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Last Updated:
   03/28/2006
   07:04 AM

Question – 10/23/02:  Is the Subpart O Lessee Training Plan a public document?

MMS Reply:  No, the Lessee Training Plan is not a public document.  According to 30 CFR 250.1503 (c) (2), “Upon request of the Regional or District Supervisor, you must provide: A copy of your training plan.”   Under normal circumstances, lessees are not required to submit their plan to the MMS.  Exceptions include when MMS requests to see the plan as part of an MMS conducted audit or when deficiencies in the lessees training program have been identified.  Under no circumstances does MMS approve the Lessee Training Plan.  In all cases, after MMS has had an opportunity to review the plan, it is returned to the lessee. 

Question – 10/23/02:  Are Letters of Compliance and Non-Compliance (Appendices H and J, respectively in the Subpart O Guidance Document) public documents?

MMS Reply:  No, Letters of Compliance and Non-Compliance are not public documents.  Subpart O regulations do not require that MMS issue Letters of Compliance or Non-Compliance.  They are issued as a courtesy to a lessee after completion of an MMS audit. 

Question - 10/22/02:  Are casing crews covered under the new Subpart O regulations?

MMS Reply:  All employees who are assigned well control or production safety duties are subject to the requirements of Subpart O.

Question – 09/20/02: I am requesting information on MMS required training for specific occupations in the oil and gas extraction industry and also for service occupations whose work is done on oil and gas platforms. If MMS does not have requirements or recommendations, is there an industry recognized and MMS recognized industry organization that does have requirements or recommendations?

MMS Reply:  According to MMS's current Subpart "O" Performance Training Rule which went into full effect on October, 15, 2002, lessee's are free to develop and implement a variety of training techniques for their employees as long as they are included in their Lessee Training Plan.  The subject rule only applies to lessees involved in well control and production safety system activities. Lessees are also required to have procedures in their Training Plan to evaluate and verify the training of their contractors.

One possible option for a lessee to follow in meeting the intent of Subpart "O" would be to use the International Association of Drilling Contractors (IADC) Well Control Accreditation Program (WellCap) for their well control (drilling, workover, and well servicing) training needs.  WellCAP has an established core curriculum, has been in existence for a number of years, and includes training schools worldwide. 

Additionally, the American Petroleum Institute (API) has developed a certification program for any type of training that you may seek certification for.  This program is called the API Training Provider Certification Program (TPCP).  There maybe other certification programs available to the oil and gas industry in addition to the programs referenced above.

Question – 09/23/02:  Does Sub O apply to well servicing?  There is some confusion over the well control definition part of the rule.   

MMS Reply:  Yes, Subpart O does apply to well servicing.  See the definition of well control at 30 CFR 250.1500 to clear up any confusion on this issue.

Question – 09/23/02:  Will MMS hire more inspectors or use third parties to assist with implementation of Subpart O?  What role will third parties play, if any?

MMS Reply:  At this time, there are no plans to hire additional inspectors or use third parties to implement this rule.

Question – 09/23/02:  Will District Inspectors issue Incident of Non-Compliance (INC's), or will INC’s just be issued from the Regional office?

MMS Reply:  Ordinarily, District Inspectors will not issue Subpart O INC’s. 

09/23/02:  Will District Inspectors conduct only Informal Employee Interviews or will they also participate in other Sub O auditing activities?

MMS Reply:  In the Gulf of Mexico, Pacific and Alaska Regions, District Inspectors will normally only conduct Informal Employee Interviews.  Other audit activities will be conducted under the direction of the Regional Supervisor, Field Operations. 

Question – 09/23/02:  Will there be surprise Subpart O audits or will there usually (always?) be prior notification of audits to the lessee?

MMS Reply:  Prior notification will usually (not always) be given for Subpart O audits.

Question – 09/23/02:  During a rig or platform inspection, what Subpart O documentation will MMS be looking for?  Will MMS only be looking for what the Lessee’s Training Plan requires or something more?

MMS Reply:  During a rig or platform inspection in the Gulf of Mexico, Pacific or Alaska Regions, District personnel will not be looking at Subpart O documentation.  

Question – 09/23/02:  Will contractors need to always carry training documentation?  Will rigs need to have a full set of training records?  Will manned platforms have to do the same?

