What are SEMS training requirements?

As stated in the SEMS notice to lessee guidance document NTL 2011-N09, an operator’s SEMS program may include the elements of their 30CFR 250.1500 Subpart O- Well Control and Production Safety Training. The NTL additionally states SEMS training requirements will normally exceed those Subpart O training requirements. I strongly recommend that the items listed below are also used to determine training needs for each job description or position.

1)      Facility Hazard Analysis

2)      Job Hazard Analysis (Used to develop Job Description)

3)      Procedure Hazard Analysis (Used to develop Job related procedures)

4)      Policy Hazard Analysis (Used to develop Job related procedures)

5)      Regulatory training requirements

SEMS section 30CFR 250.1915 specifically indicates the following training requirements:

§ 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. Training must address the operating procedures (§ 250.1913), the safe work practices (§ 250.1914), and the emergency response and control measures (§ 250.1918).

Section 30CFR 250.1915(a) indicates the following required training:

§ 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.

While section 30CFR 250.1915(b) refers to periodic training requirements:

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

(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.

You probably are asking “What is the definition of periodic?”. Well, periodic is defined by your management system. Of course some training will be required more often than others, but that will be determined by a number of factors such as regulatory requirements, related hazard analysis and so on. The definition of periodic may change for certain training subjects if near miss hazard analysis or incident investigations or even employee performance reviews determine the required frequency to change.

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

(c) Communication requirements to ensure that whenever a change is made to procedures, work practices, control measures, etc.; personnel will be trained in or otherwise informed of the change before they are expected to operate the facility.

The above requirement should be part of your management of change process. If it is not, I urge you to update this process.

There are a number of ways to address the following requirement related to competency assessment. The degree of assessment needed depends on the level of hazard associated with the job description. IADC has a Knowledge, Skills and Ability assessment tool that works for many positions. ISO also has some standards available. You, through your management will have to determine what will work best for the company.

We hope to you will attend our 10 part SEMSinar™ series where we will discuss further the issues that interest you most. Each SEMSinar™ will be followed by a Q&A.