The SEMS issue that you hear the most about right now is probably the requirement that Operators verify the skills and knowledge of Contractor personnel. We are going to devote the next few blog posts to exploring the issue, where companies are today and some of the solutions that are starting to emerge.
This is certainly one of the toughest parts for both Operators and Contractors to get their arms around. The SEMS and SEMS II regulations have something like 11 references on the need for Operators to verify skills, knowledge or experience of personnel, such as:
- “You are responsible for making certain that contractors have the skills and knowledge to perform their assigned duties and are conducting these activities in accordance with the requirements in your SEMS program.” (30 CFR 250.1914 (b) (2))
- “Periodic training to …verify adequate retention of the required knowledge and skills.” (30 CFR 250.1915 (b))
The requirement doesn’t just involve personnel who go offshore either. Shoreside activities like maintenance and design work may also fall under the regulations.
For industry it has been a huge shift in focus, from hiring companies and then expecting them to do the job safely and correctly to making sure that each worker knows how to do his or her individual job before they start work, at least under a strict reading of the SEMS rules.
So how has industry addressed this? For the first year or two of SEMS, the focus has been on collecting pieces of paper – certificates, diplomas, class rosters, resumes – anything that shows evidence that a worker was at least taught required aspects of the job.
The concern is that that is not enough. Sitting through a class doesn’t prove you know how to do something or that you know the right way to do it. After all. how many of us really want to go back and try to pass that geometry test we took back in Junior High? Besides that, a lot of the most skilled workers in the industry learned through on the job training. How do we track that?
Over the last few months Operators are increasingly looking at worker skills evaluations as a way to drill down to whether the individual has the specific skills to do the job right now. Apache (whose shelf assets have now been sold to Fieldwood Energy) led the way on this by requiring Contractors to provide evaluations of their personnel every year. Apache/Fieldwood doesn’t tell Contractors how to do that, just that it needs to be documented and auditable.
As more and more Operators adopt that model, the focus is turning towards and effective and standardized model for the evaluations. More on that in a future blog. If you are looking for help complying with this area, feel free to contact us.