon acquisition or transfer of management control,
design. a screening level review should be conducted and the facility
f. Equipment changes, including the addition of new equip- incorporated into the new organization's safety and environ-
ment or modiÞcations of existing equipment. These can mental management program. It is appropriate to consider the
include changes in alarms, instrumentation, and control factors listed in Par. 3.3.1 when establishing review priorities.
schemes.
4.4 MANAGING THE CHANGES
g. ModiÞcations of the process or equipment that cause
changes in the facility's pressure relief requirements. These The management program should establish and imple-
can include increased process throughput, operation at higher ment written procedures to manage change in facilities and
temperatures or pressures, increased size of equipment, or the personnel. These procedures should be ßexible enough to

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accommodate both major and minor changes. These proce- and on area wide emergency plans (i.e., evacuation or oil
dures should cover the following: spill) should also be reviewed.
a. The process and mechanical design basis for the proposed c. The necessary revisions of the operating procedures, safe
change. work practices, and training program.
b. An analysis of the safety health, and environmental con- d. Communication of the proposed change and the conse-
siderations involved in the proposed change, including, as quences of that change to appropriate personnel. For
appropriate, a hazards analysis. The effects of the proposed signiÞcant changes, training consistent with the guidance in
change on separate but unrelated upstream or downstream Section 7 may be appropriate.
facilities (i.e., structures/platforms, pipelines, process equip- e. The necessary revisions of the safety and environmental
ment, emergency isolation and control systems and information.
equipment, mitigative systems and equipment, accommoda- f. The duration of the change, if temporary.
tions areas, emergency evacuation facilities and equipment) g. Required authorizations to effect the change.

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5 Operating Procedures c. The operating limits resulting from the information speci-
Þed in Section 2 and, where safety and environmental
5.1 GENERAL considerations are present, a description of the following:
The management program should include requirements for 1. The consequences of deviation.
written facility operating procedures designed to enhance 2. The steps required to correct or avoid deviation.
efÞcient, safe, and environmentally sound operations. Within d. Environmental and occupational safety and health consid-
a given company the designs of several offshore facilities may erations, including the following:
differ only in the size and/or number of equipment items 1. The special precautions required to prevent environ-
present. Consequently, standard operating procedures may mental damage and personnel exposure, including
apply to multiple facilities. By their very nature, operating engineering controls and personal protective equipment.
procedures directly address human factors issues associated 2. The control measures to be taken if physical contact or
with the interaction between facilities and personnel. The airborne exposure occurs.
human factors associated with format, content, and intended 3. Any special or unique hazards.
use should be considered to minimize the likelihood of proce- 4. Continuous and periodic discharge of hydrocarbon
dural error. materials, contaminants, or undesired by-products into the
environment are restricted by governmental limitations.
5.2 CONTENT OF OPERATING PROCEDURES These discharge limitations represent the degree of efßu-
ent reduction attainable by application of the best
Written procedures should include the following: practicable control technology. Written guidance should
a. The job title and reporting relationship of the person or be provided for facility operating personnel and contrac-
persons responsible for each of the facility's operating areas. tors governing the disposal of materials within terms of
the applicable permits.
b. Instructions for the sound operation of each facility that
are consistent with the safety and environmental information 5. Special U. S. Department of Interior (Minerals Man-
including, as appropriate: startup, normal operations, tempo- agement Service) lease stipulations.
rary operations, simultaneous operations, emergency
shutdown and isolation, and normal shutdown. 5.3 PERIODIC REVIEW
1. Refer to API RP 14J, Recommended Practice for When changes are made in facilities, operating procedures
Design and Hazards Analysis for Offshore Production should be reviewed as part of the management of change pro-
Facilities (latest edition), for information on startup, nor- cedure described in Section 4. In addition, operating proce-
mal operations, and shutdown of production facilities. dures should be reviewed periodically to verify that they
2. Refer to the MODU Operations Manual developed in reßect current and actual operating practices. The frequency
conformance with ßag State requirements and/or the IMO of the review should correspond to the degree of hazard pre-
MODU Code for information on routine operations and sented. Review of and changes to the procedures should be
operating limits on mobile offshore drilling units. documented and communicated to appropriate personnel.

