Ed Well Competence

7/18/2019 Ed Well Competence

http://slidepdf.com/reader/full/ed-well-competence 1/20

HID Inspection Guide Offshore Well Competence Inspection Guide

Contents

Summary

Introduction Action Background Organisation

Targeting

Timing Recording and Reporting

Appendix 1: Inspection guidance Appendix 2: Performance assessment

SummaryThis Inspection Guide (IG) sets out the Energy Division - Offshore approachto the inspection of the management of competency of wells personnelengaged in oil or gas well operations either offshore on the UK ContinentalShelf or onshore in Great Britain.

The Guide provides a question set to be used as a basis for a wells personnelcompetency management system inspection. This has been developed froma background of HSE and industry guidance on Competency ManagementSystems.

The guide provides the basis to assess any risk gap as defined by HSE’sEnforcement Management Model, and hence the Duty Holder’s PerformanceScore which will feed into the intervention planning process.

IntroductionCompetence is a very broad subject area that may span the length andbreadth of an organisation, and the competency requirements for personnelinvolved in well engineering and operations activities will be differentdependent upon the organisation’s activities, the job position, the tasks to beundertaken and the associated risks. The work activities and tasks carried bydifferent organisations will be different dependent upon their roles as mobileand fixed installation drilling rig duty holders, or as well operators, or as thirdparty service providers.

Page 1 of 20



Major hazard organisations require competent staff that have the necessaryskills, knowledge and experience to undertake critical tasks in such a way asto prevent a major accident or minimise the consequences to people and theenvironment, should one occur.

‘Competence’ means the ability to undertake responsibilities and performactivities to a recognised standard on a regular basis. Competency is acombination of practical and thinking skills, experience and knowledge, andmay include a willingness to undertake work activities in accordance withagreed standards, rules and procedures. Competency depends on the contextand the environment in which the activity is performed, and on the workingculture of the organisation.

‘Competence Management’ means the arrangements to control, in a logicaland integrated manner, a cycle of activities within the organisation that willassure, and develop, competent performance. The aim is to ensure that

individuals are clear about the performance that is expected of them, that theyhave received appropriate training, development and assessment, and thatthey maintain, or develop, their competence over time.

Action

The aim of this Inspection Guide (IG) is to provide information and guidanceto offshore inspectors to support the delivery of consistent and effectivecompetence assessments of offshore wells personnel. It does this byhighlighting key areas essential to an effective competence assessment

process, so that these can be covered during inspections, providing aframework for inspectors to judge compliance, assign performance ratings,and decide what enforcement action to take should they find legislativebreaches. In doing so, it complements HSE’s Enforcement Policy Statement (EPS) and Enforcement Management Model (EMM).

Inspectors undertaking a Wells Competency Management System inspectionwill need to be familiar with the Oil and Gas UK Guidelines on competency forWells Personnel.

A set of model responses is provided along with a questionnaire (see

Appendix 1). These provide the interpretive standard against which theEnforcement Management Model (EMM) risk-gap should be assessed andhence the Duty Holder’s performance Score in relation to wells personnelcompetency management.

The questions were developed from the EI Research Report: Human FactorsPerformance Indicators for the Energy and Related Process Industries andthe survey questionnaire commissioned by the OSPRAG Technical ReviewGroup.

Success criteria (fundamental requirements) are listed under the inspectiontopics (see appendix 2); these cover the key issues that inspectors should

Page 2 of 20

http://www.hse.gov.uk/enforce/emm.pdf

http://www.hse.gov.uk/enforce/enforcepolicy.htm



http://www.hse.gov.uk/enforce/enforcepolicy.htm




consider when carrying-out inspections against each core intervention issue.In some instances, not all of the success criteria will apply so inspectorsshould make a judgement regarding which of these are relevant in each case.If the relevant success criteria cannot be met, inspectors should assess howserious the consequences of failure to comply could be. This will inform their

decision making in terms of the performance ratings that they assign and theenforcement action they take (if any) based on the findings of the inspection.

