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SUBPART O TESTING PUBLIC WORKSHOP David Dykes Joe Levine. February 19, 2009 New Orleans. WORKSHOP AGENDA. Subpart O Testing Regulations Subpart O Testing History Subpart O Pilot Testing Process Subpart O Pilot Test Results Testing Beyond Pilot Discussion, Q & A. WORKSHOP GOAL.

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workshop agenda
WORKSHOP AGENDA

Subpart O Testing Regulations

Subpart O Testing History

Subpart O Pilot Testing Process

Subpart O Pilot Test Results

Testing Beyond Pilot

Discussion, Q & A

workshop goal
WORKSHOP GOAL
  • To explain
    • What Subpart O testing is all about
    • Eliminate unwarranted concerns
    • How MMS & industry can use testing to help raise the level of OCS safety
can testing benefit your company
Can Testing Benefit Your Company?
  • An extra set of “eyes” evaluating your personnel
  • Additional assessment of employees between regularly scheduled training
  • If an area of concern is uncovered by testing you have the opportunity to address it
what subpart o testing is not
What Subpart O Testing Is Not
  • A quantitative measure of an employees’
    • Competency or knowledge of job
    • Ability to perform their job
    • Passing a test does not mean an employee knows their job
    • Failing a test does not mean an employee can not do their job
what subpart o testing is
What Subpart O Testing Is
  • Another data point for MMS & industry to use to assess the effectiveness of a company‘s Subpart O training program and overall safety management system (SEMS, SEMP….)
  • An opportunity to gain additional feedback on how well “you” are getting critical job related information across to your most important asset; your people
subpart o overriding principles
Subpart O Overriding Principles
  • Testing, as with other aspects of Subpart O is aimed primarily at the lessee
  • Testing will impact not only lessees, but contractors as well
  • It is the lessees responsibility to ensure their contractors can properly perform their assigned duties
30 cfr 250 1507 c
30 CFR 250.1507 (c)

c) Employee or contract personnel testing

MMS or its authorized representative may conduct testing at either onshore or offshore locations for the purpose of evaluating an individual's knowledge and skills in performing well control and production safety duties.

30 cfr 250 1507 d
30 CFR 250.1507 (d)

(d) Hands-on production safety, simulator, or live well testing

MMS or its authorized representative may conduct tests at either onshore or offshore locations. Tests will be designed to evaluate the competency of your employees or contract personnel in performing their assigned well control and production safety duties. You are responsible for the costs associated with this testing, excluding salary and travel costs for MMS personnel.

30 cfr 250 1508
30 CFR 250.1508

What must I do when MMS administers written or oral tests?

MMS or its authorized representative may test your employees or contract personnel at your worksite or at an onshore location. You and your contractors must:

(a) Allow MMS or its authorized representative to administer written or oral tests; and

(b) Identify personnel by current position, years of experience in present position, years of total oil field experience, and employer's name (e.g., operator, contractor, or sub-contractor company name).

30 cfr 250 1509
30 CFR 250.1509

What must I do when MMS administers or requires hands-on, simulator, or other types of testing?

If MMS or its authorized representative conducts, or requires you or your contractor to conduct hands-on, simulator, or other types of testing, you must:

(a) Allow MMS or its authorized representative to administer or witness the testing;

(b) Identify personnel by current position, years of experience in present position, years of total oil field experience, and employer's name (e.g., operator, contractor, or sub-contractor company name); and

(c) Pay for all costs associated with the testing, excluding salary and travel costs for MMS personnel

at this point testing should not be a surprise to you or your company
At This Point, Testing Should Not be a Surprise to You or Your Company
  • Testing has been included in our regulations since the year 2000
  • We have voiced our intention to test at a variety of conferences & meetings in recent years
  • Before initiating the 2008 Subpart O pilot the agency began exploring testing in 2007
january 2007 iadc well control work group
January, 2007 IADC Well Control Work Group

MMS introduced idea to IADC that agency was interested in implementing Subpart O testing

MMS presented hands-on well control testing options to IADC for discussion purposes

Live well tests

School based testing

simulators

computers

30 CFR 250.462 (d) Well Control Drill

january 2007 iadc well control work group1
January, 2007 IADC Well Control Work Group

Why Was MMS Interested in Testing?

