subpart o testing public workshop david dykes joe levine
DESCRIPTION
SUBPART O TESTING PUBLIC WORKSHOP David Dykes Joe Levine. February 19, 2009 New Orleans. WORKSHOP AGENDA. Subpart O Testing Regulations Subpart O Testing History Subpart O Pilot Testing Process Subpart O Pilot Test Results Testing Beyond Pilot Discussion, Q & A. WORKSHOP GOAL. - PowerPoint PPT PresentationTRANSCRIPT
SUBPART O TESTING PUBLIC WORKSHOP
David DykesJoe Levine
February 19, 2009
New Orleans
WORKSHOP AGENDA
• Subpart O Testing Regulations
• Subpart O Testing History
• Subpart O Pilot Testing Process
• Subpart O Pilot Test Results
• Testing Beyond Pilot
• Discussion, Q & A
WORKSHOP GOAL
• To explain −What Subpart O testing is all about−Eliminate unwarranted concerns−How MMS & industry can use testing to
help raise the level of OCS safety
Can Testing Benefit Your Company?
• An extra set of “eyes” evaluating your personnel
• Additional assessment of employees between regularly scheduled training
• If an area of concern is uncovered by testing you have the opportunity to address it
What Subpart O Testing Is Not
• A quantitative measure of an
employees’−Competency or knowledge of job −Ability to perform their job−Passing a test does not mean an
employee knows their job−Failing a test does not mean an
employee can not do their job
What Subpart O Testing Is
• Another data point for MMS & industry to
use to assess the effectiveness of a
company‘s Subpart O training program and
overall safety management system (SEMS,
SEMP….)
• An opportunity to gain additional feedback
on how well “you” are getting critical job
related information across to your most
important asset; your people
Subpart O Overriding Principles• Testing, as with other aspects of
Subpart O is aimed primarily at the
lessee
• Testing will impact not only lessees,
but contractors as well
• It is the lessees responsibility to ensure
their contractors can properly perform
their assigned duties
Subpart O Testing Regulations
30 CFR 250.1507 (c)
c) Employee or contract personnel testing
MMS or its authorized representative may conduct testing at either onshore or offshore locations for the purpose of evaluating an individual's knowledge and skills in performing well control and production safety duties.
30 CFR 250.1507 (d)
(d) Hands-on production safety, simulator, or live well testing
MMS or its authorized representative may conduct tests at either onshore or offshore locations. Tests will be designed to evaluate the competency of your employees or contract personnel in performing their assigned well control and production safety duties. You are responsible for the costs associated with this testing, excluding salary and travel costs for MMS personnel.
30 CFR 250.1508
What must I do when MMS administers written or oral tests? MMS or its authorized representative may test your employees or contract personnel at your worksite or at an onshore location. You and your contractors must:(a) Allow MMS or its authorized representative to administer written or oral tests; and(b) Identify personnel by current position, years of experience in present position, years of total oil field experience, and employer's name (e.g., operator, contractor, or sub-contractor company name).
30 CFR 250.1509 What must I do when MMS administers or
requires hands-on, simulator, or other types of testing?
If MMS or its authorized representative conducts, or requires you or your contractor to conduct hands-on, simulator, or other types of testing, you must:
(a) Allow MMS or its authorized representative to administer or witness the testing; (b) Identify personnel by current position, years of experience in present position, years of total oil field experience, and employer's name (e.g., operator, contractor, or sub-contractor company name); and (c) Pay for all costs associated with the testing, excluding salary and travel costs for MMS personnel
Subpart O Testing History
At This Point, Testing Should Not be a Surprise to You or Your Company• Testing has been included in our
regulations since the year 2000
• We have voiced our intention to test at a
variety of conferences & meetings in recent
years
• Before initiating the 2008 Subpart O pilot
the agency began exploring testing in 2007
January, 2007 IADC Well Control Work Group• MMS introduced idea to IADC that agency
was interested in implementing Subpart O testing
• MMS presented hands-on well control testing options to IADC for discussion purposes−Live well tests−School based testing
•simulators•computers
−30 CFR 250.462 (d) Well Control Drill
January, 2007 IADC Well Control Work Group• Why Was MMS Interested in Testing?