BACKGROUNDThe Oil Spill Prevention & Response Advisory Group (OSPRAG) was set upin the UK in response to the Macondo incident in the Gulf of Mexico in April2010. The recommendations by OSPRAG’s Technical Review Group wereaccepted by Oil and Gas UK and led to the publication of Guidelines onCompetency for Wells Personnel by Oil and Gas UK.

The OSPRAG Technical Review Group published the followingrecommendations on competence assessment:

There is a high degree of variation in how Competency Management Systems(CMS) are structured across all organisations and their focus on safety criticalwell integrity issues. We recommend that all CMS ensure that they effectivelyaddress the following minimum criteria within their systems:

Leadership and Supervisory Competencies should be established andassessed for a minimum of the following positions:

Location Position

OIM Well Service Supervisor

Company Man Well Test Supervisor

Toolpusher Coil Tubing Supervisor

Drilling Supervisor E-line Supervisor

Driller Slick Line Supervisor

Assistant Driller Completions Supervisor

Derrickman Subsea Engineer

Mud Logger BOP/LMRP Engineer

Drilling Fluids Engineer Well Integrity Engineer

Offshore

Cementer Production Supervisor

Drilling Manager Senior Completion Engineer

Drilling Superintendent Completions Engineer

Senior Drilling Engineer Petroleum Engineer

Onshore

Drilling Engineer Rig Manager

Operations Geologist Reservoir EngineerGeology andGeophysics Development Geologist Subsurface Lead/Manager

** Position or Role titles will vary across organisations

Page 3 of 20



It should be recognised that appraisal systems alone do not constitutean effective competency assessment and CMS should clearlydemonstrate competency is assessed.

Competency assessments for all positions listed above shoulddemonstrate a level of independence for the role.

CMS should have a detailed audit at least every 3 years. Additional competencies should be developed and assessed for all

positions listed above when working on challenging or high risk wells.

CMS should detail how competencies for all contract staff used forpositions listed above are selected and assessed.

Oil and Gas UK GuidanceThe Well Life Cycle Practices Forum produced guidance on competency forwells personnel for Oil and Gas UK. They were written by the Competency,Behaviours and Human Factors workgroup which included representativesfrom operator companies, well management companies, OPITO and RGU.

The guidance is relevant to;

all UKCS offshore installation duty holders, and

all employers of personnel working on wells and well operations in theUK.

The work-group has also produced example competency profiles for selectedwell personnel roles, and established key risk areas and skill elementsdefined as generic skills that are applicable throughout the well life cycle and

key risk areas of the well life cycle where other, more specific skills areapplicable.

Different roles are involved in these risk areas at different stages of the lifecycle, and also depending on the nature of the well.

IADC Competence Assurance Accreditation ProgrammeThe International Association of Drilling Contractors (IADC) runs anaccreditation system for drilling and service companies, which providesaccreditation of companies Competence Assurance Program to assure these

programs meet accepted practices to develop and ensure the skills of theirpersonnel. Accreditation focuses on policy and procedures documentation,identification of job positions and definition of competencies, the assessmentsystem, records system and quality assurance system.

IADC has developed with industry a series of Knowledge, Skills and Abilities(KSA) competency templates for rig based personnel to provide a means bywhich workers can demonstrate their capabilities.

IADC announced in 2012 a project to develop enhanced competencyguidelines for rig personnel, based on the changing rig and drilling

technologies and changing job roles. These enhanced templates are due for

Page 4 of 20



publishing in 2014, covering virtually all rig positions, with a priority on safetycritical positions with well control responsibilities.

In addition to drilling contractors, some major service companies e.g. BakerHughes Inc., Halliburton Energy Services Inc have obtained IADC

accreditation for their Competency Assurance Programmes.

Team CompetenceWell operations are usually team based activities rather than individualsworking in isolation. Assuring an appropriate mix of competencies at anindividual level may be used to assess the competency of the team. A riskand task based approach will facilitate efficient gap analysis for teamcompetency assessment.

Oil and Gas UK competency guidelines require all roles with a supervisory or

project management element should be assessed for leadership andsupervisory competency.

Contract and Third Party Contract PersonnelOil and Gas UK competency guidelines require the competency of contractstaff in the team to be assured. Contract staff should be assessed prior tohiring, at the start of the contract and during operations. This can be done by:

including contract staff in the employer’s or well operator’s CMS on atemporary basis; or

the company supplying the personnel operating its own CMS; or

individuals demonstrating their personal competency.

