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Gulf of Mexico Challenges with Contractor Verification - Skills and Knowledge. “ You must be the change you wish to see in the world ” ~Mahatma Gandhi. Objectives. Genesis of Contractor Verification (CV) Skills and Knowledge Challenges for Operators and Contractors Trends Across Industry
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Gulf of Mexico Challenges with Contractor Verification - Skills and Knowledge
“You must be the change you wish to see in the world” ~Mahatma Gandhi
Objectives • Genesis of Contractor Verification (CV) Skills and Knowledge • Challenges for Operators and Contractors • Trends Across Industry • Skills and Knowledge Assessment • Positive Direction for Future
Evolution of SEMS Development of Process Safety Fixborough Incident (1974) API 75 RP - Development of Safety and Environmental Management Program Piper Alpha Incident (1988)
Evolution of SEMS Requirement of API 75- Development of Safety and Environmental Management Program Deepwater Horizon Incident (2010)
Elements of SEMS • General Provisions (Background Info) • Safety and Environmental Information • Hazards Analysis • Management of Change • Operating Procedures • Safe Work Practices • Training • Mechanical Integrity • Pre-startup Review • Emergency Response and Control • Investigation of Incidents • Audits • Records and Documentation Contractor Verification – Skills and Knowledge
Genesis of CV Skills & Knowledge 30 CFR 250 – Subpart S • § 250.1901 - (b) All personnel involved with SEMS program must be trained to have the skills and knowledgeto perform theirassigned duties. • § 250.1914 - (c) SEMS program must include procedures and verification for selecting a contractor as follows: • Operator is responsible for making certain that contractors have the skills and knowledge to perform their assigned duties and are conducting these activities in accordance with the requirements in SEMS program. • Operator must make the results of (their) verification for selecting contractors available to Bureau of Safety Environment and Environmental Enforcement (BSEE) upon request.
DOT Pipeline Parallel • OQ is performance based • Operator's responsibility to ensure that every individual, (operator and contractor) who performs a covered task on an operator's pipeline facility must: • Either be qualified to perform those tasks or • Be directed and observed by a qualified person
"It is the intent of this rule [SEMS] to hold the operator accountable for the overall safety of the offshore facility, including ensuring that all contractors and subcontractors have safety policies and procedures in place that support the implementation of the operator's SEMS program and align with the principles of managing safety set forth in API RP 75." ~Federal Register on Oct. 15, 2010
Challenges for Operators • Heavy responsibility for interpreting regulation correctly • No common industry solution • Different existing processes • Different organizational structures • Define minimum skills and knowledge needed to perform a job safely • No clear definition from BSEE regarding acceptable risk
Challenges for Contractors • Complying with different Operator solutions • Cost of complying • Subscriptions • Technology • Augmented staff • Assessing skills and knowledge
Job Title Challenge Engineer?
Job Title Challenge Field Service Specialist? or Field Service Technician?
How Prescriptive Is Necessary? Company and Employee Verification? HSE and Technical Requirements? General or Role Specific? Daily Check or Spot Check? Quality of the Requirements? Minimum Duration for Course? Approved Training Providers?
Benefits to SEMS SAFETY
In the meantime… Change Management • It is important to approach change management with all aspects in mind: • Strategic planning • Business modeling • Organizational and cultural change • Communications and marketing strategy • Project management • Trend and market analysis • Dealing with the outcome of change • How do I efficiently fit the change into already existing processes instead of just adding to my plate… SIMPLIFY?
If you want some help… Chaucer • People • All are seasoned and proven, combining specialized expertise with business acumen • Operate at both thestrategic advisory and hands-on execution / implementation level • All about accountability and responsibility for desired end-results • Expertise • Business transformation, change management, project management and M&A are our heritage • Areas of deep expertise are formalized and delivered within the context of practice disciplines • Most of our consultants are thought leaders in their respective fields • Approach • Our core operating philosophy revolves around long-term client relationships • Maximum flexibility of approach … we leverage our methodology, the client’s or a blend of both • Solution alignment with client’s unique business context … no ‘square peg / round hole’ scenarios • Value • Major value-add … emphasis on making our Knowledge Management System a client asset • Attractive rates for comparable level and expertise of resources • Knowledge transfer is a key component of every engagement … i.e., sustainable business value