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6 Safe Work Practices nance, and modiÞcation activities, including simultaneous


operations. SpeciÞcally, safe work practices should cover:
6.1 GENERAL
a. Opening of equipment or piping.
The management program should establish and implement b. Lockout and tagout of electrical and mechanical energy
safe work practices. These practices should be designed to sources.
minimize the risks associated with operating, maintenance, c. Hot work and other work involving ignition sources.
and modiÞcation activities and the handling of materials and d. ConÞned space entry.
substances that could affect safety or the environment. e. Crane operations.
Human factors should be considered in the development of A work authorization system should be implemented for
safe work practices. These safe work practices will normally tasks involving items a, b, c, or d. This system should include
apply to multiple locations and will normally be in written provisions for adequate communication of work activities,
form (safety manual, safety standards, work rules, etc.). For including unÞnished work, to shift change and replacement
some locations, site speciÞc work practices may be appropri- personnel. Contractors should be included in these communi-
ate. The program should provide guidelines for selection and cations if they will perform the work or may effect or be
performance evaluation of contractors. effected by it.
Safe work practices should meet the most current provi-
Contractors should have their own written safe work prac-
sions of any applicable federal, state, or local regulations or
tices. In some cases contractors may adopt appropriate sec- ßag state requirements. Some safe work practices that should
tions of the operatorÕs safety and environmental management be addressed can be found in Appendix B.
program. Regardless, an operator and contractor should agree
on appropriate contractorÕs safety and environmental policies 6.3 CONTROL OF MATERIALS
and practices before the contractor begins work at the opera-
torÕs facilities. As an example, for routine contractor services, Materials speciÞcations, inventories, separation, con-
agreement could be reached at the operatorÕs on-site safety Þnement, and handling of toxic or hazardous materials that
meeting. For non-routine and complex contractor services a can affect safety and environmental protection should be
more rigorous and structured operatorÕs review of the con- determined, documented, and communicated to appropri-
ate personnel.
tractorÕs safety and environmental policies and practices may
be warranted. Additionally, where a contractor works at sev-
6.4 CONTRACTOR SELECTION
eral operatorÕs facilities, a single safety and environmental
policies and practices review by that operator may be accept- When selecting contractors, operators should obtain and
able instead of a review at each facility where the contractor evaluate information regarding a contractorÕs safety and envi-
performs work. ronmental management policies and practices, and perfor-
mance thereunder, and the contractorÕs procedures for
6.2 SAFE CONDUCT OF WORK ACTIVITIES selecting subcontractors. (Refer to Par. 1.2.2.d, Par. 7.5,
Appendix A, and API RP 2220, Improving Owner and Con-
Safe work practices for all personnel, including contrac- tractor Safety Performance (latest edition), for examples of the
tors, should provide for the safe conduct of operating, mainte- type of information that should be obtained and evaluated.)

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7 Training Safety Devices (latest edition), and 30 CFR 250, Subpart O


