SEMS Element #7- Training- Training Components

• § 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.

We know by reading the requirement above that SEMS requires you to establish and implement a training program. We also know that the 30 CFR 250.1915 goes onto say that this training must address operating procedures, safe work practices, and emergency response and control measures. In section 30 CFR 1915(a) it states:

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

(a) Initial training for the basic wellbeing of personnel and protection of the environment, and ensure that persons assigned to operate and maintain the facility possess the required knowledge and skills to carry out their duties and responsibilities, including startup and shutdown.

The API RP 75 section 7.2.1 gives a descriptive listing of what these initial training requirements may be. It indicates some or all of the following training may be required for personnel going offshore. Some of the items in the list may not apply to all personnel, it ultimately depends upon the job hazard analysis you conducted for each position and the training requirements as a result of that.

1. API RP T1 First Time Orientation Program
2. API RP T4 Non-Operating Emergencies
3. API RP T7 Training of Personnel for Water Rescue
4. API RP 14G Fire Prevention and Control
5. Safe Work Practices (e.g., Hot Work, Hot Tapping, Safe Entry, Lock Out/ Tag Out)
6. Simultaneous Operation Planning
7. Hazard Communications
8. Trained as per Government Regulations

The API RP 75 section 7.2.2 gives a descriptive listing of what training requirements may be for operating and maintenance personnel.

1. API RP T2 Production Personnel Whom Work with Anti-Pollution and Safety Devices
2. API RP 2D Crane Operation and Maintenance
3. API RP T6 Well Control Equipment related to Completions and Well Workover Operations
4. API RP 59 Well Control Operations
5. API RP 49 Drilling and Well Servicing Operations Involving H2S
6. API RP 55 Producing Wells Involving H2S
7. All personnel are to be trained in environmental protection and pollution control.

The NTL 2011-N09 SEMS Guidance document provides further clarification and addresses 30 CFR 250.1500 SubPart O training requirements. Subpart O training requirements aren’t as clearly defined as what the API RP 75 lays out. See the SubPart O requirement below:

• § 250.1501 What is the goal of my training program?

you must ensure that your employees and contract personnel engaged in well control, deepwater well control, or production safety operations understand and can properly perform their duties.

What does all of this mean? Well as I have stated in previous SEMSinars™, ultimately it comes down to what you identify as the hazards related to your operations, the training you determine to be required and the frequency of drills required to verify competency by each position. The NTL SEMS Guidance document previously mentioned states:

The training requirements in a SEMS program will normally exceed those included in subpart O because they apply to all personnel and all activities, not just well control and production safety activities.

Let us not forget 30 CFR 250.1909(f) that states:

• § 250.1909 What are management’s general responsibilities for the SEMS program?

(f) Utilize personnel with expertise in identifying safety hazards, environmental impacts, optimizing operations,

developing safe work practices, developing training programs and investigating incidents.

Please attend the SEMSinar™ Part 3 to find out what the differences are between regulatory training requirements and your required training.