SEMS Element #7- Training- What is periodic?

I get asked frequently, “What is the definition of periodic?”. Well the actual definition of periodic, in relation to training, is located in the 30 CFR 250.1500 Subpart O- Well Control and Production Safety Training:

 § 250.1500 Definitions

Periodic means occurring or recurring at regular intervals. Each lessee must specify the intervals for periodic training

and periodic assessment of training needs in their training programs

For those of you that have many years offshore on the OCS, you know that Subpart O training has been around for numerous years. Read below 30 CFR 250.1503(c):

§ 250.1503 What are my general responsibilities for training?

(c) You must have a training plan that specifies the type, method(s), length, frequency, and content of the training for your employees. Your training plan must specify the method(s) of verifying employee understanding and performance. This plan

must include at least the following information:

(1) Procedures for training employees in well control, deepwater well control, or production safety practices;

(2) Procedures for evaluating the training programs of your contractors;

(3) Procedures for verifying that all employees and contractor personnel engaged in well control, deepwater well control, or production safety operations can perform their assigned duties;

(4) Procedures for assessing the training needs of your employees on a periodic basis;

(5) Recordkeeping and documentation procedures; and

(6) Internal audit procedures.

You see that it is very similar in structure to what SEMS (Subpart S) and API RP 75 section 7 training requirements are.  So if your company has been conducting operations on the OCS and has not developed a training program similar to what is now required, you have actually been out of compliance. SEMS widens the scope of the required training to include each positions role and responsibilities. The training required for these roles and responsibilities must be performed and the person assessed periodically.

The 30 CFR 250.1915 goes a little further to define how often periodic shall be:

§ 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.

(b) Periodic training to maintain understanding of, and adherence to, the current operating procedures, using periodic drills, to verify adequate retention of the required knowledge and skills.

How would you determine this? That would depend on a few factors, one of which would be regulatory requirements (T4, T2, etc.). Many of the training requirements mentioned in 30 CFR Subpart O, API RP 75 sections 7.2.1 and 7.2.2 have minimum timeframe training requirements. So that would become the definition of periodic for those items. However, you could require more frequent training for those items if the periodic drills (competency assessments) determine that more training is needed.  Another determining factor is your job hazard analysis. If for instance your training program requires so many of hours on a particular piece of machinery to qualify for refresher training in lieu of a complete training course and you have employees that move from location to location which are incapable of accruing the needed hours, then those employees may be subject to taking the complete course and the related assessment each year, per say. Another determining factor would be your required management system annual review as per 30 CFR 1909(d).