(latest revision) for those who maintain and test safety valves
7.1 GENERAL and controls.
The management program should establish and implement b. Crane operation and maintenance training per API RP 2D,
training programs so that all personnel are trained to work Recommended Practice for Operation and Maintenance of
safely and are aware of environmental considerations off- Offshore Cranes (latest edition), and 30 CFR 250.20(c) for
shore, in accordance with their duties and responsibilities. those who operate platform cranes.
Training should address the operating procedures described c. Well control training per API RP T6, Recommended Prac-
in Section 5, the safe work practices recommended in Section tice for Training and QualiÞcation of Personnel in Well
6, and the emergency response and control measures recom- Control Equipment and Techniques for Completion and
mended in Section 10. Any change in facilities that requires Workover Operations on Offshore Locations (latest edition),
new or modiÞcation of existing operating procedures per Sec- API RP 59, Recommended Practices for Well Control Opera-
tion 5 may require training for the safe implementation of tions (latest edition), and 30 CFR 250, Subparts D, E, F, H
those procedures. Training should be provided by qualiÞed and O for drilling, completion, and workover personnel; safe
instructors and documented. drilling of wells containing hydrogen sulÞde per API RP 49,
Recommended Practices for Drilling and Drill Stem Testing
7.2 INITIAL TRAINING of Wells Containing Hydrogen SulÞde (latest edition), and 30
CFR 250, Subpart D, if well target is to or through horizons
7.2.1 Due to the nature of offshore operations, certain
suspected of containing hydrogen sulÞde; production opera-
training elements should be provided for the basic well-being
tions where hydrogen sulÞde is known to be present per API
of personnel and protection of the environment. Some exam-
RP 55, Recommended Practices for Oil and Gas Producing
ples of appropriate training are:
and Gas Processing Plant Operations Involving Hydrogen
a. All personnel should receive orientation training per API SulÞde (latest edition), and 30 CFR 250, Subpart H (latest
RP T1, Recommended Practice for Orientation Program for edition).
Personnel Going Offshore for the First Time (latest edition), d. Operating and maintenance training may utilize API rec-
before being given transport offshore for the Þrst time. ommended training modules and Þlms, or equivalent, and
b. All personnel regularly assigned offshore should receive should be reinforced by appropriate demonstrations and
training in non-operating emergencies per API RP T4, Rec- Òhands-onÓ training. Reinforcement through on-the-job train-
ommended Practice for Training of Offshore Personnel in ing is permissible if under the supervision of a knowledgeable
Non-Operating Emergencies (latest edition), rescue of per- operating/maintenance person of proven performance.
sons in the water per API RP T7, Recommended Practice for e. If hydrogen sulÞde is present at levels that require training,
Training of Personnel in Rescue of Persons in Water (latest appropriate training is required for all personnel, including
edition), and Þre Þghting per API RP 14G, Recommended visitors.
Practice for Fire Prevention and Control on Open Type Off- f. All regularly assigned personnel should be trained in envi-
shore Production Platforms. ronmental protection and pollution control as per applicable
c. Appropriate personnel, regularly or occasionally assigned portions of 30 CFR 250, Subpart C.
as required by the circumstances, should be trained for safe
work practices (e.g., hot work, hot tapping, safe entry, lock- 7.3 PERIODIC TRAINING
out/tagout), simultaneous operations planning, and hazards
communication. Refresher training should be provided to maintain under-
d. All regularly assigned personnel should be trained as standing of and adherence to the current operating proce-
appropriate in Þre protection, lifesaving and survival instruc- dures. Procedures should be established to verify adequate
tion as per applicable portions of 33 CFR Parts 140-146. retention of the required knowledge and skills.

7.2.2 The management program should require that qualiÞ- 7.4 COMMUNICATION
cation criteria be developed and implemented for operating
and maintenance personnel. Procedures should be developed The management program should require that whenever a
to ensure that persons assigned to operate and maintain the change is made in the procedures recommended in Sections
facility possess the required knowledge and skills to carry out 5, 6, or 10, personnel will be trained in or otherwise informed
their duties and responsibilities, including startup and shut- of the change before they are expected to operate the facility.
down. Some examples of appropriate training are:
7.5 CONTRACTOR TRAINING
a. Safety and anti-pollution device training per API RP T2,
Recommended Practice for QualiÞcation Programs for Off- Contractors should train their personnel in the work prac-
shore Production Personnel Who Work With Anti-Pollution tices necessary to perform their jobs in a safe and environ-

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mentally sound manner. The training provided to contract inßuence operation of the facility, such as, janitorial work,
personnel should include applicable site-speciÞc safety and food and drink services, laundry, delivery, other supply ser-
environmental procedures and rules pertaining to the facility vices, etc.
and the applicable provisions of emergency action plans. This The operator should verify contractor training utilizing a
paragraph applies to contractors performing operating duties, variety of methods, which may include audits of the contrac-
maintenance or repair, turnaround, major renovation, or spe- torÕs environmental, health and safety training programs;
cialty work at the facility. Except for transportation safety ori- work site checks of individual contractor employees training;
entation, emergency evacuation training, and other applicable and operator observation of contractor work performance.
safety and environmental training, this paragraph does not (Refer to Appendix A).
apply to contractors providing incidental services that do not