Increase in Subpart O INCs

40 INCs as of 1/2007

G 846, G851, G862, G842

Loss of experienced personnel

Up to this point MMS had conducted 6 written tests, several oral tests, & no hands-on tests

MMS requested IADC/Industry input on testing

ntl no 2008 n03 well control production safety training
NTL No. 2008-N03 - Well Control & Production Safety Training

Effective March 31, 2008

Clarified terms used in Subpart O rule

Internal audit, production safety, periodic, contractor

Discussed lessee and contractor responsibilities, program evaluations, & employee verifications

Announced MMS intent to conduct hands-on testing in 2008

april 2008 baker energy
April, 2008 - Baker Energy
  • MMS met with Baker to review their production training program
  • Baker provided MMS detailed information on program highlights to aid us in developing a successful Subpart O test program
    • Training components
    • Assessment criteria
    • Test questions
    • Grading issues
    • Program statistics
june 2008 iadc well control work group
June, 2008 IADC Well Control Work Group

MMS updated IADC & continued to press for input into testing program

Training INCs continue to increase

71 INCs as of 12/2007

Up to this point MMS had conducted 10 written tests, 36 oral tests, & no hands-on tests

IADC agreed to form internal group to provide MMS testing feedback

august 2008 iadc well control work group
August, 2008 IADC Well Control Work Group

Since June, 2008 IADC/Chevron provided MMS a series of hands-on well control scenarios

Operational based

Position specific

Discussed IADC/Chevron suggestions for hands-on well control scenarios received by agency

MMS provided work group overview of how pilot Subpart O testing program could work moving forward

october 2008 diamond offshore drilling
October, 2008Diamond Offshore Drilling
  • Diamond volunteers rigs for offshore written &/or hands-on well control testing
    • Diamond/Devon
    • Ocean Endeavour semisubmersible
    • Pre MMS pilot
  • Received valuable real world input and comments on specific test questions, test process, grading policies
testing
Testing
  • Since publication of Subpart O in 2000 MMS has had a variety of tools at our disposal to monitor industry compliance
    • Employee interviews
    • Audits
    • Tests
  • Majority of MMS efforts to date have focused on interviews and audits
slide24

SUB O AUDITS & INCs

(2002 – 2008 YTD)

testing1
Testing
  • After evaluating how interviews and audits work/don’t work MMS began to explore testing
  • Provides MMS another tool in our audit tool box to evaluate employee competency
  • Provides MMS and company more of a “real” world evaluation of individual skills as related to their job
testing pilot program
Testing Pilot Program

Started 11/1/08

No enforcement (INC)

Goal

Issue as many tests as possible to gain a better understanding of test administration

Receive lessee & contractor input

Areas of concern

Grading

70%

pass/fail

Consistency

test administration

Level of difficulty

testing pilot program1
Testing Pilot Program

Open book

All material acceptable

Charts, guides, books, tables….

No time limit

Testing location

Onshore (office, school), offshore

Passing grade

Written – 70% and above

Hands-on – pass/fail, all steps deemed critical

written well control pilot tests
Written Well Control Pilot Tests

Three tests; “A”, “B”, “C”

Each test includes three levels based upon rig position

Level “L1”

floorhand, derrickman

Level “L1L2”

driller, assistant driller

Level “L1L2L3”

toolpusher, company man

written well control pilot tests grading
Written Well Control Pilot Tests - Grading

Level “L1” (floorhand, derrickman)

5 questions

Passing = 70% on this section only

Level “L1L2” (driller, assistant driller)

11 questions

5 questions from “L1” + 6 new questions

Passing = 70% on 11 questions

Level “L1L2L3” (toolpusher, company man)

20 questions

5 questions from “L1” + 6 questions from “L1L2” + 9 new questions

Passing = 70% on 20 questions (entire test)

written well control pilot tests questions
Written Well Control Pilot Tests - Questions

Level “L1” questions

Basic well control concepts, equipment practices

Level “L1L2” questions

More advanced well control theory, equipment concepts

Level “L1L2L3” questions

Deeper knowledge of well control techniques, operational systems, calculations

Only level to contain calculations

hands on pilot well control tests
Hands-On Pilot Well Control Tests

Five scenarios

Each scenario includes a series of Yes/No skill based questions

5 to 8 questions per scenario

Employee/team needs to show competency by demonstrating or answering all questions correctly

Each question in a scenario deemed to be critical

Scenarios focus on either an individual or a team

written production pilot tests
Written Production Pilot Tests

Five tests; “A”, “B”, “C”, “D”, “E”

Each test includes three levels based upon position on facility

Level “L1”

C or D operator

Level “L1L2”

A or B operator

Level “L1L2L3”

Lead operator

written production pilot tests grading
Written Production Pilot Tests - Grading

Level “L1” (C or D operator)