In addition, the main duty holders (offshore installation owners, operators, andwell operators), need to assure themselves that all personnel, including thirdparty contractor personnel involved in well operations, are competent for theproposed work. Oil and Gas UK guidelines require an audit prior to the start ofoperations to assure themselves that the contractors have suitable policies,procedures, and management controls (including competency assurance fortheir employees) in place.

Human and Organisational Factors in Well ControlThe North Sea Offshore Authorities Forum (NSOAF) have carried out a multi-national audit during 2013 to look at how offshore operators and drillingcontractors in the North Sea are incorporating the wide range of necessaryhuman and organisational factors into their well control systems.

The audit results supported the view that industry was providing key wellcontrol personnel with clear and comprehensive ranges of relevantinformation, and with adequate designs of displays, control panels, alarm anddata systems. Although there were some rigs where practices needed

improvement, overall the control panel and associated engineering systemaspects from the audit were good.

Page 5 of 20



Similarly, those aspects linked to how drilling personnel would be able tomake the right judgement and the decisions on well control issues were good.Encouragingly, the audit received strong assurance on the driller’s authority toshut in wells when necessary. However, there was a broader range of

performance here, and hence the need for those at the lower end to emulatethe more advanced operators and drilling contractors, particularly in the wideruse of scenario based training.

The audit, however, identified a particular issue caused by the generalshortage of experienced drilling personnel – the high activity level of theindustry has contributed to accelerated promotions to key drilling positions,and there was widespread acknowledgement that this caused difficulty insecuring adequate competence assurance programmes.

To ensure that the drilling operation is safe and successful, the drilling crew

must continuously monitor displays and other information, and makedecisions on how they perceive and interpret that information. This ‘situationawareness’ of how circumstances are at the time and how they might developin the future is a crucial element. Such activities take place within a complexrelationship of client and contractors, both onshore and offshore, and with anintermeshing of different procedures, objectives, and technical monitoringarrangements. The relationship between all the people and organisationsinvolved must be clear so that everyone knows and understands their role andcan deliver their contribution competently.

The Human Factors findings of the audit included all personnel involved in thedrilling process reported to be trained to International Well Control Forum(IWCF) standards and in possession of a Well Control Certificate (at least tosupervisor level). Well control drills were undertaken and documented.

The drilling contractors reported having training and competency matrices inplace, including job descriptions with continuous evaluation and competencyassurance and on-the-job (OJT) training books for selected drilling activities.One drilling contractor had a bespoke Competency Assurance system (CMS)in place where personnel were assessed on actual performance by competentassessors. However, because of the general shortage of experienced drilling

personnel, it was acknowledged that personnel were often being promotedinto positions early on in their training and development. This caused someorganisations difficulties in keeping planned competency assuranceprogrammes for drill crews fully effective.

There was some variation in the type of drill training undertaken, ranging fromTask and IWCF-focused to Scenario-based training. The audit identifieda welcome improvement from solely ‘routine’ training towards the latterapproach, which is designed to prepare crew for the range of information anddecisions they will face. The wider involvement of 3rd parties in that learningapproach was also acknowledged as an improvement.

Page 6 of 20



‘Drill Well on Paper’ (DWOP) exercises were considered an excellent way foridentifying unfamiliar elements in the well programme and hence exploring theoffshore crew competence. Any gaps could be addressed, for example bybespoke onshore courses or adding experienced supervisors to the offshorecrew to support learning offshore until it was clear that the crew had the

required competence. It was acknowledged, though, that there was a need toextend scenarios to later phases and further handling of a loss of well controlsituation.

Organisational Factors addressed the safety management systems within thedrilling contractor where issues were highlighted. Drilling operations and wellintervention were usually under the direct control of the drilling contractor butthere was close involvement with the client who often maintained overallresponsibility for installation safety. Although all audited companies hadbridging documents in place, the content and quality of these documentsvaried.