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8 Assurance of Quality and Mechanical tured to enhance safety and protect the environment.
Integrity of Critical Equipment Maintenance personnel includes both operator and contract
employees involved in maintenance.
8.1 GENERAL
The maintenance program should include the following
The management program should require that procedures provisions:
are in place and implemented so that critical equipment for
a. Procedures and work practices to maintain the mechanical
any facility subject to this recommended practice is designed,
integrity of equipment.
fabricated, installed, tested, inspected, monitored, and main-
tained in a manner consistent with appropriate service b. Training of maintenance personnel in the application of
requirements, manufacturer's recommendations, or industry the procedures, relevant hazards, and safe work practices.
standards. Contractors should have programs in place to c. Quality control procedures to verify that maintenance
address their own critical equipment. materials and spare equipment and parts meet design
Human factors should be considered, particularly regard- speciÞcations.
ing equipment accessibility for operation, maintenance and d. A system to conÞrm that maintenance personnel are
testing. The overall quality assurance strategy to require con- qualiÞed.
formance to speciÞcations/requirements should be developed e. Procedures to review all changes in facilities in accor-
at the beginning of the project and become a part of the over- dance with Section 4.
all project execution plan and maintenance program. The
quality assurance strategy should carry over into the operat- 8.6 TESTING AND INSPECTION
ing and maintenance procedures and management of change. Testing, inspection, and monitoring programs for critical
equipment should be established. Programs may be required
8.2 PROCUREMENT for environmental protection compliance monitoring. The
Written procedures for procurement of critical equipment management plan should document the technologies utilized
should be developed as part of the overall quality and mechan- and measurement systems used for compliance. Such pro-
ical integrity assurance program to verify equipment compli- grams should include the following items:
ance with applicable design and material speciÞcations.
a. A list of critical equipment and systems that are subject to
8.3 FABRICATION inspection and testing. The list should specify the method and
interval of testing and inspection, acceptable limits, and crite-
Where appropriate, written quality control procedures and ria for passing the test or inspection.
speciÞcations for critical equipment should be established b. Testing and inspection procedures that follow commonly
and implemented to conÞrm that materials and construction, accepted standards and codes, such as API 510, Pressure Ves-
during the fabrication stage, are in accordance with the design sel Inspection Code: Maintenance Inspection, Rating, Repair,
speciÞcations. and Alteration (latest edition).
8.4 INSTALLATION c. Documentation of completed testing and inspection. Pres-
sure vessel testing and inspection documentation should be
Appropriate checks and inspection procedures should be retained for the life of the equipment. All other documenta-
established and implemented before startup to verify that the tion should be retained for a minimum of 2 years or as needed
installation of critical equipment is consistent with design to determine any changes that may be needed in frequency of
speciÞcations and the manufacturer's instructions. testing, inspection, and preventive maintenance, or as
required by regulatory agencies or for the preparation or revi-
8.5 MAINTENANCE sion of hazards analyses.
Maintenance programs that include appropriate inspection d. Procedures to document and correct critical equipment
and testing should be established and implemented for critical deÞciencies or operations that are outside acceptable limits.
equipment to sustain ongoing mechanical integrity. Mainte- e. A system for reviewing and authorizing changes in tests
nance activities focused on this equipment should be struc- and inspections.

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9 Pre-startup Review c. Safety and environmental information is current.


d. Hazards analysis recommendations have been considered-
9.1 GENERAL addressed, and implemented as appropriate.
The management program should require that the commis- e. Training of operating personnel has been completed.
sioning process include a pre-startup safety and environmen- f. Programs to address management of change and other ele-
tal review for new and modiÞed facilities that are subject to ments of this publication are in place.
this recommended practice to conÞrm that the following cri- g. Safe work practices are in place.
teria are met: Refer to API RP 14J, Recommended Practice for Design
and Hazards Analysis for Offshore Production Facilities (lat-
a. Construction and equipment are in accordance with est edition), for additional information. Refer to applicable
speciÞcations. standards in Appendix B for mobile offshore units.
b. Safety, environmental, operating, maintenance, and emer-
gency procedures are in place and are adequate.

