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Lessee Performance-Based Training Program

Background

The Office of Offshore Regulatory Programs (OORP) is responsible for program oversight and coordination of MMS’s Subpart "O" lessee and operator training program. To ensure that OCS oil and gas operations emphasize operational and environmental safety, lessees must employ highly qualified and trained personnel. The MMS has developed and implemented training regulations since the late 1970’s. Initially, training was required for key personnel in drilling well-control and production safety systems. In the late 1980’s, MMS promulgated new requirements for well-completion, well-workover, and well-servicing operations as well as revising regulations for drilling and production safety systems.

On August 14, 2000, MMS promulgated a performance-based rule that holds lessees accountable for developing and implementing their training programs. This new regulation which became effective on October 15, 2002, calls for each lessee to prepare a training plan laying out the company’s training philosophy including the type, method, length, frequency, and content of their training program. The MMS will use a series of performance measures to periodically assess the quality of lessee and contractor training programs. Such assessments may include one or more of the following evaluation methods:

	Audits
	Written tests
	Hands-on test
	Employee interviews

These measures are discussed in detail in the MMS Guidance Document. This is a living document and is periodically updated. (251 KB PDF File)

Current Status

To date, MMS’s performance based Subpart O training program has been in effect for 6 years. During this period, MMS has generated a variety of program data to help gauge the effectiveness of the program and to identify areas of concern which should be targeted for improvement.

Between January 15, 2007 and January 15, 2008, MMS conducted 710 Employee Contractor Interviews resulting in 2 unfavorable and 14 poor ratings. Thirty formal audits were performed resulting in the issuance of 30 citations for an Incident of Non-Compliance (INC). Some operators were found to have developed only bare minimum training programs for production operations.

In response to the problems identified during the audit process, MMS initiated the following:

	Issued a National NTL that was published on March 31, 2008, to clarify the requirements under the regulations such as   what contractors are covered what does periodic training mean; frequency of assessment or skill verification Production safety definition as to what training needs to be conducted as part of this requirement.
	Began the process of adding four technical clarifications to the exiting regulations (to be processed as part of a series of technical amendments to the regulations). Target date for publishing a proposed rule is September 2008.

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Last Updated: 10/16/2008, 08:51 AM