[Federal Register Volume 59, Number 150 (Friday, August 5, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-19127]
[[Page Unknown]]
[Federal Register: August 5, 1994]
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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