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14 API RECOMMENDED PRACTICE 75

10 Emergency Response and Control d. MARPOL Annex 1 Reg 23: Shipboard Oil Pollution
Emergency Plan (SOPEP).
10.1 GENERAL
The management program should require that emergency 10.3 EMERGENCY CONTROL CENTER
response and control plans are in place and are ready for An emergency control center should be designated for each
immediate implementation. These plans should be validated facility and have access to the following:
by drills carried out to a schedule deÞned by the management
program. The drills should address the readiness of personnel a. Emergency action plans (refer to Par. 10.2) that address
and their interaction with equipment. events such as:
10.2 EMERGENCY ACTION PLAN 1. Spills of hazardous substances
2. Collisions
Written action plans should be established to assign 3. Fire and/or blowouts
authority to the appropriate qualiÞed person(s) at a facility for
b. Oil spill contingency plan.
initiating effective emergency response and control. These
plans should also address emergency reporting and response c. Safety and environmental information (refer to Section 2).
requirements and comply with the most current provisions of
10.4 TRAINING AND DRILLS
one or more of the following regulations, as applicable (not
an all inclusive listing): Training incorporating emergency response and evacuation
a. 33 CFR 146.140: Emergency Evacuation PlanÑU. S. procedures should be conducted periodically for all personnel
Coast Guard. (including contractorÕs personnel), as required by the man-
b. 30 CFR Parts 250 and 256: Oil, Gas, and Sulphur Opera- agement program. Hypothetical drills based on realistic sce-
tions in the Outer Continental ShelfÑMinerals Management narios should also be conducted periodically to exercise
Service. elements contained in the facility or area emergency action
c. 49 CFR 192 and 195: Pipeline Emergency PlansÑU. S. plan. An analysis and critique of each drill should be con-
Department of Transportation. ducted to identify and correct weaknesses, as appropriate.

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DEVELOPMENT OF A SAFETY AND ENVIRONMENTAL MANAGEMENT PROGRAM FOR OCS OPERATIONS AND FACILITIES 15

11 Investigation of Incidents In appropriate circumstances, consideration should be


given to establishing a Òwork-in-progress privilegeÓ covering
11.1 GENERAL any documents generated during the course of an incident
investigation or to conducting the entire investigation under
The management program should establish procedures for
attorney-client privilege.
investigation of all incidents with serious safety or environ-
mental consequences. The program should also require inves- 11.2 INVESTIGATION
tigation of incidents that are determined by facility
management to have possessed the potential for serious safety The investigation of an incident should address the fol-
or environmental consequences. Incident investigations lowing:
should be initiated as promptly as possible, considering the a. The nature of the incident.
necessity of securing the incident scene and protecting people b. The factors (human or other) that contributed to the initia-
and the environment. tion of the incident and its escalation/control.
The intent of the investigation should be to learn from the c. Recommended changes identiÞed as a result of the
incident and help prevent similar incidents. A corrective investigation.
action program should be established based on the Þndings of
the investigation in order to analyze incidents (e.g., uncon- 11.3 FOLLOW-UP
trolled release or non-compliant pollution incident) for com- 11.3.1 The Þndings of the investigation should be retained
mon root causes. The corrective action program is a follow- for possible use in the next hazard analysis update, company
up system to the incident analysis procedures. The investiga- audits, or for a minimum of 2 years, whichever is greater.
tion should be expedited and Þndings and recommendations
resolved in a timely manner. 11.3.2 Management should establish a system to determine
and document the response to each Þnding to ensure that
The incident investigation should be conducted by person-
agreed-upon actions are completed.
nel designated by the operator. An incident investigation
should be conducted by personnel knowledgeable in the pro- 11.3.3 Companies should implement a system whereby
cess involved, investigation techniques, and other specialties conclusions of investigations are distributed to similar facili-
that are viewed as relevant or necessary. ties and/or appropriate personnel within their organization.

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16 API RECOMMENDED PRACTICE 75

