Quality Production Management LLC Production Safety & Well Control Operator Qualification Manual Version 2.2 November, 2014
1.0 Purpose 2.0 Definitions 3.0 Training Program Goal 4.0 Implementation 5.0 Training 5.1 Competency Requirement 5.2 Methods of Training 5.3 Newly Hired Employees 5.4 Frequency 5.5 Length 6.0 Validation of Training Competency 6.1 New Employees 6.2 Existing Workforce 6.2.1 Well Control 6.2.2 Production Safety 6.2.3 Employee Assessment 6.3 Recordkeeping and Documentation 6.4 Audits 7.0 Training Sources 7.1 Sub Part O EYE program (Evaluating Yourself Electronically) 8.0 BOEM Reviews Appendix A Appendix B New Hire Processing Flow Diagram Qualification Flow Diagram
1.0 PURPOSE To provide and implement a written training plan for well control and production safety that fulfills the requirements of 30 CFR Part 250, Subpart O 2.0 DEFINITIONS Qualified Employee - an employee that has acquired, through training and testing, the proper skills needed to perform their duties at QPM in a safe and competent manner. Production Safety - production operations as well as the installation, repair, testing, maintenance, or operation of surface or subsurface safety devices. Well Control - (for the purpose of this plan) simultaneous operations pertaining to production activities while drilling, well work over, well completion, snubbing, coil tubing, or wire line operations are considered well control activities. 3.0 TRAINING PROGRAM GOAL The goal of the training program is to ensure safe and clean Outer Continental Shelf (OCS) operations. This program has been developed to ensure that QPM employees who engage in well control or production safety operation understand and can properly perform their assigned duties. 4.0 IMPLEMENTATION The following job titles are required to follow the guidance of this document: Production Field Foreman Production Lead Operator Production A Operator Production B Operator Any other position where job duties dictate PSST or Well Control duties QPM will accept prior forms of training, documented in accordance with the BOEMRE guidelines in the form of valid BOEMRE well control and production safety systems certificates from previously BOEMRE accredited training schools. These certificates will be accepted only until the date of their expiration. Personnel hired whose qualification is expired or is to expire within 30 days, must complete training and qualify by: 1) Completing the QPM Sub Part O EYE program 2) Attending and completing a qualified well control or production safety system school that, at a minimum, meets the previously approved BOEMRE curriculum and has been updated with any changes in regulation since the previous approval standards. These curriculums will be reviewed by QPM before acceptance.
5.0 TRAINING 5.1 Competency Requirements Personnel must meet competency requirements for their specific assigned job responsibilities. Personnel having met these requirements will be considered by QPM as qualified employees to perform well control or production safety systems work. This plan includes methods and provisions for the training of new and current employees. Training will remain flexible to meet the ever-changing requirements of our industry while helping our employees set the industry standard. The training duration will depend on whether the employees are being educated initially or recertified on their documented abilities. Experienced and competent employees may require a shorter retraining time. We will continue to find ways to meet the need for any additional training to help our employees become industry leaders. 5.2 Methods of Training Methods of training may include previously accredited 3rd party training for well control with classroom and field settings, utilizing performance based hands on, written and/or computer based online and oral teaching methods for production safety systems training needs. To help in reaching specific needs, we have implemented written and/or computer based, hands on and oral teaching methods in the field. The use of electronic and self-paced study programs to enhance skills may also be utilized. Quality Production Management will continue using the API (American Petroleum Institute) series of training to enhance our employee s ability to better understand their current job assignment and to grow. We will be encouraging and make available to our employees the following additional educational opportunities: classroom instruction self-paced and computer based modules internet resources specific vendor and equipment manufactures supply information model cutaways and static representations of factual production safety equipment pictures and drawings of operational equipment processes and methods of operation hands on activities and written examinations 5.3 Newly Hired Employees Newly hired employees and employees whose certifications are expired will complete training and recertification in accordance with this plan. The assessment and further training will be provided within the following time intervals to ensure that the employees are able to maintain competency and a thorough understanding of their job responsibilities. 5.4 Frequency Quality Production Management employees will qualify at the following intervals: Training Qualification Well Control Production Safety Systems Recertification Interval As required by assigned duties Three years
