Training of Lessee and Contractor Employees Engaged in Oil and Gas and Sulphur Operations in the Outer Continental Shelf (OCS)

DEPARTMENT OF THE INTERIOR

Minerals Management Service

30 CFR Part 250

RIN 1010-AB99

Training of Lessee and Contractor Employees Engaged in Oil and

Gas and Sulphur Operations in the Outer Continental Shelf (OCS)

AGENCY: Minerals Management Service, Interior.

ACTION: Advance notice of proposed rulemaking.

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SUMMARY: The Minerals Management Service (MMS) intends to revise

regulations governing the training of lessee and contractor employees

engaged in drilling, well-completion, well-workover, well-servicing, or

production operations in the OCS. Current requirements may restrict the

ability of companies to use new technology and innovative programs to

meet the needs of a changing industry. The revisions will attempt to

provide more flexibility to companies and provide them with the ability

to better integrate their training program into their overall

operations.

DATES: Comments should be received or postmarked by September 19, 1994

to be considered for this rulemaking.

ADDRESSES: Mail or hand-carry comments to the Department of the

Interior; Minerals Management Service; Mail Stop 4700; 381 Elden

Street; Herndon, Virginia 22070-4817; Attention: Chief, Engineering and

Standards Branch.

FOR FURTHER INFORMATION CONTACT:

Jerry Richard, Information and Training Branch, telephone (703) 787-

1582 or FAX (703) 787-1575.

SUPPLEMENTARY INFORMATION: Section 3 of the OCS Lands Act establishes

that operations in the Outer Continental Shelf should be conducted in a

safe manner by well-trained personnel using technology, precautions,

and techniques sufficient to prevent or minimize the likelihood of

blowouts, loss of well control, fires, spillages, physical obstruction

to other users of the waters or subsoil and seabed, or other

occurrences which may cause damage to the environment or to property,

or endanger life or health. (43 U.S.C. 1332)

The MMS implements this authority largely through the establishment

and enforcement of the regulations in 30 CFR part 250, Subpart O,

Training. These regulations require that lessees and contractors

properly train employees engaged in drilling, well-completion, well-

workover, well servicing, or production operations in the OCS. Current

training requirements include the proper operation of equipment,

operating procedures, and techniques to avoid hazards to people,

property, and the environment.

This training takes place at MMS approved training schools. To

obtain MMS approval, training schools submit all training programs to

MMS for approval. The MMS reviews the program for compliance with

requirements of the regulations and conducts an onscene review of a

class and training equipment. Based on the findings, MMS either

certifies that the school meets MMS requirements or informs the

training company of the deficiencies. Once a school is approved, MMS

conducts unannounced audits of classes to ensure that the schools

continue to comply with the regulations.

Workers must successfully complete an approved course in the

appropriate area (e.g., drilling well control) and then must repeat the

basic course or an advanced course once every 4 years. Additionally,

drilling, well-completion, well-workover, and well-servicing workers

must successfully complete a well control refresher course each year

between the required basic courses. Production workers must

successfully complete a refresher course 2 years after completion of

the basic course.

The existing regulations at 30 CFR part 250, Subpart O, Training,

determine the content and set the length of courses. These are either

basic, advanced, or refresher courses in drilling, well completion,

well workover, well servicing, or production safety systems. Drilling,

well-completion, and well-workover courses include an option for

surface or subsea operations. Well servicing is a term used to refer to

coil tubing, small tubing, and snubbing operations. Courses may address

one of the well-servicing areas, a combination of two of the areas, or

all three areas.

Although MMS has never done so, the existing regulations allow MMS

to test workers at the worksite or trainees at the training facility to

evaluate the effectiveness of the approved training programs.

The MMS established minimum requirements for training of drilling

operation workers in December 1977. For production operation workers,

MMS established fewer minimum requirements leaving more latitude to the

training companies to determine what a training course would include

and how often courses would be repeated.

Some production companies developed training programs for

production workers that provided training at a level equivalent to that

mandated for drilling. Other production companies developed minimal

courses and did not require their workers to repeat training on a

periodic basis. In January 1991, MMS expanded the training provisions

to establish requirements for well-completion, well-workover, well-

servicing, and production operation workers which were similar to

requirements for drilling operation workers.

The current system ensures that minimum standards are met by all

workers in the OCS and requires submittal of training courses from

schools to MMS for review and approval. The MMS reviews plans and

attends one of the courses to ensure that the course properly

implements the submitted plan. While the system has provided for the

training of offshore workers, it may also limit the flexibility

available to lessees and contractors and their ability to integrate

their training requirements into their overall safety program.

The MMS is seeking ways to ensure that lessees and contractors

continue to properly train offshore workers, while reducing paperwork

and providing more flexibility. This notice is the first step in that

process. To help generate comments, MMS has identified five approaches

to modifications of the regulations--listed below as options 1 through

5. Questions follow each option to solicit specific information. These

options and questions are intended to provide a basis for comments and

are not intended to limit ideas. In addition to comments on the five

options and answers to questions, interested parties are encouraged to

submit other approaches which will meet the needs of MMS and of lessees

and contractors, other ideas, and any available information to support

the ideas.