12 Audit of Safety and Environmental This should include a number of facilities sufÞcient to evaluate
Management Program Elements management's commitment to items a, b, and c in Par. 12.1.
During each audit, at least Þfteen percent (15%) of the
12.1 GENERAL Þelds operated, with a minimum of one Þeld, should be
audited. The Þelds included in the audit should not be the
Management should require that the ten elements of the
same as those included in the previous audit. When sufÞcient
management program presented in Sections 2 through 11 are
deÞciencies are identiÞed in the effectiveness of any safety
periodically self-audited. The audit requirements of this sec-
and environmental management program elements, the test
tion should be considered when formatting, distributing, and
sample size shall be expanded for that program element.
Þling the documentation required in the other ten elements of
Contractors which have a SEMP should consider having a
the safety and environmental management program. When
similar testing system to audit mobile offshore units and sig-
selecting Þelds to audit, consideration should be given to
niÞcant contractor-owned facilities.
common features (e.g., Þeld supervisors, regulatory districts,
facility design, systems and equipment, ofÞce management, The audit should be conducted by one or more persons
etc.) to obtain a cross-section of practices for the Þelds oper- knowledgeable in the process involved and other specialties
ated. The scope of the audit should include the following: deemed necessary. Care should be exercised when selecting
the audit team to ensure impartiality. The Þrst audit should be
a. Determine if the management program elements of Sec- accomplished within 2 years of initial implementation of the
tions 2 through 11 are in place. management program. The audit interval for the management
b. Determine if the management program elements incorpo- program should not exceed 4 years.
rate the required components.
12.2 AUDIT REPORTING
c. Testing system to evaluate the effectiveness of the man-
agement program. The system should include a review of The Þndings of the audit should be provided to the man-
documentation, private interviews of various levels and disci- agement personnel responsible for the program. Management
plines of personnel, and facility inspections. should establish a system to determine and document the
The testing system of the audit need not be applied to each appropriate response to the Þndings and to assure satisfactory
facility; rather, interviews and inspections should be con- resolution. The audit report should be retained at least until
ducted at Þelds that differ signiÞcantly (e.g., oil vs. dry gas). the completion of the next audit.

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APPENDIX A—CONTRACTOR SELECTION CRITERIA

A major step in achieving acceptable contractor perfor- e. An outline of the contractor's initial employee safety
mance is selecting a safe and environmentally responsible orientation.
contractor. Therefore, it is appropriate for operators to f. Evidence of the existence of a disciplinary action pro-
request that contractors submit speciÞc performance infor- cedure dealing with safety and environmental related
mation in their contract response proposals. For example, infractions.
such information might include: g. Descriptions of the contractorÕs various safety pro-
grams, including: accident investigation procedures; how
a. A copy of the contractorÕs written safety and environ-
safety inspections are performed; safety meetings; safety
mental policies and practices endorsed by the contractor's
incentive programs; substance abuse prevention programs.
top management.
h. Description of the safety and environmental training
b. A statement of commitment by the contractor to com-
that each contractor employee has received and the con-
ply with all applicable safety and environmental
tractor's programs for refresher training.
regulations and provisions of this publication.
i. Description of the contractorÕs short-service employee
c. OSHA deÞned recordable injury and illness experience
training program including what criteria must be met for
for the previous 3 years.
employees to progress from short-service to regular status.
d. Experience ModiÞcation Rates (EMR) for WorkerÕs
Compensation Insurance for the previous three years.