There was often a lack of GAP analysis of the systems/ standards used by thedrilling contractor and client/operator, and this reflected a lack of attention atthe contract stage to manuals and compliance. It was notable, in someexamples, that training (and presumably competence) was not included inthese arrangements.

LEGAL REQUIREMENTSThere is a general duty under Regulation 13 of the Offshore Installations andWells (Design and construction, etc) Regulations 1996 for the well operator to:

ensure that a well is so designed, modified, commissioned, constructed,equipped, operated, maintained, suspended and abandoned that:

a) so far as is reasonably practicable, there can be no unplanned escapeof fluids from the well; and

b) risks to the health and safety of persons from it or anything in it, or instrata, to which it is connected, are as low as reasonably practicable.

This general duty is supplemented by further Regulations, including

Regulation 21, Information, instruction, training and supervision whichrequires:

In the case of a drilling, well intervention or workover operation to be carriedout on a well:

a) from an installation. the duty holder, andb) otherwise than from an installation, the well operator,

shall ensure that the operation is not carried out, unless it is carried on incircumstances where the persons carrying out the operation:

a) have received such information, instruction and training; and

Page 7 of 20



b) are being so supervised, that the risk to health and safety from suchoperation is reduced to the lowest level that is reasonably practicable.

The Regulation seeks to promote competence in those carrying out welloperations by ensuring that they receive appropriate training (including

on-the-job training), initial and refresher, information and appropriatesupervision. It requires the installation duty holder or well operator (when thewell is being worked on other than from an installation) to ensure all staff arecapable of carrying out the tasks allocated to them.

Duty holders can discharge their duties for personnel and third parties, otherthan their own by checking that specialist contractors carrying out operationshave suitable policies, procedures and management controls for theoperations foreseen.

Organisation

Targeting

Inspections should be carried-out in accordance with ED duty holderintervention plans.

Timing

Inspectors should undertake wells competence inspections as part of theagreed ED Offshore Intervention Plan; when intelligence indicates interventionis necessary, or as part of an investigation following an incident.

Resources

Resource for the undertaking of wells competence interventions will beagreed as part of the ED Offshore Work Plan or by agreement betweendiscipline specialist team-leaders and inspection management team-leaders,as appropriate.

Recording & Reporting

The duty holder performance ratings should be entered on the InspectionRating Form (IRF) tab of the relevant installation Intervention Plan ServiceOrder. Findings should be recorded in the normal post inspection report and

letter.

References

Oil and Gas UK – Guidelines on Competency for Wells Personnel;

Oil and Gas UK - Example of Competency Profiles for Wells Personnel;

The Offshore Installations and Wells (Design and Construction, etc.)Regulations 1996; Regulations 13 and 21;

Developing and Maintaining Staff Competence. Office of RailRegulation;

Page 8 of 20



Inspection of Competence Management Systems at COMAHEstablishments, COMAH Competent Authority; and

Multi-National Audit “Human and Organisational Factors in WellControl”, North Sea Offshore Authorities Forum, 2012-13.

ContactsED Offshore: ED 1.6 specialist inspectors

Appendices Appendix 1 Inspection Guidance Appendix 2 Performance Rating

Page 9 of 20



Appendix I: Inspection Guidance

The need for a Wells Personnel Competency Management System inspectionusing this guide will be defined by the Energy Division – Offshore interventionplanning process.

Personnel to be interviewed should include at least the custodian of the CMS,an onshore user such as the Rig Manager, and an offshore user such as theOIM.

The inspection will be carried out using the question set below.

Inspectors undertaking a Wells Competency Management System inspectionwill need to be familiar with the Oil and Gas UK Guidelines on competency forWells Personnel.

Question Model Answer Response

1. General – CMS Cycle

Describe yoursystem, processesand procedures forthe management of

workforcecompetence

There should be:

A clearly identified process owner and clearaccountabilities for well technical authoritiesand line management;

The process and responsibilities fordefining and maintaining competencystandards for well activities should bedescribed;

The process and responsibilities should beclearly set out for assessment of wellspersonnel and their individualcompetencies;

The process and responsibilities should beclearly set out for assessment of wellsteams and their collective competency;

The process and responsibilities should be

clearly set out for the management ofassessed shortfalls in competency and forcompetency development of individualsand teams; and

The process and responsibilities should bespecifically set out for the management ofcontract staff.