MMS Reply:  Contractor requirements depend on lessee expectations, agreements and what is included in the Lessee Training Plan.

Question – 09/23/02:  If a worker stays with a company for 90 days and then leaves for another company will his records need to be kept for 5 years?

MMS Reply:  According to this rule records must be maintained for a period of five years.

Question – 09/23/02:  Our company understands the following basic MMS enforcement strategy.  Is this correct?  Field Inspectors will conduct informal interviews, check to see that there is a training plan/program in place and then hand it off to Regional Personnel.  MMS will collect other data, including INCs, incident reports, etc.

If the collected data warrants, if a serious training-related incident happens, or if a company is selected randomly, then the Region will conduct an audit.  Prior notice of this audit will be given.   If discrepancies warrant, the Region will issue INCs or take other actions.

MMS Reply:  You are partially correct.  District Inspectors in the Gulf of Mexico, Pacific and Alaska Region, will only conduct Informal Employee Interviews.  Anything else will be conducted under the direction of the Regional Supervisor, Field Operations.  Prior notification will usually (not always) be given for Sub O audits.

 Question – 12/26/01:  Our company has been sending foremen to MMS approved well control schools.  Their coordinator just informed me that as a result of internet fraud, etc, after 1/1/02, the company will no longer be using individuals’ Social Security Numbers (SSN) for identification purposes.  I know that in the past when MMS well control paperwork was managed out of Herndon, VA, the MMS included the option of issuing an MMS ID number to put on a students certification card in lieu of a SSN.  My question is this, is it still possible, and if so, who at MMS would I contact to acquire an MMS ID number?

MMS Reply:  We do not currently issue an MMS ID number.  We stopped this practice in early 2000 when we started telling industry that they no longer had to submit student training records. 

Question – 10/23/01:  If a Lessees’ Training Plan includes information on their corporate HSE policy (e.g., as an appendix item for additional information), does this information become an item that the MMS may audit the lessee on?

MMS Reply:  Yes, if this information is relevant to employees who are assigned well control or production safety duties

Question – 10/23/01:  Is there a need for a lessee to specify in its’ training plan the particular schools that will be used or is the term IADC WellCAP® accredited training schools sufficient?

MMS Reply:  The MMS does not require that a particular school be specified in the Lessee Training Plan.  However, it may be to the lessees’ advantage to specify a school in case of an audit by the MMS.

 

Question – 10/23/01:  The MMS “Subpart O” Guidance Document indicates that “an acceptable level of content” is expected for a Lessees’ Training Plan.  Could you provide some additional details?

MMS Reply:  The MMS is not willing to specify an acceptable level of content for a Lessees’ Training Plan.  However, the MMS expects the Lessees’ Training Plan to contain enough information to show how the lessee addresses the six key items that “Subpart O” requires.

 

Question – 10/23/01:  How will the MMS verify that the Lessees’ Training Plan provides a process to ensure that employees understand and can perform their assigned well control or production safety duties?

MMS Reply:  MMS will hold the lessee accountable for implementing whatever process they have included in their training plan.  To verify that the lessee has actually accomplished this, MMS may use record checks, interviews, hands-on tests, written tests, or audits.  See the MMS Subpart O Guidance Document for additional information. 

Question – 10/23/01:  If the lessee plans to independently audit the contractors’ training program, do the audit results have to be documented, maintained, and made available for inspection?

MMS Reply:  No, but the audit report may be used as verification that the lessee has procedures in their plan to verify the training programs of their contractor personnel.

 

Question – 10/23/01:  Where must documentation be located (Wellsite/Lessees’ office/Contractors’ office/Training school office)?

MMS Reply:  The lessee can specify this in their plan.  Documentation maybe in multiple locations, but according to 30 CFR 250 & 1503 (c) records must be available to the MMS. 

 

Question – 10/23/01:  Is the lessee required to have documentation verifying that employees understand and can perform their assigned duties?

MMS Reply:  Yes.  This documentation should be based on what is specified in the Lessees’ Training Plan.

 

Question – 10/23/01:  Will prior notification be given to the operator of an informal employee interview at an offshore facility?

MMS Reply:  No.  An informal employee interview may be conducted offshore during a routine MMS inspection. 