−Increase in Subpart O INCs • 40 INCs as of 1/2007• G 846, G851, G862, G842
−Loss of experienced personnel
• Up to this point MMS had conducted 6 written tests, several oral tests, & no hands-on tests
• MMS requested IADC/Industry input on testing
NTL No. 2008-N03 - Well Control & Production Safety Training
• Effective March 31, 2008• Clarified terms used in Subpart O rule
−Internal audit, production safety, periodic, contractor
• Discussed lessee and contractor responsibilities, program evaluations, & employee verifications
• Announced MMS intent to conduct hands-on testing in 2008
April, 2008 - Baker Energy
• MMS met with Baker to review their
production training program
• Baker provided MMS detailed information on
program highlights to aid us in developing a
successful Subpart O test program−Training components−Assessment criteria−Test questions−Grading issues −Program statistics
June, 2008 IADC Well Control Work Group• MMS updated IADC & continued to
press for input into testing program• Training INCs continue to increase
−71 INCs as of 12/2007• Up to this point MMS had conducted
10 written tests, 36 oral tests, & no hands-on tests
• IADC agreed to form internal group to provide MMS testing feedback
August, 2008 IADC Well Control Work Group• Since June, 2008 IADC/Chevron provided MMS a
series of hands-on well control scenarios −Operational based −Position specific
• Discussed IADC/Chevron suggestions for hands-
on well control scenarios received by agency
• MMS provided work group overview of how pilot
Subpart O testing program could work moving
forward
October, 2008Diamond Offshore Drilling• Diamond volunteers rigs for offshore
written &/or hands-on well control testing −Diamond/Devon−Ocean Endeavour semisubmersible−Pre MMS pilot
• Received valuable real world input and comments on specific test questions, test process, grading policies
Testing• Since publication of Subpart O in 2000
MMS has had a variety of tools at our
disposal to monitor industry
compliance −Employee interviews−Audits−Tests
• Majority of MMS efforts to date have
focused on interviews and audits
45
0
493
5
740
10
651
4
699
15
486
291
10
100
200
300
400
500
600
700
800
2002 2003 2004 2005 2006 2007 2008
Informal Employee Interviews Unfavorable Interviews
INFORMAL EMPLOYEE INTERVIEW’S
(2002 – 2008 YTD)
INFORMAL EMPLOYEE INTERVIEW’S
(2002 – 2008 YTD)
SUB O AUDITS & INCs SUB O AUDITS & INCs
(2002 (2002 –– 2008 YTD) 2008 YTD)
SUB O AUDITS & INCs SUB O AUDITS & INCs
(2002 (2002 –– 2008 YTD) 2008 YTD)
4 2
18
6
19
7
2018
27
10
30 2926
50
0
10
20
30
40
2002 2003 2004 2005 2006 2007 2008 ytd
Audits Conducted INCs Issued
Testing• After evaluating how interviews and audits
work/don’t work MMS began to explore
testing
• Provides MMS another tool in our audit tool
box to evaluate employee competency
• Provides MMS and company more of a “real”
world evaluation of individual skills as
related to their job
SUBPART OPILOT TESTING PROCESS
Testing Pilot Program• Started 11/1/08 • No enforcement (INC) • Goal
− Issue as many tests as possible to gain a better understanding of test administration
− Receive lessee & contractor input• Areas of concern
− Grading • 70% • pass/fail
− Consistency• test administration
− Level of difficulty
Testing Pilot Program
• Open book • All material acceptable
− Charts, guides, books, tables….