35 questions

Passing = 70% on this section only

Level “L1L2” (A or B operator)

44 questions total

35 questions from “L1” + 9 new questions

Passing = 70% on 44 questions

Level “L1L2L3” (lead operator)

50 questions total

35 questions from “L1” + 9 questions from “L1L2” + 6 new questions

Passing = 70% on 50 questions (entire test)

written production pilot tests questions
Written Production Pilot Tests - Questions

Level “L1” questions

Basic wellhead equipment design, safety device testing and reporting requirements

Level “L1L2” questions

More advanced safety analysis concepts, system design theory and practices

Level “L1L2L3” questions

Deeper knowledge of analysis, design, installation and testing of production surface safety systems and of government codes, rules and regulations

hands on production pilot tests
Hands-On Production Pilot Tests

Ten scenarios

Each scenario includes a series of Yes/No skill based questions

10 to 14 questions per scenario

Employee/team needs to show competency by demonstrating or answering all questions in a correct manner

Each question in a scenario deemed to be critical

Scenarios focus on either an individual or a team

type of tests conducted during pilot
Type of Tests Conducted During Pilot

Majority of written tests were offshore & announced

Small percentage of written tests were unannounced

18 well control written tests conducted at school & compared against schools’ test

All hands-on pilot tests were conducted offshore

testing pilot program2
Testing Pilot Program

Lessee & contractors either volunteered to participate or were picked at random

Testing was conducted during normal MMS inspection activities

Tests were mostly graded onsite

Employee comments were solicited

Often times an individual was given multiple tests for feedback and comparison purposes

Test data was entered into an MMS data base

companies tested during pilot
Companies Tested During Pilot
  • Devon/Diamond
  • ExxonMobil/H&P
  • ExxonMobil/Sam Jones
  • Energy XX1/Hercules
  • BP/Rowan
  • Helis/Rowan
  • Hunt/Ensco
  • Badger/Pride
  • Mariner/Noble
  • El Paso/Wood Group
  • Mariner/Prosper
  • Chevron/Parker
  • Venoco
  • PXP
  • Shell
  • Stone
  • Apache
pilot test breakdown by mms region
Pilot Test Breakdown by MMS Region

Total tests conducted during pilot

Gulf of Mexico - 129

Pacific - 7

Alaska - 0

subpart o pilot tests conducted
Subpart O Pilot Tests Conducted

Written Tests

Well control – 86

37 L1

23 L1L2

26 L1L2L3

Production – 31

4 L1

7 L1L2

20 L1L2L3

Hands-On Tests -19

Well control - 4

Production - 15

pilot well control written test vs school tests
PILOT WELL CONTROL WRITTEN TEST vs. SCHOOL TESTS
  • 18 MMS well control written tests conducted at school & compared against schools’ test
  • Tested 6 people; 2 toolpushers, 1 driller, 1 derrickman, 2 floorhands
  • School WellCAP test averages
    • Introductory – 78%
    • Fundamental – 87%
    • Supervisory – 89%
  • MMS test averages
    • “L1” – 70%
    • “L1L2” – 81.7%
    • “L1L2L3” – 83.3%
  • Limited data shows consistently higher school scores than MMS scores for “comparable” tests
well control written pilot tests what did we learn
WELL CONTROL WRITTEN PILOT TESTS WHAT DID WE LEARN ?

Well Control Test “C” Appears to be the Most Difficult

Test C has more calculations than Test A or Test B

Test C has lowest average test scores in each category

Most Test Failures are for the “L1” level

Floorhand, derrickman

As expected, “L1” personnel are least experienced

6 yrs. avg. oilfield experience

Majority of “L1” personnel appear to be trained in accordance with IADC WellCAP Introductory level

some MMS “L1” questions were outside scope of IADC WellCAP Introductory level

BOP testing and MMS regulations

well control written pilot tests areas of concern
WELL CONTROL WRITTEN PILOT TESTS AREAS OF CONCERN

L1 (floorhand, derrickman)

Causes of kick

not keeping hole full

insufficient mud weight

lost circulation

First step to control kick

shut well in ASAP

Location of wrench for manual valves (MMS regulations)

ready access

Annular test pressure or test frequency

14 day

70% RWP or per MMS (not in WEllCAP, MMS regulations)

well control written pilot tests areas of concern1
WELL CONTROL WRITTEN PILOT TESTS AREAS OF CONCERN

L1L2 (driller, assistant driller)

Hydrostatic pressure concept

gradient or density of fluid x height of fluid column

Ways to circulate out kick

drillers, wait/weight, volumetric

Ram test pressure

RWP or per MMS (MMS regulations)

