SEMS Element #7- Training- Competency Management

For this blog subject, I would like to discuss how to verify an understanding and adherence to the current operating procedures. This can be done by initiating a competency assessment program that contains procedures for educating your personnel in the procedures related to each position. For instance, a class or online training module can be developed to teach all employees associated with the management of change procedure. Then the personnel would be required to be tested, or drilled, on the procedure to determine if they have the competency to perform that function. Why, may you ask, do I mention management of change when 30 CFR 250.1915 doesn’t mention management of change? Well, read the CFR requirement as it is written:

• § 250.1915 What criteria for training must be in my SEMS program?

Your SEMS program must establish and implement a training program so that all personnel are trained to work safely and are aware of environmental considerations offshore, in accordance with their duties and responsibilities.

The main thing to pay attention to is the statement related to their duties and responsibilities. If that position requires them to be part of the management of change procedure or process, then they are required to be trained and assessed on it. So you can see how you are now required to train your personnel in all aspects of your management system and then assess, or drill, them on it to confirm an understanding and adherence to your management system, or law. This applies to both offshore and office personnel whom work on OCS activities.

Now let’s discuss contractor competency management. How you approach this subject depends on if your contractors are utilizing your management system or their own as determined by your bridging document. The operator is responsible for verification of contractor training, either through providing the training and assessments or through a verification process. 30 CFR 250.1915(d) states:

• § 250.1915 What criteria for training must be in my SEMS program?

(d) How you will verify that the contractors are trained in the work practices necessary to perform their jobs in a safe and environmentally sound manner

The API RP 75 section 7.5 refers to Appendix A which indicates API RP 76 Contractor Safety Management to be a useful resource. I would highly recommend utilizing this recommended practice for guidance. Your management system, or law, may require more than this recommended practice. Appendix A goes on to list some specific performance information be collected from your contractors such as:

1. An endorsed copy of the contractor’s written safety and environmental policy.
2. A commitment statement from the contractor to adhere to all applicable safety and environmental regulations as well as the provisions of the API RP 75.
3. Injury and Illness log for the past 3 yrs.
4. Contractors initial employee safety orientation.
5. Description of the contractor’s safety programs such as but not limited accident investigation, HSE inspections, safety meetings, substance abuse testing, mechanical integrity.
6. Contractors training program
7. Contractors short service employee program
8. Contractors involvement in industry affairs