Lessee Performance-Based Training Program

Background

The Office of Offshore Regulatory Programs (OORP) is responsible for program oversight and coordination of BOEMRE's Subpart "O" lessee and operator training program. To ensure that OCS oil and gas operations emphasize operational and environmental safety, lessees must employ highly qualified and trained personnel. The BOEMRE has developed and implemented training regulations since the late 1970’s. Initially, training was required for key personnel involved in drilling well-control and production safety systems. In the late 1980’s, BOEMRE promulgated new requirements for well-completion, well-workover, and well-servicing operations as well as revising regulations for drilling and production safety systems.

On August 14, 2000, BOEMRE promulgated a performance-based rule that holds lessees accountable for developing and implementing their training programs. This new regulation which became effective on October 15, 2002, calls for each lessee to prepare a training plan laying out the company’s training philosophy including the type, method, length, frequency, and content of their training program. To implement this regulation BOEMRE has used a series of performance measures to periodically assess the quality of lessee and contractor training programs. Such assessments have included one or more of the following evaluation methods:

	Audits
	Written tests
	Hands-on test
	Employee interviews

Current Status

On October 15, 2010, BOEMRE published a final Safety and Environmental Management System (SEMS) regulation. In accordance with this regulation, OCS operators need to have a SEMS program in effect on or before November 15, 2011. This rule requires operators to comply with the provisions of API RP 75, Third Edition and BOEMRE specific requirements included in Subpart “S”. Training is one element of a SEMS program. The training element of a fully functioning SEMS needs to address how all personnel are to be trained to work safely in accordance with their job duties and responsibilities. Training requirements addressed in Subpart O for drilling well-control, well completion, well-workover, well-servicing and production safety systems are still in effect and an OCS operator may decide to integrate their current Subpart O program into their SEMS program. However, the Subpart O training regulation is now considered one component of SEMS required training. For additional information on Subpart O and Subpart S (SEMS) please see this page; http://www.boemre.gov/semp/. Training 30 CFR 250.1500 - Subpart O Current Rule (142 KB PDF)