• No time limit• Testing location
− Onshore (office, school), offshore
• Passing grade− Written – 70% and above− Hands-on – pass/fail, all
steps deemed critical
Written Well Control Pilot Tests• Three tests; “A”, “B”, “C”
• Each test includes three levels based
upon rig position• Level “L1”
− floorhand, derrickman
• Level “L1L2”− driller, assistant driller
• Level “L1L2L3”− toolpusher, company man
Written Well Control Pilot Tests - Grading• Level “L1” (floorhand, derrickman)
− 5 questions− Passing = 70% on this section only
• Level “L1L2” (driller, assistant driller)− 11 questions
• 5 questions from “L1” + 6 new questions− Passing = 70% on 11 questions
• Level “L1L2L3” (toolpusher, company man)− 20 questions
• 5 questions from “L1” + 6 questions from “L1L2” + 9 new questions
− Passing = 70% on 20 questions (entire test)
Written Well Control Pilot Tests - Questions
• Level “L1” questions −Basic well control concepts, equipment
practices
• Level “L1L2” questions −More advanced well control theory,
equipment concepts
• Level “L1L2L3” questions −Deeper knowledge of well control
techniques, operational systems, calculations
−Only level to contain calculations
Hands-On Pilot Well Control Tests• Five scenarios
• Each scenario includes a series of Yes/No skill based questions−5 to 8 questions per scenario
• Employee/team needs to show competency by demonstrating or answering all questions correctly
• Each question in a scenario deemed to be critical
• Scenarios focus on either an individual or a team
Written Production Pilot Tests• Five tests; “A”, “B”, “C”, “D”, “E”
• Each test includes three levels based upon position on facility−Level “L1”
• C or D operator
−Level “L1L2”• A or B operator
−Level “L1L2L3”• Lead operator
Written Production Pilot Tests - Grading• Level “L1” (C or D operator)
− 35 questions− Passing = 70% on this section only
• Level “L1L2” (A or B operator)− 44 questions total
• 35 questions from “L1” + 9 new questions − Passing = 70% on 44 questions
• Level “L1L2L3” (lead operator)− 50 questions total
• 35 questions from “L1” + 9 questions from “L1L2” + 6 new questions
− Passing = 70% on 50 questions (entire test)
Written Production Pilot Tests - Questions
• Level “L1” questions −Basic wellhead equipment design, safety device
testing and reporting requirements
• Level “L1L2” questions −More advanced safety analysis concepts, system
design theory and practices
• Level “L1L2L3” questions −Deeper knowledge of analysis, design,
installation and testing of production surface safety systems and of government codes, rules and regulations
Hands-On Production Pilot Tests
• Ten scenarios • Each scenario includes a series of Yes/No
skill based questions−10 to 14 questions per scenario
• Employee/team needs to show competency by demonstrating or answering all questions in a correct manner
• Each question in a scenario deemed to be critical
• Scenarios focus on either an individual or a team
PILOT TESTING PROGRAM RESULTS
Type of Tests Conducted During Pilot• Majority of written tests were offshore &
announced
• Small percentage of written tests were unannounced
• 18 well control written tests conducted at school & compared against schools’ test
• All hands-on pilot tests were conducted offshore
Testing Pilot Program• Lessee & contractors either volunteered to
participate or were picked at random