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APPENDIX B—INDUSTRY CODES, PRACTICES, AND STANDARDS

The most recent editions of the following publications are RP 53 Blowout Prevention Equipment Systems
related to this recommended practice: RP 54 Occupational Safety for Oil and Gas Well
Drilling and Servicing Operations
RP 55 Oil and Gas Production and Gas Process-
API
ing Plant Operations Involving Hydrogen
SulÞde
Bull E2 Management of Naturally Occurring
RP 59 Well Control Operations
Radioactive Materials (NORM) in Oil and
RP 500 ClassiÞcation of Locations for Electrical
Gas Production
Installations at Petroleum Facilities
Publ 510 Pressure Vessel Inspection Code: Mainte-
RP 64 Diverter Systems Equipment and
nance Inspection, Rating, Repair, and
Operations
Alteration
RP 750 Management of Process Hazards
Publ 520 Sizing, Selection, and Installation of Pres-
RP T1 Orientation Program for Personnel Going
sure-Relieving Devices in ReÞneries
Offshore for the First Time
Publ 521 Guide for Pressure-Relieving and Depres-
RP T2 QualiÞcation Programs for Offshore Pro-
suring Systems
duction Personnel Who Work With Anti-
Publ 2004 Inspection for Fire Protection
Pollution Safety Devices
Publ 2007 Safe Maintenance Practices in ReÞneries
RP T4 Training of Offshore Personnel in Non-
Publ 2009 Safe Welding and Cutting Practices in
Operating Emergencies
ReÞneries, Gasoline Plants, a nd P e tro-
chemical Plants RP T6 Training and QualiÞcations of Personnel
in Well Control Equipment and Techniques
Publ 2015 Cleaning Petroleum Storage Tanks
for Completion and Workover Operations
Publ 2201 Procedures for Welding or Hot Tapping on
on Offshore Locations
Equipment Containing Flammables
Publ 2207 Preparing Tank Bottoms for Hot Work RP T7 Training of Personnel in Rescue of Persons
in Water
Publ 2217A Guidelines for Work in Inert ConÞned
Spaces in the Petroleum Industry Spec 2C Offshore Cranes
Publ 2510 Design and Construction of LiqueÞed Spec 4F Drilling and Well Servicing Structures
Petroleum Gas (LPG) Installations Std 1104 Welding of Pipelines and Related Facilities
Publ 2510A Fire-Protection Considerations for the
Design and Operation of LiqueÞed Petro- ASME1
leum Gas (LPG) Storage Facilities Boiler and Pressure Vessel Code
RP 1107 Pipeline Maintenance Welding Practices
RP 2D Operation and Maintenance of Offshore
Cranes ANSI2
RP 2220 Improving Owner and Contractor Safety ANSI B31.3 Chemical Plant and Petroleum ReÞnery
Performance Piping
RP 4G Maintenance and Use of Drilling and Well
Servicing Structures ASTM3
RP 14C Analysis, Design, Installation and Testing F1166-95 Human Engineering Design for Marine
of Basic Surface Safety Systems on Off- Systems, Equipment and Facilities
shore Production Platforms
RP 14E Design and Installation of Offshore Pro-
duction Platform Piping Systems
RP 14F Design and Installation of Electrical Sys-
tems for Offshore Production Platforms
RP 14G Fire Prevention and Control on Open Type
1American Society of Mechanical Engineers, 345 East 47th Street,
Offshore Production Platforms
New York, New York 10017.
RP 14J Design and Hazards Analysis for Offshore 2American National Standards Institute, 11 West 42nd Street, New
Production Facilities York, New York 10036.
RP 49 Drilling and Drill Stem Testing of Wells 3 American Society for Testing and Materials, 100 Barr Harbor
Containing Hydrogen SulÞde Drive, West Conshohocken, Pennsylvania 19428.
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APPENDIX C—GOVERNMENT CONVENTIONS, CODES, RULES, AND
REGULATIONS AND GUIDELINES

MMS4 46 CFR Part 16 Chemical Testing


30 CFR 250, 256 Oil, Gas, and Sulphur Operations in the
Outer Continental Shelf
DOT4
49 CFR Parts
USCG4 192 and195 Pipeline Emergency Plans
33 CFR 146.140 Emergency Evacuation Plans
33 CFR Part 95 Vessel Operating Regulations
33 CFR Part 126 Handling of Explosives or Other Dan IMO5
gerous Cargoes Within or Contiguous International Convention for the Safety of Life at Sea, 1974
to Waterfront Facilities (as amended)
33 CFR International Safety Management Code (ISM Code) (as
Subchapter M Marine Pollution Financial Responsi- amended)
bility and Compensation International Convention for the Prevention of Pollution
33 CFR from Ships, 1973, as modiÞed by the Proto-
Subchapter N Outer Continental Shelf Activities col of 1978 relating thereto (MARPOL 73/
33 CFR 78) (as amended)
Subchapter NN Deepwater Ports Guidelines for the Development of Shipboard Oil Pollution
33 CFR Emergency Plans
Subchapter O Pollution International Conference on Load Lines (with supplements
46 CFR and amendments)
Subchapter A Marine Casualties and Investigation Guidelines for the Design and Construction of Offshore
46 CFR Supply Vessels
Subchapter I-A Mobile Offshore Drilling Units Code for the Construction and Equipment of Mobile Off-
46 CFR shore Drilling Units, 1979 (1979 MODU
Subchapter I Cargo and Miscellaneous Vessels Code) (as amended)
46 CFR Code for the Construction and Equipment of Mobile Off-
Subchapter L Offshore Supply Vessels shore Drilling Units, 1989 (1989 MODU
46 CFR Code) (as amended)
Subchapter V Marine Occupational Safety and Health Code for the Safety of Special Purpose Ships
Standards Code on Alarms and Indicators (as amended)

4Code of Federal Regulations (CFR) publications are available from 5IMO Publications, 4 Albert Embankment, London, England, SE1
the U.S. Printing OfÞce, Washington, DC 20402. 7BP.

