GOM operators and contractors must tailor programs to comply with Subpart 0 - Well control and production safety training - regulations.

A major revision to the US Minerals Management Service (MMS) training regulations that govern oil and gas activity in US offshore areas occurred recently when existing regulations were incorporated into the 30 Code of Federal Regulations, Subpart "O" training document (Federal Register, Vol. 65, No. 157). The MMS recognized that more stringent accountability was required to prove an individual's core knowledge of the skills and topics required at each job description. In addition, a methodology was required to assess core competency of the skills needed to perform individual job duties. In response, MMS released Subpart O - Well Control and Production Safety Training regulations.

After Oct. 15, 2002, all companies were required to comply with the provisions of Subpart O, as required by MMS 250.1502. Following that date, the MMS will no longer accredited schools or other organizations for well control and production safety training and certification. The MMS set forth to create clear guidelines for leasees in the OCS and to set a deadline for them to have a training plan created and in place for implementation. Leasees were informed that the burden of accountability would fall on the individual companies to create and implement a plan for proving competency of personnel and contractor employees. The reasons that the MMS implemented the Oct. 15, 2002 Subpart O regulations was to put the burden on Lessees to identify how best to train their personnel, provide greater flexibility to the Lessees to develop training programs that work, and to give Lessees an opportunity to develop new training techniques.

MMS requires personnel involved in well control and production operations to have the skills needed to competently do their jobs. Well control applies to drilling, well completion and well servicing (snubbing, small tubing, coiled tubing and wireline) operations. Production safety covers production operations, as well as the installation, repair, testing, maintenance and operation of surface or subsurface safety devices.

Requirement

Lessees and Contractors have to prove that well control and production personnel who work offshore in the OCS have demonstrated they are competent in both instructional knowledge and job performance. MMS 250.1501 (Subpart O) states, "You must ensure that your employees and contract personnel engaged in well control and production safety operations understand and can properly perform their duties."

The MMS Subpart O regulations identify the training, record keeping and overall training plans and audits that Lessees and Contractors should address. In the past, a certificate and a training card was enough to prove that personnel had successfully completed training. It became evident over time that passing the test did not mean that the individual could perform the skills and tasks required once they were at the actual job site. MMS stressed that on-the-job-training for the specific types of responsibilities the employee will have to perform should be used to reinforce the training methods used.

In addition, MMS 250.1503 stated, "You must establish and implement a training program so that all of your employees are trained to competently perform their assigned well control and production safety duties." Companies must have a training plan that specifies the type, method(s), length, frequency and content of employee training. The plan must include procedures for training, evaluating the training plan, verifying competency, assessing training frequency needs, record keeping and internal auditing.

Traditional Training

Conventional instructor-led training is one option used by companies to meet MMS requirements. With qualified instructors, limited classroom sizes, defined training levels, and approved course content and materials, companies feel that their personnel are being instructed and tested on the required topics and skills. Classroom simulators allow general hands-on training in a classroom that covers warning signs and actions that may be encountered while on duty. However, a passing examination score is only one part of the training objective. Companies must train personnel to perform their assigned duties safely by offering on-the-job training in the form of drills and exercises. The key concern for many operators is how to measure employee retention of the skill sets they are learning outside of a traditional classroom setting or test.

The goal of the new MMS Subpart O regulations is to raise the level of training and help reduce the number of accidents on the Outer Continental Shelf. The importance of identifying areas where an employee or contractor needs remediation through adequate documentation is the key. The greatest concern for lessees and contractors has been the creation of a consistent training plan with documentation to help verify knowledge and skill levels. This has led many companies to consider both how to expand on traditional instructor-led schools and the benefits of utilizing alternative training methods such as computer-based training.