With well shut in what happens to BHP as gas bubble rises

Quantities of drilling fluid and drilling fluid materials on rig to ensure well control (MMS regulations)

Safe drilling margin

well control written pilot tests areas of concern2
WELL CONTROL WRITTEN PILOT TESTS AREAS OF CONCERN

L1L2L3 (toolpusher, company man)

Calculations (only test w/ calculations)

P1V1=P2V2

sacks Barite to increase MW

circulating pressures

equivalent mud weight

MMS regulations

diverter vent line OD (bottom founded, floater)

directional requirements (inclination, azimuth)

written well control tests lessons learned
Written Well Control Tests Lessons Learned

Evaluate increasing number of questions in “L1” section of test from 5 to 10 for easier/better grading

Evaluate IADC WellCAP course curriculum in developing questions for tests and use as appropriate;

Introductory (floorhand, derrickman)

Fundamental (derrickman, assistant driller, driller)

Supervisory (tool pusher, company man)

Evaluate question specific comments received by MMS & industry personnel

written pilot production tests what did we learn
Written Pilot Production Tests What Did We Learn?

MMS would have liked to have conducted more production written tests however, based upon the data;

Production tests A – E appear to be of equivalent difficulty

No failures out of 31 tests

74% lowest recorded grade (Test A-L1L2L3)

written pilot production tests areas of concern
Written Pilot Production Tests Areas of Concern

L1 (C, D operators)

Wellhead component identification

casing valves (intermediate, production)

casing heads (surface, intermediate, production)

Equipment testing interval

TSH-compressor (six months)

TSH-fired component (annual)

written pilot production tests areas of concern1
Written Pilot Production Tests Areas of Concern

L1L2 (A, B operators)

Wellhead component identification

casing valves (intermediate, production)

casing heads (surface, intermediate, production

Separator pressure valve settings

Equipment testing interval

BSL (annual)

tubing plug (six months)

What does LACT stand for?

written pilot production tests areas of concern2
Written Pilot Production Tests Areas of Concern

L1L2L3 (lead operators)

DOI pipeline out of service requirements

% of LEL gas detector should alarm at

Separator pressure valve settings

What does LACT stand for?

Equipment testing interval

tubing plug (annual)

pilot hands on test results
Pilot Hands On Test Results
  • Well Control – 4 (P, P, P, P)
  • Production – 15
      • (P, F-13/14)
      • (P)
      • (P)
      • (P, P, F-9/10)
      • (P, P)
      • (P, F-9/10)
      • (P, F-7/10)
      • (P, P)
pilot hands on tests what did we learn
Pilot Hands On Tests – What Did We Learn
  • Grading
    • Test taker could be competent even though they did not answer all questions correctly or perform task properly
    • Subjectivity of MMS
  • Should we continue with P/F hands on grading system or evaluate use of a grading system similar to written testing?
test taker comments
Test Taker Comments

Well Control Written

Good program

Tests put together well, each level fair, good learning tool, good refresher, fair test

Tests should lead to increased safety

L1 test adequate, tests L1L2 and L1L2L3 should be more detailed

Straightforward, easy to understand

Good for basic knowledge, good mix of easy/hard questions

Good for rig tests

Will help improve skills between school based training

L1 test easy, L1L2 test confusing

Do not test on crew change days (2 times)

test taker comments1
Test Taker Comments

Well Control Written

Some questions I have seen before others I have not

Strong test, good test (7 times)

Questions did not clearly show choices, I knew the answer but it was not in the choices

Need MMS regulation book for test

Hard test

Testing is good, allows you to see who understands what

Don’t test on first day back after days off, keep testing

Not enough time, felt rushed

Use one big test

Good questions (2 times)

Too many repeat questions

Tests shouldn’t be announced

Tests identify items I am weak in

test taker comments2
Test Taker Comments

Production Written

Some questions geared to management personnel not operational personnel

Test A question #7; confusing

Test A question #2; misleading

Test B question #19; could not find in CFR (2 times)

We need a list of publications showing where questions come from

Good general test on equipment and regulations

Good test

Test B is best, more real world then other test versions

test taker comments3
Test Taker Comments

Production Hands On

Scenario went over all procedures to troubleshoot this event (2 times)

Evaluation went over all steps to troubleshoot equipment and went through all components

Scenario went over all components & operations associated with performing task

Well Control

None

major points of interest
Major Points of Interest

Post-pilot testing program will go into effect on 4/1/09

Post-pilot program will include enforcement

Lessons learned from pilot program will be integrated into program whenever feasible

who will mms test
Who Will MMS Test ?