• Testing was conducted during normal MMS
inspection activities
• Tests were mostly graded onsite
• Employee comments were solicited
• Often times an individual was given multiple
tests for feedback and comparison purposes
• Test data was entered into an MMS data base
Companies Tested During Pilot−Devon/Diamond−ExxonMobil/H&P−ExxonMobil/Sam
Jones−Energy
XX1/Hercules−BP/Rowan−Helis/Rowan−Hunt/Ensco−Badger/Pride
−Mariner/Noble−El Paso/Wood
Group−Mariner/Prosper−Chevron/Parker−Venoco−PXP−Shell−Stone−Apache
Pilot Test Breakdown by MMS Region
• Total tests conducted during pilot −Gulf of Mexico - 129 −Pacific - 7−Alaska - 0
Subpart O Pilot Tests Conducted• Written Tests
−Well control – 86• 37 L1• 23 L1L2• 26 L1L2L3
−Production – 31• 4 L1• 7 L1L2• 20 L1L2L3
• Hands-On Tests -19−Well control - 4−Production - 15
0
2
4
6
8
10
12
14
Nu
mb
er
of
Tests
Test Type
Pilot Written Well Control Tests
PILOT WRITTEN WELL CONTROL TEST “A”GRADE DISTRIBUTION*
L1,L2,L3 L1,L2 L1
85 91 100
95 73 80
85 64 60
90 91 60
93 73 80
65 64 80
100 60
60 * Failures (less than 70% noted in red) 60
40
80
Tests Given 7 6 11
Average Grade 87.6 76 69.1
PILOT WRITTEN WELL CONTROL TEST “B” GRADE DISTRIBUTION* L1,L2,L3 L1,L2 L1
95 64 100
75 73 100
80 64 80
90 91 100
85 91 60
90 91 100
80 100 80
85 73 100
* Failures (less than 70% noted in red) 90 64 80
70 80
60
60
100
100
Tests Given 10 9 14
Average Grade 84 79 85.7
PILOT WRITTEN WELL CONTROL TEST “C” GRADE DISTRIBUTION*
L1,L2,L3 L1,L2 L1
65 64 40
90 64 80
60 73 80
45 64 20
95 64 40
75 64 40
* Failures (less than 70% noted in red) 90 37 40
70 55 40
80 40
40
0
0
Tests Given 9 8 12
Average Grade 74 61 42
PILOT WRITTEN WELL CONTROL TEST “A”
6.3
69
11 11.6
76
6
28.5
88
7
0
20
40
60
80
100
Av
g Y
rs, A
vg
Sc
ore
, Tim
es
Ta
ke
n
L1 L1L2 L1L2L3
Avg. Yrs. Oilfield Experience Avg. Score (%) # Times Test Taken
PILOT WRITTEN WELL CONTROL TEST “B”
6.3
86
14 12
79
9
29.6
84
10
0
20
40
60
80
100
Av
g Y
rs, A
vg
Sc
ore
, Tim
es
Ta
ke
n
L1 L1L2 L1L2L3
Avg. Yrs. Oilfield Experience Avg. Test Score (%) # Times Test Taken
PILOT WRITTEN WELL CONTROL TEST “C”
6
42
12 11
61
8
28
74
9
0
20
40
60
80
100
Av
g Y
rs, A
vg
Sc
ore
, Tim
es
Ta
ke
n
L1 L1L2 L1L2L3
Avg. Yrs. Oilfield Experience Avg. Test Score (%) # Times Test Taken
PILOT WELL CONTROL WRITTEN TEST vs. SCHOOL TESTS• 18 MMS well control written tests conducted at school &
compared against schools’ test• Tested 6 people; 2 toolpushers, 1 driller, 1 derrickman, 2
floorhands• School WellCAP test averages
− Introductory – 78%− Fundamental – 87%− Supervisory – 89%
• MMS test averages− “L1” – 70%− “L1L2” – 81.7%− “L1L2L3” – 83.3%
• Limited data shows consistently higher school scores than MMS scores for “comparable” tests
WELL CONTROL WRITTEN PILOT TESTS WHAT DID WE LEARN ?• Well Control Test “C” Appears to be the Most
Difficult− Test C has more calculations than Test A or Test B− Test C has lowest average test scores in each category
• Most Test Failures are for the “L1” level − Floorhand, derrickman− As expected, “L1” personnel are least experienced
≈ 6 yrs. avg. oilfield experience− Majority of “L1” personnel appear to be trained in
accordance with IADC WellCAP Introductory level • some MMS “L1” questions were outside scope of IADC
WellCAP Introductory level − BOP testing and MMS regulations
WELL CONTROL WRITTEN PILOT TESTS AREAS OF CONCERN• L1 (floorhand, derrickman)