Computer-based training

According to MMS 250.1504, "alternative training methods must be conducted according to, and meet the objectives of, your training plan." An emerging option that is available to the industry is interactive, computer-based training (CBT). Several studies have shown that students have achieved significantly higher scores and content retention with computer-aided instruction. "Content retention is increased by engaging multiple senses (auditory, visual and kinesthetic) during the learning process" (Dhanjal & Calis 1999). Additionally, a study conducted by the United States Coast Guard on the effectiveness of computer-based training concluded that CBT can be as effective as instructor led courses conducted at shoreside training centers, often reducing costs and training time.

CBT offers extensive reporting systems to provide proof of competency and verifies that topics and skills have been administered and assessed. In CBT, interactive tasks and role playing familiarize learners with well control concepts, emphasizing correct procedure and teamwork. The interactive nature of CBT allows the program to log not only an employee's strengths, but also his/her weaknesses, providing a plan for further areas where improvement and remediation may be necessary. CBT also helps to eliminate bias by evaluating each student's performance based on standards required by the training curriculum. Students are able to utilize help menus to address questions they may be reluctant to voice in a classroom environment with personnel of varying levels, knowledge and experience. CBT programs are easily implemented at the rig site, platform, offices, in-house schools or training facility, and may help reduce overall training costs by eliminating expenses for travel, hotel, meals, overtime and relief personnel.

Currently, there are several CBT programs that have full approval by both the American Petroleum Institute (API) and the International Association of Drilling Contractors (IADC). These programs help to satisfy the requirements mandated by the new MMS federal regulations to develop a training curriculum, verify the competency and frequency of oil field training, and document and maintain records for both operator and contractor personnel. Again, alternative training methods must also include appropriate demonstrations and hands-on training at the job site to help reinforce the various types of training.
There are CBT programs that were previously approved by the MMS; however, as with other MMS programs, the CBT programs are no longer approved as a result of the Subpart O regulations which took effect on Oct. 15, 2002.

System 21 Well Control and Production Safety Systems Training was one of the CBT programs that was approved by the MMS when it still accredited schools and training programs. Today, System 21 holds the full approval of the IADC WellCAP for Well Control in both English and Spanish and API approval for Production Safety Systems Training. System 21 also offers companies International Well Control Forum (IWCF) preparation and practice testing to help personnel prepare for the exam at an IWCF approved testing facility.

The instructional design of the system helps to ensure comprehension of key points by preventing a student from moving on until the material is completely understood. If a student misses a question, he/she returns to the appropriate section for instruction and is then asked the question again. Random test questions and random answers can be used to validate competency in each area covered.

The training system allows companies to provide full disclosure of a student's performance at the touch of a button. This includes test scores, topics and skills covered, as well as custom reporting on those areas where students missed questions or had to make repeated attempts on a simulator. This extensive reporting system provides proof of competency and verifies the topics and skills have been administered and assessed.

Compliance

To comply with the new regulations, lessees must be prepared to explain to the MMS their overall training program and produce evidence to support their explanation. The MMS may conduct testing to verify an individual's knowledge and skill level in well control and production safety. Hands-on production safety, simulation, or live well testing may be used to evaluate the competency of employees or contract personnel performing the tasks. If the MMS finds that a training program is not in compliance, it may initiate one or more enforcement actions, including issuing an incident of non-compliance, requiring the company to revise and submit the training plan to address and identify deficiencies, assessing civil/criminal penalties, or initiating disqualification procedures.

Less than a year ago the industry was required to be in compliance with the new MMS Subpart O regulations. The implementation of these new regulations and the creation of training plans helped the industry to discuss training and its implications on a much larger scale. Lessees are hoping that by creating a standard method of training and maintaining records they can set the example for the industry in providing diligent and consistent training worldwide. This will be their only way to feel confident the contractors are trained and their skills are properly assessed in well control and production safety.
Since the burden of proof for Leasees encompasses not only their employees, but contract personnel as well, large companies will be inclined to select contractors that follow their own training guidelines. With this in mind, several contractors are waiting for the larger operating and service companies to decide what types of training they will use so they can begin to prepare their workforces.