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Title: SUBPART O TESTING PUBLIC WORKSHOP David Dykes Joe Levine


1
SUBPART O TESTING PUBLIC WORKSHOPDavid
DykesJoe Levine
  • February 19, 2009
  • New Orleans

2
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

3
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

4
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

5
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

6
What Subpart O Testing Is
  • Another data point for MMS industry to use to
    assess the effectiveness of a companys 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

7
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

8
Subpart O Testing Regulations
9
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.

10
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.

11
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).

12
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

13
Subpart O Testing History
14
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

15
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

16
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

17
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

18
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

19
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

20
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

21
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

22
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

23

24
(No Transcript)
25
Testing
  • After evaluating how interviews and audits
    work/dont 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

26
SUBPART OPILOT TESTING PROCESS
27
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

28
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

29
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

30
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)

31
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

32
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

33
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

34
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)

35
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

36
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

37
PILOT TESTING PROGRAM RESULTS
38
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

39
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

40
Companies Tested During Pilot
  • Devon/Diamond
  • ExxonMobil/HP
  • 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

41
Pilot Test Breakdown by MMS Region
  • Total tests conducted during pilot
  • Gulf of Mexico - 129
  • Pacific - 7
  • Alaska - 0

42
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

43
Pilot Written Well Control Tests
44
PILOT WRITTEN WELL CONTROL TEST AGRADE
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
45
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
46
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
47
PILOT WRITTEN WELL CONTROL TEST A
48
PILOT WRITTEN WELL CONTROL TEST B
49
PILOT WRITTEN WELL CONTROL TEST C
50
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

51
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

52
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)

53
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

54
WELL CONTROL WRITTEN PILOT TESTS AREAS OF CONCERN
  • L1L2L3 (toolpusher, company man)
  • Calculations (only test w/ calculations)
  • P1V1P2V2
  • sacks Barite to increase MW
  • circulating pressures
  • equivalent mud weight
  • MMS regulations
  • diverter vent line OD (bottom founded, floater)
  • directional requirements (inclination, azimuth)

55
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

56
Pilot Written Production Tests
57
PILOT WRITTEN PRODUCTION TEST AGRADE
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
58
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
59
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
60
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
61
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
62
PILOT WRITTEN PRODUCTION TEST A
63
PILOT WRITTEN PRODUCTION TEST B
64
PILOT WRITTEN PRODUCTION TEST C
65
PILOT WRITTEN PRODUCTION TEST D
66
PILOT WRITTEN PRODUCTION TEST E
67
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)

68
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)

69
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?

70
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)

71
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)

72
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?

73
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)

74
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
  • Dont 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 shouldnt be announced
  • Tests identify items I am weak in

75
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

76
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

77
What's Next?Testing Beyond Pilot
78
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

79
Who Will MMS Test ?
  • Possible test candidates
  • Operator
  • Contractor
  • Companies picked _at_ 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

80
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

81
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 IMs
  • No time limit for test

82
Post-Pilot Testing Procedure - Basics
  • No set number of tests to be conducted by MMS
    during a year
  • If we conduct test _at_ 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

83
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

84
Post-Pilot Testing Procedure
  • Enforcement
  • If employee fails written test (lt 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)

85
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

86
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 ??

87
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 lessees
    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.

88
Discussion, Questions, Comments, Opinions
  • Joseph.Levine_at_mms.gov
  • Phone (703) 787-1033 David.Dykes_at_mms.gov
  • Phone (504) 736-3249
  • THANK YOU !!!
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