Recent growth in deepwater E&P activities in the U.S. Gulf of Mexico has drawn operators from around the world. Many of these, particularly large multinational corporations with roots outside the U.S., bring with them existing Safety and Environment (SE) Management Systems. Having been developed in different regulatory and business environments, however, these SE systems vary from U.S. requirements and practices in significant respects. Employing such non-U.S. systems in the Gulf of Mexico could pose risks and costs ranging from noncompliance to over-compliance, and could ignore important factors associated with U.S. liability regimes for which there may be no parallels elsewhere in the world.

It is imperative, therefore, that SE Management Systems be tested against and adapted fully to the U.S. environment. Even decisions to retain the over-compliant "home" systems must be made after careful consideration of the costs and consequences.

This paper will provide an overall framework for evaluating and adapting non-U.S. SE systems in the Gulf of Mexico, as well as specific areas of concern. The latter include liability regimes in the spill and personal injury arenas; reputation issues; investigating incidents; benefits and risks of "over-compliance"; use of lawyers and other consultants; and other critical areas where the U.S. offers special SE challenges. The paper also will discuss methodologies for identifying and assessing gaps, risks and costs associated with use of non-U.S. systems in the Gulf of Mexico.

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