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mms subpart o update

Subpart

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mms subpart o update

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    1. MMS Subpart O Update IADC Well Control Committee Meeting Galveston, Texas August 8, 2003

    2. Subpart ‘O’ Training Became effective on October 15, 2002 Applies to well control and production safety training Performance-based rule that focuses on results Places burden on industry rather than MMS Currently being implemented by regional personnel

    3. Subpart ‘O’ Training(continued) The lessee (with regards to contractors) is responsible for: 30 CFR 250.1503(b)(2) Procedures for evaluating the training programs of your contractors. 30 CFR 250.1503(b)(3) Procedures for verifying that all…contractor personnel engaged in well control or production safety operations can perform their assigned duties. 30 CFR 250.1506(c) Ensure that your contractors training programs provide for periodic training and verification of knowledge.

    4. Subpart ‘O’ Training(continued) The contractor is responsible for training its employees to perform their well control or production safety operations responsibilities. Including plan for periodic training. Verification of knowledge and skill.

    5. Subpart OBulletin Board Questions received from industry on training rule and MMS responses will be posted on mms.gov Allows MMS an opportunity to provide consistent answers to industry questions Comments to bulletin board may be able to be received anonymously

    6. Common IndustryApproaches IADC WELLCAP Well control training Globally recognized program Proven track record API TPCP Training management system Certification program Will be used primarily for production safety training Established September, 2002 Use of the Gulf Coast Safety and Training Group generic training plan

    7. Audit Plans - Tentative 22 companies marked for auditing (Oct ’02 – Oct ’03). Are conducting audits of poor performers and those with significant events Other companies will be randomly selected for audit Plans are to average two audits per month 15 of the 22 audits completed plus an additional 3 resulting from the APR’s

    8. Audit Process Request copy of company training plan Schedule audit date Plan review Personnel records review Contractor evaluation and contract employee verification Procedures for internal audits Audit closeout

    9. INCs Issued G-402 The operator failed to specify in the training plan the length of the training for the employees. The plan identified an 8-hour refresher and full course for production safety. The plan also identified a well-control and well-servicing training curriculum, however, the length of the courses was not specified for the full production safety course, the well-control course, and the well servicing course. G-408 The operator failed to include in the training plan procedures for conducting internal audits.

    10. INCs Issued G-405 The operator failed to include in the training plan, procedures for evaluating the well-control and production safety training programs of its contractors. Their plan stated minimum criteria contractors must have in order to conduct work for the operator, however, there were no procedures identified for evaluating the training programs of the contractors. G-408 The operator failed to include in the training plan procedures for conducting internal audits of the production safety training program. Their well-control part of their training plan included procedures for conducting internal audits; however, they did not have any procedures for auditing their production safety training part of the plan.

    11. INCs Issued G-416 - The operator failed to produce evidence that the operator had evaluated the training program of the drilling contractor to ensure that the program met the operator’s expectations as well as ensuring that the contractor’s training program verified knowledge and skill and provided for periodic training.

    12. Misconceptions Hands-on training Internal audits Multiple/Duplicate procedural requirements

    13. 250.1503(b)…plan that specifies the type, method(s), length, frequency, and content of the training for your employees. Your training plan must specify the method(s) of verifying employee understanding and performance. Training Plan Contentscontinued

    14. Your plan must include at least the following information: 1503(b)(1) Procedures for training employees in well control or production safety practices. 1503(b)(2) Procedures for evaluating the training programs of your contractors. 1503(b)(3) Procedures for verifying that all employees and contractor personnel engaged in well control or production safety operations can perform their assigned duties. Training Plan Contentscontinued

    15. Training Plan Contentscontinued 1503(b)(4) Procedures for assessing the training needs of your employees on a periodic basis. 1503(b)(5) Recordkeeping and documentation procedures. 1503(b)(6) Internal audit procedures.

    16. Training Plan Contentscontinued Included in items 1503(b)(1-6) Use of alternative training methods (1504). Sources of training (1505). You must provide for periodic training to ensure that employees maintain understanding and competency (1506)(a). Procedures to verify adequate retention of knowledge and skills. You must ensure that contractors’ programs provide for periodic training and verification of knowledge and skill (1506)(c).

    17. Thank You www.mms.gov David Dykes 504-736-3249 david.dykes@mms.gov

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