Possible test candidates;

Operator

Contractor

Companies picked @ random

Companies experiencing;

problems with Subpart O audit

loss of well control

lower than average OSI (poor performers)

When training is identified as a cause in an accident

test triggers
Test Triggers
  • Testing is one tool in the audit toolbox
  • Triggers for testing include:
    • Failure of the operator to verify employee knowledge and skill
    • Failure of the operator to verify contractor employee knowledge and skill
    • Failure of the operator to evaluate contractors training program
post pilot testing procedure basics
Post-Pilot Testing Procedure - Basics
  • Tests will be announced or unannounced
    • Announced
      • phone call or letter from MMS
  • Tests will be conducted at a variety of locations; onshore (school, office), offshore
    • Offshore
      • MMS to discuss w/ field management to determine if it is safe & appropriate to conduct a test at that time (written or hands-on)
  • Open book
    • All material acceptable
    • Computers OK with MMS monitoring
      • No emails, no IM’s
  • No time limit for test
post pilot testing procedure basics1
Post-Pilot Testing Procedure - Basics
  • No set number of tests to be conducted by MMS during a year
  • If we conduct test @ your rig/facility/school goal is to test 10% of personnel on location
  • No retests
  • No help from others
  • Grading
    • 70% = passing for both written and hands-on tests
post pilot testing procedure basics2
Post-Pilot Testing Procedure - Basics
  • Well control written tests
    • 4 new tests instead of 3
    • 10 questions in “L1” (floorhand, derrickman) section of test instead of 5
    • Questions to focus more on IADC WellCAP Introductory level and less on MMS regulations
  • Production written tests
    • More or less same questions as pilot tests however questions will be renumbered for easier grading
    • Addition of an H2S supplement – operational specific testing
post pilot testing procedure
Post-Pilot Testing Procedure
  • Enforcement
    • If employee fails written test (< 70%) a G-856 INC may be issued
      • MMS will consider a hands-on test of employee to validate written test prior to deciding on INC
    • Based on test(s) results MMS briefs lessee with general assessment of employees performance
      • if MMS feels strongly that INC should be issued lessee will be informed to expect INC in the mail from District within 7 business days
      • no INC issued on-site
      • grading will not be conducted on-site, but in District
      • lessee needs to identify to MMS how they will address deficient employee before MMS leaves location (school, rig/facility…)
g 856 inc information
G 856 INC Information
  • INC with explanatory letter to lessee is issued by District office and will include;
    • Date & time of test
    • Employer
      • lessee, contractor
    • Location of test
      • onshore (school, office)
      • offshore (rig/facility, lease/block)
    • Position of employee
      • Lead operator, driller …..
    • Score and result
      • numeric grade
      • pass/ fail
      • specific questions wrong will not be released
    • Overview of concerns
post pilot testing procedure1
Post-Pilot Testing Procedure
  • G-856 Possible Corrective Actions
    • Retrain employee
    • Retest employee w/ company test
    • Retrain and retest employee
    • Put employee under direct supervision of another employee
    • Transfer employee to another job
    • Others ??
new g 856 pinc
New G-856 PINC
  • G-856   DOES EACH EMPLOYEE UNDERSTAND AND PERFORM THE ASSIGNED WELL-CONTROL OR PRODUCTION SAFETY DUTIES?
  • Authority: 30 CFR 250.1503(a)   30 CFR 250.1507(c)                    
  • Enforcement Action: W/C  30 CFR 250.1507(d)    
  • INSPECTION PROCEDURE:  Verify that lessee’s training plan provides a process to ensure that employees understand and can perform their assigned well-control or production safety duties.    Verify (either through written, hands-on, or oral testing) that employees understand and can perform their assigned well-control or production safety duties.
  • IF NONCOMPLIANCE EXISTS:   Issue one warning (W) INC for an audit of one or more employees if the training plan fails to provide a process to ensure that employees understand and can perform assigned well-control or production safety duties.  Issue one component shut-in (C) INC for one or more employees that fail to demonstrate either through written, hands-on, or oral testing, their ability to perform the assigned well-control or production duties.
  • Note:  The employee is the component.
  • INSPECTION COUNT/INC COUNT: Enter one item checked/issue on INC per training plan audited.
discussion questions comments opinions
Discussion, Questions, Comments, Opinions…

Joseph.Levine@mms.gov

Phone: (703) 787-1033 David.Dykes@mms.gov

Phone: (504) 736-3249

THANK YOU !!!