−Causes of kick• not keeping hole full• insufficient mud weight• lost circulation
−First step to control kick• shut well in ASAP
−Location of wrench for manual valves (MMS regulations)
• ready access
−Annular test pressure or test frequency• 14 day• 70% RWP or per MMS (not in WEllCAP, MMS
regulations)
WELL CONTROL WRITTEN PILOT TESTS AREAS OF CONCERN• L1L2 (driller, assistant driller)
− Hydrostatic pressure concept• gradient or density of fluid x height of fluid
column− Ways to circulate out kick
• drillers, wait/weight, volumetric− Ram test pressure
• RWP or per MMS (MMS regulations)− With well shut in what happens to BHP as gas bubble
rises− Quantities of drilling fluid and drilling fluid materials
on rig to ensure well control (MMS regulations)− Safe drilling margin
WELL CONTROL WRITTEN PILOT TESTS AREAS OF CONCERN• L1L2L3 (toolpusher, company man)
−Calculations (only test w/ calculations)• P1V1=P2V2
• sacks Barite to increase MW• circulating pressures• equivalent mud weight
−MMS regulations• diverter vent line OD (bottom founded, floater)• directional requirements (inclination, azimuth)
Written Well Control Tests Lessons Learned• Evaluate increasing number of questions in “L1”
section of test from 5 to 10 for easier/better grading
• Evaluate IADC WellCAP course curriculum in developing questions for tests and use as appropriate;− Introductory (floorhand, derrickman)− Fundamental (derrickman, assistant driller, driller)− Supervisory (tool pusher, company man)
• Evaluate question specific comments received by MMS & industry personnel
0
1
2
3
4
5
6
7
Nu
mb
er
of
Tests
Test Type
Pilot Written Production Tests
PILOT WRITTEN PRODUCTION TEST “A”GRADE DISTRIBUTION
L1,L2,L3 L1,L2 L1
74 75 80
88 82 92
86
92
Tests Given 4 2 2
Average Grade
85 78.5 86
PILOT WRITTEN PRODUCTION TEST “B” GRADE DISTRIBUITION
L1,L2,L3 L1,L2 L1
92 77
90
90
76
76
86
92
Tests Given 7 1 0
Average Grade 86 77 NA
PILOT WRITTEN PRODUCTION TEST “C” GRADE DISTRIBUTION
L1,L2,L3 L1,L2 L1
80 91 86
92
94
Tests Given 3 1 1
Average Grade 88.7 91 86
PILOT WRITTEN PRODUCTION TEST “D” GRADE DISTRIBUTION
L1,L2,L3 L1,L2 L1
86 84 83
96
88
Tests Given 3 1 1
Average Grade 90 84 83
PILOT WRITTEN PRODUCTION TEST “E” GRADE DISTRIBUTION
L1,L2,L3 L1,L2 L1
80 91
92 89
94
Tests Given 3 2 0
Average Grade 88.7 90 NA
PILOT WRITTEN PRODUCTION TEST “A”
2.25
86
2
17.5
79
2
20.75
85
4
0
20
40
60
80
100
Av
g Y
rs, A
vg
Sc
ore
, Tim
es
Ta
ke
n
L1 L1L2 L1L2L3
Avg. Yrs. Oilfield Experience Avg. Test Score (%) # Times Test Taken
PILOT WRITTEN PRODUCTION TEST “B”
0 0 0
10
77
1
15.2
86
7
0
20
40
60
80
100
Av
g Y
rs, A
vg
Sc
ore
, Tim
es
Ta
ke
n
L1 L1L2 L1L2L3
Avg. Yrs. Oilfield Experience Avg. Test Score (%) # Times Test Taken
PILOT WRITTEN PRODUCTION TEST “C”
1.5
86
1
18
91
1
19
89
3
0
20
40
60
80
100
Av
g Y
rs, A
vg
Sc
ore
, Tim
es
Ta
ke
n
L1 L1L2 L1L2L3
Avg. Yrs. Oilfield Experience Avg. Test Score (%) # Times Test Taken
PILOT WRITTEN PRODUCTION TEST “D”
1.5
83
1
18
84
1
19
90
3
0
20
40
60
80
100
Av
g Y
rs, A
vg
Sc
ore
, Tim
es
Ta
ke
n
L1 L1L2 L1L2L3
Avg. Yrs. Oilfield Experience Avg. Test Score (%) # Times Test Taken
PILOT WRITTEN PRODUCTION TEST “E”
0 0 0
14
90
2
21
89
3
0
20
40
60
80
100
Av
g Y
rs, A
vg
Sc
ore
, Tim
es
Ta
ke
n
L1 L1L2 L1L2L3
Avg. Yrs. Oilfield Experience Avg. Test Score (%) # Times Test Taken
Written Pilot Production Tests What Did We Learn?
