Implementation Survey Summary for API RP75 -- Production Years: 1994-1998

United States Department of the Interior

Content: Doug Slitor

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Implementation Survey Summary for API RP75

Production Years: 1994-1998

Background
The MMS announced in 1994 that API’s RP75 generally reflected its view of what a Safety and Environmental Management Program (SEMP) should contain. The MMS collaborated with the API, IPAA, and OOC for the next five years to survey if, and to what extent, OCS operators had voluntarily implemented RP75. At the end of each calendar year, identical surveys were sent to every OCS operator having production during that year. Operators were asked to gauge on a six-point scale (see Table) the degree to which they had implemented each element of RP75. The response from operators is reported to a third party and kept confidential from both MMS and other operators to encourage honest reporting. Aggregate results from the five surveys conducted to date are captured on the attached table.

Summary
The API Implementation Surveys show a clear willingness by nearly all OCS operators to report on their SEMP. In the current survey 87% of all OCS operators responded to the survey (representing over 97% of all OCS oil and gas production). As expected, each subsequent survey has shown growth in the level of overall RP75 implementation. Each year the surveys have confirmed that the larger (higher volume producers) operators are further along in RP75 implementation (based on the production-weighted responses). After growing for several years, however, the gap in implementation between the larger and smaller operators began to narrow in 1997. It should be noted that though the pool of larger OCS operators remains fairly constant from year to year, there is substantial turnover in the smaller operator category.

Some specific observations drawn from the attached RP75 Implementation Survey Summary and related experience are:

Improvement was again seen in all RP-75 elements representing an overall average score improvement of 7% over 1997 figures based on production and 7% based on population. This is the fourth straight year that improvement has been seen in RP-75 implementation since the survey was first conducted in 1994, indicating continuous improvement in the implementation of Safety and Environmental Management Programs;

Greatest improvements in implementation status based on the total population of respondents were seen in the following areas:

Hazards Analysis (+11%)

Operating Procedures (+11%)

Pre-startup Review (+9%)

Management of Change (+8%)

Greatest improvements in implementation status based on production-weighted responses were seen in the follow areas:

Operating Procedures (+14%)

Pre-startup Review (+11%)

Audit of Safety and Environmental Management Program Elements (+10%)

Safe Work Practices(+9%)

	The area of Audit of Safety and Environmental Management Program Elements (4.1) remains the lowest level of implementation among the OCS population; however, this area continues to show high levels of improvement each year. This area is typically the last element of a management program to be implemented;
	The areas of Operating Procedures and Hazards Analysis (4.8) have the lowest level of implementation among OCS operators weighted by production.

API RP75 Implementation Surveys
	1994	1995	1996	1997	1998
OCS Operators Participating	80%	95%	96%	93%	86.8%
OCS Production Covered	94%	99.8%	99.9%	99.2%	97.5%

*Av. Population Score - No Weighting**	3.2	3.6	3.9	4.3	4.6
*Av. Production Score - Weighted**	3.7	4.3	4.7	4.9	5.2

RP75 Section: Pop./Prod. Score*
1 - General Mgmt. Program/Principles	3.7/4.5	4.1/5.0	4.2/5.3	4.7/5.5	5.0/5.6
2 - Safety/Environmental Information	3.5/3.9	3.7/4.2	4.2/4.6	4.5/5.0	4.8/5.2
3 - Hazards Analysis	2.7/3.1	3.2/3.9	3.6/4.3	3.9/4.4	4.3/4.8
4 - Management of Change	3.0/3.6	3.5/4.2	3.8/4.4	4.2/4.9	4.5/5.1
5 - Operating Procedures	2.7/3.3	3.3/3.8	3.5/4.0	3.9/4.2	4.3/4.8
6 - Safe Work Practices	3.4/4.2	3.9/4.6	4.1/5.0	4.4/5.1	4.7/5.5
7 - Training	3.4/3.9	3.8/4.4	3.9/4.7	4.3/5.1	4.6/5.4
8 - Quality Assurance / Integrity	3.1/3.6	3.4/4.1	3.8/4.7	4.1/4.9	4.3/5.2
9 - Pre-startup Review	2.8/3.2	3.4/4.0	3.7/4.5	4.1/4.7	4.5/5.2
10 - Emergency Response/Control	4.2/4.4	4.6/5.2	4.7/5.5	5.1/5.7	5.3/5.8
11 - Incident Investigation	3.1/3.7	3.8/4.5	3.9/4.8	4.5/5.2	4.7/5.4
12 - SEMP Elements Audit	2.7/3.4	3.1/4.2	3.4/4.5	3.8/4.5	4.1/5.0

*Key to Scoring: 1 - No action taken to date; 2 - Evaluating existing company practices against RP75 3 - Developing program to implement RP75			4 - Implementing RP75 5 - RP75 generally in place 6 - Reassessing RP75 implementation for continuous improvement

RP75 Element Implementation Status
Implementation (1- 6)	By Population	By Production
3.8
3.9
4.0	Audit of SEMP Elements
4.1
4.2
4.3	Quality Assurance & Mechanical Integrity
4.4	Hazards Analysis / Operating Procedures
4.5	Management of Change / Training / Pre-Startup Review
4.6
4.7	Safe Work Practices / Incident Investigation	Hazards Analysis
4.8	Safety and Environmental Information	Operating Procedures
4.9	General Management Program Elements and Principles	Audit of SEMP Elements
5.0
5.1		Management of Change / Safety and Environmental Information
5.2	Emergency Response and Control	Pre-Startup Review / Quality Assurance & Mechanical Integrity
5.3		Training
5.4		Incident Investigation
5.5		Safe Work Practices
5.6		General Management Program Elements and Principles
5.7		Emergency Response and Control
5.8
5.9
Note: Shading indicates those sections with below average level of implementation for that group.

Last Updated: 08/08/2008, 02:06 PM