5.5 Length Quality Production Management, LLC is composed of employees both experienced and new to Well Control and Production Safety Systems. The needs and experience of the individual will be a major factor in determining the length and depth of training. Therefore, course length must remain flexible. 6.0 VALIDATION OF TRAINING COMPENTANCY 6.1 New Employees New employees to Quality Production Management, LLC that will have job duties requiring work with surface safety systems must possess a current production safety system training qualification. The prospective employee will also undergo safety and regulatory compliance evaluations to verify their qualification for the duties assigned. These tests will be used to determine the prospective employee s ability to perform their job classification. This will also indicate any areas of weakness or misunderstanding which can be corrected through classroom or self-paced learning. These corrections must take place within a reasonable time frame that will be determined on a case by case basis. If the employee does not meet these requirements they may be subject to disciplinary or corrective action up to termination. 6.2 Existing Workforce 6.2.1 Well Control For purposes of this plan, simultaneous operations pertaining to production activities while drilling, well work over, well completion, snubbing, coil tubing, or wire line operations are considered well control activities. If the employee does not have a well control qualification from a QPM recognized training program (ie. IADC Well Cap), the employee will be required to complete a recognized training program before being designated as a qualified employee for these activities if the qualification is required by government regulation, customer requirements or QPM requirements. 6.2.2 Production Safety If the employee does not have a current production safety qualification from a QPM recognized training program, the employee will be required to complete the Sub Part O EYE program or a QPM approved qualification course before being designated as a qualified employee 6.2.3 Employee Assessment A knowledge assessment consisting of applicable topics will be provided for one third of our active operational field employees annually, to be alternated each year for an extended period of three years until all active employees are assessed. Those employees who score 80% or greater when assessed will not be required to attend additional training at that time. If the employee has a current qualification but does not score at least 80% on the assessment, the employee will be required to qualify by completing the Sub Part O EYE program or a QPM approved qualification course before being designated as a qualified employee
6.3 Recordkeeping and Documentation Recordkeeping and documentation will be maintained for a period of not less than five years for all active employees. All personnel training records will be made available to the BOEMRE for review upon request. 6.4 Audits Audits will be conducted annually on randomly selected employees to identify deficiencies in this training plan. If any deficiencies are found they will be examined and corrected. 7.0 Training Sources Quality Production Management, LLC will continue to consider classroom, hands-on simulations and written competency testing in well control and production safety operations as appropriate training sources. Classroom instruction provided by third party sources should meet current industry standard training requirements. Vendors and industry recognized specialty training in well control or production safety operations will be used to enhance personnel knowledge and ensure exposure to the latest technological advances. Other training sources may be used to educate personnel on well control and production safety operations. This may include location supervisors conducting on-site drills, operational tests and simulations in controlled environments to review, reinforce and demonstrate safe and competent execution of job tasks. The focus of the training is to assure that QPM personnel receive proper instruction on well control and production safety so that they are competent to perform their job task safe and properly. 7.1 Sub Part O EYE Program (Evaluating Yourself Electronically) This is a self paced electronic training program. The EYE program is administrated by Pro Active Compliance through a QPM assessor whose primary duties are training related. The assessor will mentor the trainee through the program and provide an oral and hands on assessment after the required blocks of training are completed. The curriculum is set up to guide the trainee through the CFR s, looking up the requested regulation and then completing the question. The concept is to teach the process of looking through the CFR s for a particular regulation familiarizing them with the process of research and the set up of the CFR s. This process also makes the trainee read the requested regulation so that he can then associate that regulation with his day to day production safety activities helping him retain this knowledge more effectively.
There are nine required blocks of training that consist of the following: 1) General Block (161 answers) General platform conditions, welding operations, crane operations 2) Environmental (119 answers) General pollution, oil spills, documentation, sampling, human waste 3) Production #1(153 answers) - General production safety, Vent and flare, etc. 4) Production #2 (201 answers) Undesirable events, abnormal conditions, safety device requirements and placement. 5) Production #3 (117 answers) General safety device Testing, Testing documentation, testing procedures. 6) Pipelines (44 answers) DOI Pipeline safety devices, inspection and procedures. 7) USCG #1 (247 answers) General safety, safety and lifesaving equipment inspection and requirements. Assessment (55 tasks) oral and hands, outlining the criteria contained in the electronic sections and the designated work location of the trainee. 8) USCG #2 (72 answers) requirements for installation, maintenance and testing of aids to navigation. 9) Measurement (193 answers) requirements for installation, maintenance and testing of metering equipment for oil and gas production 8.0 Bureau of Ocean Energy Management, Regulation and Enforcement Review Quality Production Management, LLC HSE Department will be the primary contact for any Bureau of Ocean Energy Management, Regulation and Enforcement review of this training plan. Field personnel will be made available to the BOEMRE for interviews at either land or offshore locations to determine the type of training used and how effective the training was. Upon reasonable notice, Quality Production Management, LLC will make employees or contractor personnel available to the BOEMRE or its authorized representatives to evaluate their competency in performing their assigned duties. Information on employees such as their current position, years experience in present position, years of overall field experience and name will be provided to the BOEMRE upon request.
APPENDIX A New Hire Processing Flow Diagram Personnell Cordinator Superintendant HR and Training dept General Manager
APPENDIX B Qualification Flow Diagram