Is this systemintegrated with othermanagement

systems and, if sohow?

The CMS is an integral part of anymanagement system and can bedemonstrated to be specifically tailored to

manage the competencies of thatorganisation’s work activities and associated

Page 10 of 20




safety risks.

What industryguidelines forcompetencemanagementsystems are beingused?

References: Oil & Gas UK Guidelines on competency for

wells personnel & Example competencyprofiles for well personnel;

IADC Competence Assurance AccreditationProgram & Knowledge, Skill and Abilities(KSA) competency guidelines.

Describe theprocesses in placefor recruitment,selection, training,

and assessment ofstaff, including theselection criteriaused, trainingmethods used, andhow competence isassessed (whereand by whom?)

The CMS should link into other sections ofthe management system and link to therecruitment process, ie job descriptions, theselection criteria and process of selection

and training requirements.

Who is included inthe competencysystem, how

frequently are theyassessed?

A minimum list of positions to be included inthe wells competency management system,is provided for both onshore and offshorepositions in the OSPRAG recommendationsand the Oil & Gas UK Guidelines oncompetency for wells personnel (seeBackground).

The CMS should cover all new employeesand contract staff who start after the systemis in place.

Existing staff and employees should beassessed as soon as practicable andcompetency and training for individualsstarted after assessment.

A maximum period between the formalcompetency assessments conductedbetween an individual and their assessor andshould be defined.

How much time andresource is beingused to administerthe competencysystem, per person,per year?

The organisation should demonstrate thatthe CMS is continuously reviewed todetermine the efficiency of the system,accuracy of decisions being made,employees, contract staff, supervisors, havesufficient time to carry out the requirementsof the system, and the CMS is not

distracting people from their primaryresponsibilities.

Page 11 of 20




How is the system

administered?

Formal training and assessment records

should be maintained. Usually an electronic system of tracking and

maintaining individual performance againstan approved list of job or task relatedcompetencies is maintained.

2. CMS Cycle Phase 1 & 2: Establish Requirements and Design CMS

Who has theauthority to establishand approveperformance

standards within thesystem?

Accountabilities for implementing andmanaging the CMS should be assigned.

The process and responsibilities for definingand maintaining competency standards for

wells activities by the organisation should bedescribed.

This may be a role for the wells technicalauthorities for a well operator.

How are thesestandards measuredfor effectiveness andhow are the resultsmanaged?

An approved list of job or task basedapproved competency standards and aprocess for reviewing and revisingcompetencies should be available withassigned responsibilities for each element ofthe process.

Competency standards should be reviewedat periodic intervals or whenever there is achange in the wells activities.

If there are changesto the performancestandards, how arethey communicatedand measured foreffectiveness?

Competence standards should be availableto staff such that they are able to refer tothem and understand how they relate totheir activities.

3. CMS Cycle Phase 1 & 2: Establ ish Requirements and Design CMSHave safety criticalroles been definedand have safetycritical competencerequirements beenmapped againstthese safety criticalroles?

Oil & Gas UK Guidelines Table 1 provides atable of the minimum positions withinoffshore and onshore well’s organisationsfor competency assessment and statesLeadership and Supervisory competenciesshould be established and assessed for allthese positions.

The training and development needs ofrecruits must be established and differentlevels of competence identified and clearlydefined for different parts of the job.

Additional competencies should bedeveloped or assessed for all positions

Page 12 of 20




listed when working on challenging or highrisk wells.

Please identify anyadditional roles thathave been added tothe Oil and Gas UKlist of minimumrecommendedpositions.Please confirm,which of theseadditional roles areconsidered safety

critical

Note; The list will vary depending upon thevarious companies egDrilling Contractor – MODUs or DrillingContractor – PlatformWell operators etc.

Are attitudes,behaviours andleadershipperformancestandards applied toall staff assigned towell control,planning, design,examination,verification and

operationalactivities. If so, howis it accomplished?

Critical competencies should be identifiedfor all positions and have been described inKey Risk Areas and Skill Elements in Oil &Gas UK Guidelines.