• MMS would have liked to have
conducted more production written
tests however, based upon the data;−Production tests A – E appear to be of
equivalent difficulty −No failures out of 31 tests
• 74% lowest recorded grade (Test A-L1L2L3)
Written Pilot Production Tests Areas of Concern
• L1 (C, D operators) −Wellhead component identification
• casing valves (intermediate, production)• casing heads (surface, intermediate,
production)
−Equipment testing interval• TSH-compressor (six months)• TSH-fired component (annual)
Written Pilot Production Tests Areas of Concern
• L1L2 (A, B operators) −Wellhead component identification
• casing valves (intermediate, production)• casing heads (surface, intermediate, production
−Separator pressure valve settings−Equipment testing interval
• BSL (annual)• tubing plug (six months)
−What does LACT stand for?
Written Pilot Production Tests Areas of Concern
• L1L2L3 (lead operators) −DOI pipeline out of service requirements−% of LEL gas detector should alarm at−Separator pressure valve settings−What does LACT stand for?−Equipment testing interval
• tubing plug (annual)
Pilot Hands On Test Results
• Well Control – 4 (P, P, P, P)
• Production – 15• (P, F-13/14)• (P)• (P)• (P, P, F-9/10)• (P, P)• (P, F-9/10)• (P, F-7/10)• (P, P)
Pilot Hands On Tests – What Did We Learn• Grading
−Test taker could be competent even though they did not answer all questions correctly or perform task properly
−Subjectivity of MMS
• Should we continue with P/F hands on grading system or evaluate use of a grading system similar to written testing?
Test Taker Comments• Well Control Written
− Good program− Tests put together well, each level fair, good
learning tool, good refresher, fair test− Tests should lead to increased safety− L1 test adequate, tests L1L2 and L1L2L3 should be
more detailed− Straightforward, easy to understand− Good for basic knowledge, good mix of easy/hard
questions− Good for rig tests− Will help improve skills between school
based training− L1 test easy, L1L2 test confusing− Do not test on crew change days (2 times)
Test Taker Comments• Well Control Written
− Some questions I have seen before others I have not− Strong test, good test (7 times)− Questions did not clearly show choices, I knew the
answer but it was not in the choices− Need MMS regulation book for test− Hard test− Testing is good, allows you to see who understands
what− Don’t test on first day back after days off, keep
testing− Not enough time, felt rushed− Use one big test− Good questions (2 times)− Too many repeat questions− Tests shouldn’t be announced− Tests identify items I am weak in
Test Taker Comments
• Production Written−Some questions geared to management
personnel not operational personnel−Test A question #7; confusing−Test A question #2; misleading −Test B question #19; could not find in CFR (2
times)−We need a list of publications showing where
questions come from−Good general test on equipment and regulations−Good test−Test B is best, more real world then other test
versions
Test Taker Comments
• Production Hands On−Scenario went over all procedures to
troubleshoot this event (2 times)−Evaluation went over all steps to troubleshoot
equipment and went through all components−Scenario went over all components &
operations associated with performing task
• Well Control−None
What's Next?Testing Beyond
Pilot
Major Points of Interest
• Post-pilot testing program will go into effect on 4/1/09
• Post-pilot program will include enforcement
• Lessons learned from pilot program will be integrated into program whenever feasible
Who Will MMS Test ?
