...we are not supportive of the extensive, prescriptive regulations as proposed in this rule. We believe industry's current safety and environmental statistics demonstrate that the voluntary programs implemented since the adoption of API RP 75 have been and continue to be very successful.
The proposed rule prescribes stricter requirements than the approach on which it is based (API Recommended Practice 75, Development of a Safety and Environmental Management Program for Offshore Operations and Facilities, or SEMP), and may generate significant difficulties for operators and contractors to abide by the rule.
This proposed action is a major, paper work intensive, rulemaking that will significantly impact our business, both operationally and financially, and will bring little or no benefit towards improving safety of offshore operations. In addition to the unnecessary burden to industry, it will create an additional unwarranted burden to regional MMS staff that will require additional inspector/auditor training and increased workload demand.