These cover the lifecycle of the wellincluding well design, operations planning,operations execution, workover andintervention planning and execution,production well integrity and long term

integrity. Ref.: Oil and Gas UK GuidelinesTable 2.

4. CMS Cycle Phase 3: Implement CMS

In addition totechnicalcompetence doesyour system addressbehaviouralcompetence?

Critical competencies have been identifiedas ‘technical' and ‘leadership andsupervisory’.

Typical examples of leadership andsupervision skill elements have been

provided in Oil & Gas UK guidanceproviding example competency profiles forwell personnel.

Is team competenceevaluated to ensurethe right people arein the right place atthe right time toconduct both routinetasks and safetycritical activities?

Well operations are usually team basedactivities rather than individuals workingalone.

A gap analysis for team competence is agood starting point for assessment of thecompetency of a team.

Offshore installation owners or operators,and well operators need to assure

themselves that all personnel in welloperations are competent for the proposed

Page 13 of 20




work. They should ensure themselves, byaudit prior to the start of operations, that the

contractors have suitable policies,procedures and management controls inplace.

5. CMS Cycle Phase 3: Implement CMS

What trainingmethods are used?

Various training methods may include PCbased desk top training; computer basedtraining techniques, on the job training, theuse of simulators etc.

In-house and external training modules maybe used.

What learningobjectives are inplace, and are theysupported bysuitable modes oftraining egsimulators?

The most effective CMS are specificallytailored to manage the competenciesrequired for that particular organisation’swork activities and associated safety risksand provide a comprehensive picture of jobrequirements allowing a training needsanalysis to provide targeted and effectivetraining interventions and a framework foron going coaching and feed back.

What methods areused to assesstrainees and how isit ensured thesemethods aresuitable?

Assessment techniques can vary from;o direct methods of observation,

products of work and questioning;o indirect methods of witness

testimony, professional discussions,candidate statements andsimulation;

o Trade tests.

It is important to establish if trainees areassessed by suitable means and whetherstructured refresher training is conductedfor recognised safety critical or infrequent

safety related tasks in well operations. Team exercises and simulations may be

used for developing team competency,ranging from desk top exercises to the useof simulators.

How is it ensuredthe assessment iscarried out by anindividual competentto evaluate thetrainee?

Assessors must have a goodunderstanding of the concepts andprinciples of competency basedassessment.

Assessors may be qualified through variousschemes, eg OPITO’s competency

assessor award or NVQs, however someorganisations may prefer in-house training.

Page 14 of 20




The assessor should be technicallycompetent in the area being assessed.

Some companies use supervisors or linemanagers whilst others use dedicatedassessors.

How is thecompetency ofcontract staffassessed?

The competency of contract staff within theorganisation must be assured. Contract staffshould be assessed prior to hiring, at the start ofthe contract and during operations. This may bedone by:

Including contract staff in a welloperators or employers CMS on atemporary basis;

The company supplying the personnelhaving a competency assurance system,or

Individuals demonstrating their personalcompetency.

How is thecompetency of thirdparty services staffassessed?

The main duty holders, offshore installationowners or operators, and well operators,need to assure themselves that allpersonnel involved in well operations arecompetent for the proposed work.

They should do this by checking that thecontractors have suitable policies,procedures and management controls(including competency assurance for theiremployees) in place. This should be auditedprior to start of operations.

This would include, in particular, offshorepositions such as:

Mud logger, Drilling fluids engineer,Cementer, Well Service supervisor, WellTest supervisor, Coiled tubing supervisor, E-line and Electric line Supervisors.

6. CMS Cycle Phase 4: Maintain and Develop Competence

How is trainingvalidated?

The duty holder or employer must be ableto demonstrate that activities to be carriedout and the training and developmentrequirements have been defined e.g. byTraining Needs Analysis, and thatarrangements are in place to be able todevelop and train each individual andassess their competence via definedmethods.

There should be a system in place forongoing monitoring of competency by

Page 15 of 20




suitably competent supervisors, and internalmentors and coaches to assist in the

competency process. Some key roles e.g. the Well Examiner or

Drilling Manager may rely on some form ofExternal/ Internal Review.

