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
• 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 subcontractor 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 handson 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 handson 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 handson well control scenarios received by agency
• MMS provided work group overview of how pilot
Subpart O testing program could work moving
forward
October, 2008
Diamond 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
INFORMAL EMPLOYEE INTERVIEW’S
(2002 – 2008 YTD)
740
800
699
651
700
600
486
493
500
400
300
200
45
100
91
5
0
4
10
15
2
1
0
2002
2003
2004
2005
Informal Employee Interviews
2006
2007
2008
Unfavorable Interviews
SUB O AUDITS & INCs
(2002 – 2008 YTD)
50
40
30 29
26
27
30
18
20
19
18
20
10
10
4
7
6
2
0
2002
2003
2004
Audits Conducted
2005
2006
2007
2008 ytd
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 O
PILOT 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
Pilot Written Well Control
Tests
Number of Tests
14
12
10
8
6
4
2
0
A
L1
A
L1
A
L2
L1
B
L2
L
3
L1
B
L1
B
L2
Test Type
L1
C
L2
L
3
L1
C
L1
C
L2
L1
L2
l
3
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
60
* Failures (less than 70% noted in red)
40
80
Tests Given
Average Grade
7
6
11
87.6
76
69.1
PILOT WRITTEN WELL CONTROL
TEST “B” GRADE DISTRIBUTION*
L1,L2,L3
* Failures (less than 70% noted in red)
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
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*
* Failures (less than 70% noted in red)
L1,L2,L3
L1,L2
L1
65
64
40
90
64
80
60
73
80
45
64
20
95
64
40
75
64
40
90
37
40
70
55
40
80
40
40
0
0
Tests Given
Average Grade
9
8
12
74
61
42
PILOT WRITTEN WELL CONTROL
TEST “A”
Avg Yrs, Avg Score, Times Taken
100
88
76
80
69
60
40
20
28.5
11
6.3
11.6
7
6
0
L1
Avg. Yrs. Oilfield Experience
L1L2
Avg. Score (% )
L1L2L3
# Times Test Taken
PILOT WRITTEN WELL CONTROL
TEST “B”
Avg Yrs, Avg Score, Times Taken
100
86
84
79
80
60
40
20
29.6
14
6.3
12
10
9
0
L1
Avg. Yrs. Oilfield Experience
L1L2
Avg. Test Score (% )
L1L2L3
# Times Test Taken
PILOT WRITTEN WELL CONTROL
TEST “C”
Avg Yrs, Avg Score, Times Taken
100
74
80
61
60
42
40
20
28
12
6
11
9
8
0
L1
Avg. Yrs. Oilfield Experience
L1L2
Avg. Test Score (% )
L1L2L3
# 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
Pilot Written Production Tests
Number of Tests
7
6
5
4
3
2
1
0
A
L1
A
A
B
B
B
C
L1
L1
L1
L1
L1
L
L2
L2
L2
L2 1
L3
L3
C
C
D
L1
L1
L
L2
L2 1
l3
Test Type
D
E
D
L
L1
L1
L2
L2 1
L3
E
E
L1
l
L 2 1L 2L
3
PILOT WRITTEN PRODUCTION
TEST “A”GRADE DISTRIBUTION
L1,L2,L3
L1,L2
L1
74
75
80
88
82
92
4
2
2
85
78.5
86
86
92
Tests Given
Average Grade
PILOT WRITTEN PRODUCTION
TEST “B” GRADE DISTRIBUITION
L1,L2,L3
L1,L2
92
L1
77
90
90
76
76
86
92
Tests Given
Average Grade
7
1
0
86
77
NA
PILOT WRITTEN PRODUCTION
TEST “C” GRADE DISTRIBUTION
L1,L2,L3
L1,L2
80
L1
91
86
3
1
1
88.7
91
86
92
94
Tests Given
Average Grade
PILOT WRITTEN PRODUCTION
TEST “D” GRADE DISTRIBUTION
L1,L2,L3
L1,L2
86
L1
84
83
3
1
1
90
84
83
96
88
Tests Given
Average Grade
PILOT WRITTEN PRODUCTION
TEST “E” GRADE DISTRIBUTION
L1,L2,L3
L1,L2
L1
80
91
92
89
94
Tests Given
Average Grade
3
2
0
88.7
90
NA
PILOT WRITTEN PRODUCTION
TEST “A”
Avg Yrs, Avg Score, Times Taken
100
86
85
79
80
60
40
20.75
17.5
20
2.25
2
4
2
0
L1
Avg. Yrs. Oilfield Experience
L1L2
Avg. Test Score (% )
L1L2L3
# Times Test Taken
PILOT WRITTEN PRODUCTION
TEST “B”
Avg Yrs, Avg Score, Times Taken
100
86
77
80
60
40
15.2
20
10
0
0
0
7
1
0
L1
Avg. Yrs. Oilfield Experience
L1L2
Avg. Test Score (% )
L1L2L3
# Times Test Taken
PILOT WRITTEN PRODUCTION
TEST “C”
Avg Yrs, Avg Score, Times Taken
100
91
86
89
80
60
40
19
18
20
1.5
1
3
1
0
L1
Avg. Yrs. Oilfield Experience
L1L2
Avg. Test Score (% )
L1L2L3
# Times Test Taken
PILOT WRITTEN PRODUCTION
TEST “D”
Avg Yrs, Avg Score, Times Taken
100
90
83
84
80
60
40
19
18
20
1.5
1
3
1
0
L1
Avg. Yrs. Oilfield Experience
L1L2
Avg. Test Score (% )
L1L2L3
# Times Test Taken
PILOT WRITTEN PRODUCTION
TEST “E”
Avg Yrs, Avg Score, Times Taken
100
90
89
80
60
40
21
14
20
0
0
3
2
0
0
L1
Avg. Yrs. Oilfield Experience
L1L2
Avg. Test Score (% )
L1L2L3
# 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 wellcontrol 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…
Joseph.Levine@mms.gov
Phone: (703) 787-1033
David.Dykes@mms.gov
Phone: (504) 736-3249
THANK YOU !!!