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APPENDIX D—REFERENCES

1. Guidelines for Hazard Evaluation Procedures, Center 4. J. P. Zeuwen, C.J.M. van Wingerden, and R.M. Dauwe,
for Chemical Process Safety, American Institute of Chemical ÒExperimental Investigation into the Blast Effect Produced by
Engineers, New York, 1992. UnconÞned Vapor Cloud Explosions,Ó Symposium Series No.
80, Prins Maurits Laboratory TNO, Rijswijk, The Nether-
2. Process Safety Management, Chemical Manufacturers lands, 1985, pp. D20ÐD29.
Association, Washington, DC, 1985.
5. V.C. Marshall, ÒUnconÞned Vapor Cloud Explosions,Ó
3. D.C. Bull and J.A. Martin, ÒExplosion of UnconÞned Chemical Engineering, June 13, 1982, pp. 149Ð154.
Clouds of Natural Gas,Ó Operating Section Proceedings,
American Gas Association, Arlington, Virginia, 1977, pp. 6. C.H. Vervalan, Fire Protection Manual for Hydrocarbon
T-149ÐT-153. Processing Plants, Gulf Publishing, Houston, Texas, 1985.

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APPENDIX E—DEFINITIONS

E.1 contractor: The individual, partnership, Þrm, or cor- E.8 mobile offshore unit: A vessel which can be readily
poration retained by the owner or operator to perform work or relocated to perform an industrial function related to offshore
provide supplies or equipment. The term contractor shall also oil, gas, or sulphur exploration or exploitation. Such vessels
include subcontractors. include mobile offshore drilling units (MODUs), lift boats
and other units involved in construction, maintenance
E.2 critical equipment: Equipment and other systems (including the maintenance of wells) and lifting operations
determined to be essential in preventing the occurrence of or associated with offshore facilities. Mobile offshore units nor-
mitigating the consequences of an uncontrolled release. Such mally do not include vessels such as: supply vessels, standby
equipment may include vessels, machinery, piping, blowout vessels, anchor handling vessels, or seismic survey vessels.
preventers, wellheads and related valving, ßares, alarms,
interlocks, Þre protection equipment and other monitoring, E.9 operator: The individual, partnership, Þrm, or corpo-
control and response systems. ration having control or management of operations on the
leased area or a portion thereof. The operator may be a lessee,
E.3 facility: Wells, structures, living quarters, drilling and designated agent of the lessee(s), or holder of operating rights
workover packages, process equipment, utilities, pipelines, under an approved operating agreement.
and mobile offshore units (except as noted in Par. 1.3.1.1).
E.10 owner: The individual, partnership, Þrm, or corpora-
E.4 flag state: The Government of the nation whose ßag tion to whom the United States issues a lease and has been
a vessel is entitled to ßy. assigned an obligation to make royalty payments required by
the lease.
E.5 hazards analysis: The application of one or more
E.11 process: The systems for production, use, storage,
methodologies that aid in identifying and evaluating hazards.
handling, treatment, or movement of hydrocarbons, sulphur,
Some sources that may be helpful in performing hazards
or toxic substances.
analysis include References 1 and 2 in Appendix D and API
RP 14J, Recommended Practice for Design and Hazards E.12 simultaneous operations: Two or more of the
Analysis for Offshore Production Facilities (latest edition). following activities: production, drilling, completion, work-
over, wireline (except routine operations as deÞned in 30
E.6 human factors: The interaction and application of CFR 250.91), and major construction operations.
scientiÞc knowledge about people, facilities and management
systems to improve their interaction in the work place and E.13 uncontrolled release: An accidental release of
reduce the likelihood and/or consequences of human error. hydrocarbons, toxic substances, or other materials that is
likely to develop quickly, be outside the anticipated range of
E.7 mobile offshore drilling unit (MODU): A vessel normal operations, present only limited opportunity for cor-
capable of engaging in drilling or well workover operations rective action, require any action to be in the nature of an
for the exploration or exploitation of subsea resources (46 emergency response, and could result in serious environmen-
U.S.C. 2101 (15a)). tal or safety consequences.

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