How is it determinedwhether the traininghas delivered what itwas supposed todeliver?

There should be in place a system ofongoing monitoring for competencyincluding assessors and supervisors.

The CMS should define the maximumperiod between the formal competencyassessments between an individual andtheir assessor.

Are suitable trainingrecords maintainedand how are theyused?

A suitable system of maintaining trainingrecords for internal and external training, onthe job training and computer based trainingmodules must be in place.

These records must be available for theongoing development and training ofpersonnel to ensure personnel progressfrom a status of ‘not yet competent’ to fullycompetent.


How do you ensurethat only workerswho are deemed as‘competent’ areassigned to safetycritical tasks?

The duty holder/employer must be able todemonstrate that arrangements are in placeto ensure personnel (including contractorpersonnel) only carry out activities for whichthey have been assessed competent, Thismust ensure that people ‘not yet competent’cannot be ‘jumped’ into senior roles due to alack of experienced or competent personnel.

The duty holder/employer must be able todemonstrate that managers are aware of

the range of activities their personnel andcontractors are currently competent to carryout.

What triggers are inplace to ensure thatcompetencerequirements are re-evaluated and anynecessary trainingprovided followingchanges to process,

procedures, andconditions, eg HPHT

This is a part of the management of changeprocess and the duty holder/employershould demonstrate that there is guidance inplace which includes re-assessment ofcompetencies with installation of newequipment, higher risk well conditions, etc.

Page 16 of 20




well conditions?

How areassessment recordsmaintained?

There should be arrangements in place forthe maintenance of competencyassessment records, education and trainingrecords, certificates of competence, tradetests etc. and records of aptitude andsignificant event logs.

How is thecompetency ofcontract staffmaintained?

Contract staff should continue to beassessed during operations.

For contract or employee personnelarrangements should be in place to monitorperformance and if necessary have

arrangements in place to restorecompetence or when found to be necessaryremoval from the workplace.

How is the ongoingcompetency of thirdparty services staffassured?

Arrangements should be in place with thethird-party service provider to ensurecompetence of third-party services staff ismaintained by the service provider

Where necessary, arrangements should bein place to restore competence, or, ifnecessary removal from persons from thework place.


Is structuredrefresher trainingconducted for safetycritical andinfrequent safetyrelated tasks?

Competence criteria should be relevant tothe specific job or task and clearly linked tothe major accident hazard on site and reflecton site risks.

Major accident hazard for well operationsrelate to loss of containment, hydrocarbonrelease, blow out and explosion.

Refresher training in well control, and well

control techniques is standard in theindustry. It is normal practice when drillingHPHT wells to provide additional trainingusing simulation techniques, desktopexercises etc.

How are ‘not yetcompetent’assessmentsmanaged and howmany have beenmade in the last

12 months?

The duty holder/employer must demonstratethat he has the ability to manage those ‘notyet competent’, and to make a decision onthe suitability of the person for furthertraining and development, and if so, toprovide further training development to gain

sufficient experience prior to anotherassessment.

Page 17 of 20




A record of competence should be kept andthe duty holder/employee able to

demonstrate sufficient opportunity for theperson to consolidate any training given.

How is ‘teamcompetency’evaluated to ensurethat the correctpeople are in placeto conduct safetycritical activities?

Assessment of wells teams and theircollective competency and the process forassessment should be clearly set out plusthe process and managementresponsibilities for the assessed shortfalls incompetency and the competencydevelopment of individuals within the team.

Gap analysis techniques based on a riskand task based approach may be used.

Crew Resource Management (CRM) hasbeen used to cover non-technical aspects ofcompetency by some drilling contractors.


What systems are inplace to establishand maintain ‘trainer’and ‘assessor’competency?

The duty holder/employee must be able todemonstrate that those involved in theoperation of the competency system(including recruiters, trainers and assessors)have the combination of professionalcompetencies (related to their role) andoccupational competencies (related toknowledge, skill, experience, etc) which areclearly identified.

What systems are inplace to establishand maintainmanagers’competencies?

Management responsibilities for thoseoperating the CMS should be clearly definedand allocated and the training anddevelopment needs of the managersestablished.