 

Question – 10/23/01:  During an MMS informal employee interview at an offshore facility, is the employee or contractor personnel competency assessed?

MMS Reply:  No.  The inspectors will utilize the Informal Employee Interview form that is included in the Guidance Document.  The questions on this form all address the company’s training program.

 

Question – 10/23/01:  Is testing at the conclusion of a training course sufficient to verify adequate retention of knowledge and skills?

MMS Reply:  If testing has been identified in the Lessee Training Plan and the lessee can demonstrate that the method works then this method can be verified as “sufficient”.

Question – 07/26/01:  What caused the MMS to draft the Subpart O regulations on well control and production safety training? Did the agency notice an increase in offshore accidents?

MMS Reply:  For many years the MMS implemented a school based OCS training program for well control and production safety activities.  This program was based on a detailed set of prescriptive regulations which lessees needed to comply with.  These requirements, as with all MMS regulations, represented the minimum standard a company must achieve.   In an effort to improve upon this standard and the overall performance of the industry, MMS drafted new performance based regulations and published them as a Final rule in the Federal Register on August 14, 2000. 

Prior to publication, MMS conducted an extensive outreach program to the OCS oil and gas industry, as well as the training community to get feedback and suggestions on how best to develop this type of system.  We are confident that this initiative will lead to safer and cleaner OCS operations by providing industry the mechanism to develop new and innovative training techniques and the flexibility to put them into practice in an effective manner.

Question – 07/26//01:  How will shifting from accrediting schools to holding offshore companies responsible for worker training help to make oil and gas operations safer?

MMS Reply:  The MMS believes that this shift in responsibility from the regulator to the oil and gas industry will allow company’s to focus their training resources on the most important areas of their program, resulting in safer and cleaner OCS operations. A significant difference between MMS overseeing a school-based training program and having a company make decisions on the type of training their workers should receive is “responsibility”.  Under the new performance system, company’s conducting well control and production safety operations on the OCS will be responsible for determining and implementing appropriate training programs for their employees.  This will require company management to evaluate a wide range of options in developing their programs, and make a decision on how to best achieve improved performance.

Question – 07/26/01:  Are the new Subpart O regulations meant to reduce operator error?

MMS Reply:  As previously stated, the new Subpart O regulations are meant to provide for safer and cleaner OCS operations.  It is the hope of the MMS that these regulations along with other aspects of our regulatory program will contribute to minimizing human error and improving the overall management of OCS operations

Question – 09/06/00:  In reviewing NTL No. 2000-N03 - Clarification of 30 CFR 250, Subpart O – Well Control and Production Safety Training, I have a question concerning implementation. "Are we subject to the timetable of each of our customers as to when we can switch to the new Subpart O?  Also, do we have to train our employees at the discretion of each operator customer?  If the answer is yes, then am I to assume that I must run our training program to meet the needs of our 30 or so customers' in the GOM as well as meet their different timetables as to when each goes to the new Subpart O?” 

MMS Reply:  As you have pointed out, your company may have to address some differences between Lessees’ Training Plans.   We are hopeful that you and your customers will work out a reasonably timetable that both of you can live with.  We cannot predict if different lessees will require you to modify your training program to address company specific issues.

Question – 04/19/00:  Do service personnel need to be trained according to 30 CFR Part 250, Subpart O--Training, §250.1506(a) if they are installing or servicing electronic submergible pumps,  or troubleshooting and repairing the related electronic peripherals such as drives switchboards, and transformers? 

MMS Reply:  Service personnel do not have to be qualified in accordance with §250.1506(a) if the service personnel are working on equipment supplied by the company (e.g., electronic submergible pumps), provided the service personnel have received training and are qualified by his/her company to install, service, or repair the specific piece of equipment or device, and if the service personnel are accompanied by an individual who is trained under Section §250.1506(c).  This individual must maintain direct supervision of the operation being conducted and must be capable of evaluating the impact of the work done by the service personnel on the total system.

Question – 08/25/99:  If an employee is trained outside of the Continental United States is that training recognized by the MMS? 

MMS Reply:  Yes, the training will be recognized by the MMS provided it is included in the Lessee Training Plan.

Last changed: 03/28/06