Subpart O

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Subpart O

Published on April 15, 2008

On March 31, 2008 the MMS issued NTL No. 2008-N03 in order to clarify the current policies and procedures found in 30 CFR 250 Subpart O – Well Control and Production Safety Training. The NTL was issued to clarify four particular areas of concern identified by MMS in regards to lessees: (1) conducting internal audits, (2) providing employees with adequate training, (3) misinterpreting the intent of the periodic training requirement, and (4) allowing contractors to work at their facilities before properly evaluating the contractors’ training programs.

	Section II of the NTL clarifies lessees’ responsibilities with respect to contract employees: The lessee must ensure that contractor personnel understand and can perform assigned duties. The lessee’s training plan must include procedures for evaluating the training programs of its contractors. a. Note: Per Section III of the NTL, this must be done prior to the contractor performing offshore work for the lessee. The lessee’s training plan must include procedures for verifying that contractor personnel can perform assigned duties. The lessee is required to ensure that its contractors’ training programs provide for periodic verification of well control or production safety knowledge and skills. a. Suggested methods for meeting this requirement are provided in Section IV of the NTL.
	Section V addresses the responsibilities a lessee has toward its direct employees and lists the minimum requirements of a training plan that covers direct employees.
	Section VI of the NTL gives lessees notice that MMS intends to initiate hands-on testing of offshore personnel in 2008 as the next phase in implementing the Subpart O regulation.

For more information on these issues, please contact Ken Smith, JCC VP Health & Safety Services, at (281) 578-3388.

This Regulatory Alert was prepared by J. Connor Consulting, Inc. to advise our clients of impending deadlines and applicable regulatory requirements. No official agency policy is implied.