During the 1990’s the MMS has been reworking its approach to regulating the exploration for, and development of, the oil and gas resources of the U.S. OCS. Previously, the MMS had worked to foster application of the best available technologies in these activities through use of consensus industry standards. These standards were supplemented in the MMS regulations with prescriptive directives where the Agency determined they were inconsistent with, or lacked, its regulatory objectives. This approach worked relatively well and the offshore industry took great strides in making energy resources available to the U.S. in a safe and environmentally responsible manner. Despite the strides made by the offshore industry in developing and applying technological solutions, the continued risks posed by this industrial activity to both humans and the environment argued for a new approach. It became increasingly apparent that future gains in the safety and environmental arenas needed to come from concentrating more closely on the human and organizational elements in offshore operations and their contributions to accidents. Research in this area has indicated that as much as eighty percent of all accidents can be attributed in some way to human error or organizational shortcomings. In 1990, both the MMS and the Marine Board of the National Academy of Sciences undertook separate but related studies of one of the MMS’ main lines of defense against injury or pollution: the OCS Inspection Program. The results of both studies indicated that over reliance on inspection and enforcement tools was inadvertently fostering a compliance mentality among many OCS operators. This focus on compliance, though still important, was obscuring the operators’ responsibility to target and manage their performance to exceed the minimum thresholds established by regulation. Out of these studies sprung the MMS Safety and Environmental Management Program (SEMP). The SEMP program was the Agency’s first application of a safety management system approach on the OCS. Shortly after the MMS introduced its SEMP concept in the Federal Register (1991), the offshore industry requested that it be given a chance to develop and implement a consensus industry standard in cooperation with the Agency. Their request led to the development of API’s Recommended Practice for Development of a Safety and Environmental Management Program for Outer Continental Shelf (OCS) Operations and Facilities (RP 75). A companion standard, Recommended Practice for Design and Hazards Analysis for Offshore Production Facilities (RP 14J), was also developed by the API and MMS. The MMS publicly recognized RP 75 and joined forces with the API, the Independent Petroleum Association of America (IPAA), the Offshore Operators Committee (OOC), and other industry leaders to promote voluntary adoption of RP 75. Any management system built upon a standard such as RP 75 must reflect the unique structure and business practices of each company that adopts it. Therefore, the MMS felt that it should provide the opportunity for OCS operators to customize their SEMP plans and implement them on a voluntary basis. Four annual SEMP implementation surveys conducted by the API, IPAA, OOC, and MMS have indicated that the vast majority of OCS operators have developed SEMP plans and are in various stages of implementing them in their offshore activities. At the beginning of 1998, for example, this annual survey showed that the SEMP plans of larger oil and gas producers were generally in place. Smaller producers, on the whole, are in the process of implementing their SEMP plans.
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