Option 1. The MMS is aware of other training standards based solely

on testing. Under Option 1, MMS would eliminate its current system of

school certification in favor of a more performance-based system and

measure the performance of the school through testing of students. The

system could either provide for testing by schools, testing by an

independent third party, or testing by MMS.

1. If approach 1 is used, how can MMS measure the performance of a

school? Are written tests and hands-on testing conducted at a facility

the best way to measure performance of schools?

2. If MMS-developed tests are used to determine performance, should

tests be prepared by MMS and administered either by schools or by an

independent third party, or should the tests be developed and

administered by MMS?

3. Are there aspects of training that need to be included but

cannot be adequately tested?

Option 2. As with option 1, MMS would eliminate its current system

of school certification in favor of a more performance-based system.

This would require MMS to assess the ability of a worker to safely

perform in the OCS. This option might include testing of personnel at

an offshore location (including use of a simulator) or the use of

drills with MMS personnel observing the actions of workers during these

drills. If deficiencies are found, MMS would require lessees and

contractors to determine the changes needed to provide for safety in

the OCS. Changes may include more training, better training, better

simulators and training facilities, or different operational conditions

that better match the training to the operation. Identifying

deficiencies in a given school would then be the responsibility of the

lessees and contractors.

4. What methods should MMS use to assess the effectiveness of the

training that has been received by offshore personnel?

5. Is testing at the worksite practical? Is it a good measure of

the effectiveness of training? Should individuals or teams be tested?

6. If MMS specialists are used to observe operations and to

determine the need for further training of personnel, can the process

be sufficiently objective to be fair to lessees and contractors?

Option 3. Under option 3, MMS would retain the current training

system--i.e., submission of programs to MMS for review and approval and

onsite review of programs by MMS personnel--but would modify

requirements, where possible, to replace prescriptive requirements with

performance requirements. In other words, standards would attempt to

specify the performance that was necessary rather than specifying

detailed requirements for courses. If MMS chooses this option, lessees,

operators, and training institutions need to identify possible changes

to the current regulations.

7. What specific changes should MMS make to current training

regulations contained in 30 CFR part 250, Subpart O, Training?

8. Individualized or self-paced training programs allow each worker

to learn at his or her own pace and allows training to be customized to

meet a worker's specific need. The availability of computers and the

rapid development of interactive computer technology may make

individualized, self-paced training more effective. Since responding to

emergencies during drilling or other operations is a team effort,

interaction between personnel has always been an important aspect of

training and drills. Does individualized training impede the ability of

a worker to learn to work as a member of a team? Should MMS allow the

use of individualized training (such as in an interactive computer

format) as a means of complying with these training requirements, and

if so, how should MMS ensure that workers are properly trained in

working as a team member?

Option 4. Under option 4, an independent third party would certify

training institutions using MMS standards or standards established by

other organizations. The third party could establish a program for the

United States, or it could establish an international program. Workers

who completed a training course at a school approved by the third party

would be considered to be properly trained for work in the OCS. The MMS

would review the standards established to ensure the system established

properly addressed areas of concern to MMS.

9. Should a single independent third party be the only group that

could certify training schools or should MMS establish a system that

allows other groups to establish alternative training certification

programs?

10. Under current training requirements, courses cover MMS

regulations as part of the required curriculum. Will having courses

approved on a broader basis make it impractical to ensure that workers

are adequately trained in MMS regulations governing OCS operations?

Opton 5. Option 5 is intended to be used in combination with one of

the other options and would provide that any lessee or operator, on a

case-by-case basis, could develop and document a training program and

petition MMS to be exempt from MMS requirements. Option 5 would take

advantage of the fact that many companies are developing safety and

environmental management plans. The objective of a safety and

environmental management program is to reduce the risk of accidents and

pollution from OCS operations by incorporating safety management

practices into facility management and procedures. A safety and

environmental management program could describe the syllabus and

responsibilities of a company's training program and provide the means

for ensuring compliance with MMS regulations. If MMS approved the

company's program, MMS would use that program as a standard and would

require that the company follow its own program.

11. If MMS allows companies to develop their own training program,

how will MMS monitor performance?

12. If MMS allows companies to develop their own training program,

would problems occur if a worker transfers from one company to another?

The MMS seeks responses to the questions and an assessment of which

option is considered to be the most effective and efficient. After

analyzing the comments received from this notice, MMS will determine

the need for a public workshop to further exchange ideas. The MMS

encourages all interested parties to respond to these questions and to

provide comments on the various options.

Dated: July 22, 1994.

Nancy K. Hayes,

Acting Assistant Secretary, Land and Minerals Management.

[FR Doc. 94-19127 Filed 8-4-94; 8:45 am]

BILLING CODE 4310-MR-M