General

Purpose

This document describes the procedures and criteria used by the Minerals Management Service (MMS) to administer the annual SAFE Program.

The SAFE Program recognizes exemplary performance by Outer Continental Shelf (OCS) oil and gas operators and contractors. It also highlights to the public that companies can conduct offshore oil and gas activities safely and in a pollution-free manner, even though such activities are complex and carry a significant element of risk.

Each year, MMS presents the SAFE Award on both District and National levels:

• The Region and District Offices present the District SAFE Award to OCS companies displaying the most exemplary performance on a single platform, rig, field, unit, or throughout an entire District.  District Offices may present SAFE Awards for any of four categories including the outstanding high activity operator, moderate activity operator, production contractor, and drilling contractor.  An outstanding operator and contractor conducting simultaneous operations on one facility may be nominated as two separate candidates in their respective categories. Each district may present up to four SAFE Awards each year.

• The MMS Headquarters Office presents the National SAFE Award to OCS companies displaying the most exemplary performance throughout the nation, taking into consideration a company’s performance in each of their respective OCS districts where operations are held.  The four National SAFE Award categories include the same categories of operator and contractor as identified for the District SAFE Award.

The National SAFE Award does not rely on the District SAFE Award as a candidate source; rather the candidates are selected from the operators displaying the best nationwide performance ratings. However, any District SAFE Award received by a National SAFE Award candidate during the award year will be considered a plus during the National SAFE Award selection process.

During the award year, companies are ineligible for the MMS National SAFE Award when any one of their OCS facilities experiences an operations-related fatality; a pollution spill of significant size and/or environmental significance; or a P-103 Incident of Noncompliance (INC) referred for civil penalty review. Companies that incur one or more of the aforementioned incidents are also ineligible to receive the District SAFE Award in the district where the incident occurred; however, they may still qualify for the award in another district. If a District Supervisor feels there is sufficient reason to mitigate any of these disqualification factors, they must provide the justification in writing.

The MMS recognizes two categories of operators for production activities--High Activity Operator and Moderate Activity Operator. Qualification of operators is based on production levels as expressed in Barrels of Oil Equivalent (BOE) and the number of in-service components, for example, fired vessels, pumps, well bays, pipelines, meters, compressors, and fire fighting systems.  Components inspected and INCs issued by the MMS on behalf of and explicitly for the United States Coast Guard will not be considered in the qualification and rating of operators at this time.

• A company that qualifies under the High Activity category would need to meet the following criteria:

• Produce at least 10 MMBOE per year.

• Operate a minimum of 1,000 in-service components during the year.

• A company that does not qualify for the above category, may qualify for the Moderate Activity category if they meet the following criteria:

•  Produce at least 1 MMBOE per year.

• Operate a minimum of 100 in-service components during the year.

These criteria are a reflection of the amount of activity on the OCS and do not account for land-based activities, international activities, or a company's financial strength.   The complexity of operations may also be considered in selecting among operators with comparable safety and compliance records. 

The MMS currently recognizes two categories of contractors -- Drilling Contractor and Production Contractor.  All eligible contractors (see Award Ineligibility) qualify for consideration under the SAFE program with greater weight given to contractors with higher staffing and activity levels. 

The SAFE Award will be presented, along with the MMS Corporate Leadership and Corporate Citizenship Awards, in April of each year during the MMS Industry Awards Luncheon held in Houston, Texas. 

The nomination letter is the initial recognition of a potential District SAFE Award recipient. The inspector submits this letter to the supervisory team leader, for review and concurrence, who then forwards the letter to the District Supervisor.  At this point, the nominated company becomes an official candidate. The District Supervisor convenes a meeting with the supervisory team leader and the inspectors to review the achievements narrated in the candidate nomination letter. 

The following criteria groupings allow the nominating inspector(s) an opportunity to comment on each performance area and the reasons an operator or contractor should receive the District SAFE Award. The nomination letter must be as explicit as possible for each category.

1. Result of MMS Inspections - Number of inspections, number of components inspected, and number of incidents of noncompliance written against each company during the award year.

2. Record of Events - Number and severity of major accidents, spills, fires, blowouts, explosions, injuries, and fatalities.

3. Operational Considerations - Overall condition of facility, equipment maintenance, and housekeeping; accuracy, completeness, and availability of records; observation of regulatory awareness; knowledge of contingency plan provisions; ability to locate reference documents; and cooperation, attitude, and knowledge of overall operations.

4. Technology - Use of the best available technology to primarily enhance the safety aspects of operations, plus an overall assessment of the training of personnel using this technology and employee’s general knowledge on matters of safety and good operation.

Inspector participation is directly related to the success of the MMS SAFE Program.    Inspector participation, promotion of the program, and management of the candidate selection process is the responsibility of the District Supervisor.  Supervisors also administer the processing of awards and any documentation requested by the Regions.

Examples of documentation for District Awards:

• Initial District SAFEAward Nomination Letter

• Results of a candidate’s District performance review

• District SAFE Award citation

After receiving the District nominations, the Regional Supervisor conducts a review to confirm candidate performance.  Recipients of the District SAFE Award will be notified of their selection and invited to participate in any local ceremonies and the MMS Industry Awards Luncheon for recognition. 

The National Safe Award does not utilize a nomination procedure to identify award candidates as does the District Safe Award process.  Instead, potential SAFE Award candidates at the National level are screened through a two-step process comprised of statistical analysis and in-depth meetings involving MMS Headquarters, Regional, and District personnel to determine a company’s overall performance on the OCS. 

The first step in selecting National SAFE Award candidates is a statistical analysis of a company’s record of INCs for the year as determined through the MMS Inspection program.  Each INC is weighted to reflect the added potential for human injury and/or harm to the environment.   The resulting weighted INC-to-Component ratio or Safety Index compares the safety performance of each company to that of others and to the average OCS company within their respective category thus reducing the field of candidates to a more manageable level. 

The second step for selecting National SAFE Award candidates is the review of a company’s offshore performance by means of correspondence and meetings involving MMS District, Regional, and Headquarters personnel.  Discussions are held to gather information in regard to the same four categories as outlined under the District SAFE Award Process Selection Criteria section thus provide the national SAFE Award Committee (SAC) with a better understanding of a company’s compliance, knowledge of regulations, and attention to safety; operational complexity and challenges; and innovative approaches to existing and future operations.  Only the top candidates who show outstanding performance in each of their respective OCS districts will be considered a finalist for the National SAFE Award. 

Once all candidates have been thoroughly reviewed, the SAC will choose up to five finalists for each of the four categories.  The finalists of the National SAFE Award will be notified of their selection and invited to participate in the Annual MMS Industry Awards Luncheon at which time the SAFE Award winners will be announced.