• Possible test candidates;−Operator −Contractor −Companies picked @ random −Companies experiencing;
• problems with Subpart O audit• loss of well control• lower than average OSI (poor performers)
−When training is identified as a cause in an accident
Test Triggers
• Testing is one tool in the audit toolbox
• Triggers for testing include:−Failure of the operator to verify employee
knowledge and skill−Failure of the operator to verify contractor
employee knowledge and skill−Failure of the operator to evaluate
contractors training program
Post-Pilot Testing Procedure - Basics• Tests will be announced or unannounced
− Announced • phone call or letter from MMS
• Tests will be conducted at a variety of locations; onshore (school, office), offshore− Offshore
• MMS to discuss w/ field management to determine if it is safe & appropriate to conduct a test at that time (written or hands-on)
• Open book− All material acceptable − Computers OK with MMS monitoring
• No emails, no IM’s
• No time limit for test
Post-Pilot Testing Procedure - Basics• No set number of tests to be conducted by
MMS during a year• If we conduct test @ your rig/facility/school
goal is to test 10% of personnel on location• No retests• No help from others• Grading
−70% = passing for both written and hands-on tests
Post-Pilot Testing Procedure - Basics• Well control written tests
−4 new tests instead of 3 −10 questions in “L1” (floorhand, derrickman)
section of test instead of 5−Questions to focus more on IADC WellCAP
Introductory level and less on MMS regulations
• Production written tests−More or less same questions as pilot tests
however questions will be renumbered for easier grading
−Addition of an H2S supplement – operational specific testing
Post-Pilot Testing Procedure• Enforcement
− If employee fails written test (< 70%) a G-856 INC may be issued• MMS will consider a hands-on test of
employee to validate written test prior to deciding on INC
−Based on test(s) results MMS briefs lessee with general assessment of employees performance• if MMS feels strongly that INC should be
issued lessee will be informed to expect INC in the mail from District within 7 business days
• no INC issued on-site• grading will not be conducted on-site, but in
District • lessee needs to identify to MMS how they
will address deficient employee before MMS leaves location (school, rig/facility…)
G 856 INC Information• INC with explanatory letter to lessee is
issued by District office and will include;− Date & time of test− Employer
• lessee, contractor− Location of test
• onshore (school, office)• offshore (rig/facility, lease/block)
− Position of employee • Lead operator, driller …..
− Score and result • numeric grade• pass/ fail• specific questions wrong will not be released
− Overview of concerns
Post-Pilot Testing Procedure
• G-856 Possible Corrective Actions−Retrain employee−Retest employee w/ company test−Retrain and retest employee−Put employee under direct supervision
of another employee−Transfer employee to another job −Others ??
New G-856 PINC• G-856 DOES EACH EMPLOYEE UNDERSTAND AND PERFORM THE ASSIGNED
WELL-CONTROL OR PRODUCTION SAFETY DUTIES?
• Authority: 30 CFR 250.1503(a) 30 CFR 250.1507(c)
• Enforcement Action: W/C 30 CFR 250.1507(d)
• INSPECTION PROCEDURE: Verify that lessee’s training plan provides a process to ensure that employees understand and can perform their assigned well-control or production safety duties. Verify (either through written, hands-on, or oral testing) that employees understand and can perform their assigned well-control or production safety duties.
• IF NONCOMPLIANCE EXISTS: Issue one warning (W) INC for an audit of one or more employees if the training plan fails to provide a process to ensure that employees understand and can perform assigned well-control or production safety duties. Issue one component shut-in (C) INC for one or more employees that fail to demonstrate either through written, hands-on, or oral testing, their ability to perform the assigned well-control or production duties.
• Note: The employee is the component.
• INSPECTION COUNT/INC COUNT: Enter one item checked/issue on INC per training plan audited.
Discussion, Questions, Comments, Opinions…
Phone: (703) 787-1033
Phone: (504) 736-3249
THANK YOU !!!