Managers required to carry out competencyassessment should be suitably trained and

periodically re-assessed as part of the CMSprocedures.

10. CMS Cycle Phase 5: Monitor, Verify and Review CMS

What systems are inplace to enableworkforceinvolvement in thecontinuousimprovement of thesystem?

Refresher training and personnel briefingsshould be in place with feed back sessionsto help identify the need for and be able todeliver additional and refresher training andcheck for use of appropriate performancestandards, methods of assessment andconsistent use of procedures and work

instructions developed for the CMS.

Page 18 of 20




Is the competencemanagement system

subject tocontinuous top levelmanagement reviewWho is involved,how is the reviewconducted and howoften?

Oil & Gas UK guidelines state the CMSshould be under continuous internal quality

assurance. It is important that senior management

endorse and drive the CMS. A sense ofownership of the system is important,particularly for those carrying out key roleswithin the system.

Quality assurance of assessment decisionsis the key to the integrity of a competencymanagement system and may include thesampling of assessor’s judgments todetermine whether a decision is valid by adesignated internal verifier; conducting

exercises with assessors for consistency inassessors decisions. Check for how well thesystem works under stressed conditions, egshortage of skilled, competent personnel tofill safety critical roles.

Does a credible thirdparty audit thecompetencemanagementsystem? If so,provide details of the

third party and howfrequently they auditthe system

Oil & Gas UK guidelines recommend theCMS be audited every 3 years.

Competent personnel should carry out theaudit. They may be company personnel butthey should not be part of the welloperations team nor personnel responsiblefor management of the CMS.

HSE guidance would recommend the auditbe undertaken by an Auditor external to thecompany, but familiar with systems forcompetence assurance.

Audit of the CMS should look at the systemas a whole, sampling and checkingperformance and compliance over the entirescope of the CMS against the proceduresand the latest regulatory guidance.

Page 19 of 20



Appendix 2: Performance Assessment

The EMM Risk Gap should be judged on the basis of the responses to theinspection questionnaire and hence the Duty Holder’s Performance Scoreaccording to:

EMM RISK GAP

EXTREME SUBSTANTIAL MODERATE NOMINAL NONE NONE

TOPIC PERFORMANCE SCORE

60 50 40 30 20 10

Unacceptable Very Poor PoorBroadly

CompliantFully

CompliantExemplary

Unacceptablyfar belowrelevantminimum legal

requirements.

Most successcriteria are notmet.

Degree ofnon-complianceextreme andwidespread.

Failure torecognise

issues, theirsignificance,and todemonstrateadequatecommitment totake remedialaction.

Substantially

below therelevantminimum legalrequirements.

Many successcriteria are notfully met.

Degree of non-compliancesubstantial.Failures notrecognised,

with limitedcommitment totake remedialaction.

Significantlybelow therelevantminimum legalrequirements.

Severalsuccesscriteria are notfully met.

Degree ofnon-compliancesignificant.

Limitedrecognition ofthe essentialrelevant

components ofeffectivehealth andsafetymanagement,butdemonstratecommitment totake remedialaction

Meets most ofthe relevantminimum legalrequirements.

Most successcriteria arefully met.

Degree ofnon-complianceminor andeasilyremedied.

Managementrecogniseessentialrelevantcomponents ofeffectivehealth andsafetymanagement,andcommitment toimprovestandards.

Meets therelevantminimum legalrequirements.

All successcriteria are fullymet.

Managementcompetent andable todemonstrateadequateidentification ofthe principalrisks,implementationof the

necessarycontrolmeasures,confirmationthat these areusedeffectively; andsubject toreview.

Exceeds therelevantminimal legalrequirements.

All successcriteria arefully met.

Managementcompetent,enthusiastic,and proactivein devisingandimplementingeffectivesafetymanagementsystem to‘good practice’or abovestandard. Actively seekto furtherimprovestandards.

EMM INITIAL ENFORCEMENT EXPECTATION

Prosecution /EnforcementNotice.

EnforcementNotice / Letter.

EnforcementNotice / Letter.

Letter / Verbalwarning.

None. None.

Documents

Ed Well Competence