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On 14 August 2000, the U.S. Minerals
Management Service (MMS) published a new final rule regarding
the training of
employees working on the U.S. Outer Continental Shelf (OCS). The
new Subpart O rule became effective on
13 October 2000, and provides for a
two-year transition period from existing MMS regulations. All
lessees on the OCS will
be required to comply as of 15 October 2002, or
may do so earlier provided they notify MMS.
With this rule, MMS has shifted to a
"performance-based" type of regulation which extends a great
deal of flexibility to
operators in determining how their employees (and
their contractors' employees) are to be trained. The rule largely
does away
with existing requirements for well control training, leaving
it to operators to determine the best way to accomplish this.
IADC recommends that operators and
contractors adopt WellCAP as their
company standard for well control training. General
acceptance of
WellCAP will avoid conflicting training requirements between operators,
and would ensure operators that their
contractor personnel have been
trained to acceptable standards as defined by industry experts.
In the 14 August 2000 Federal
Register, MMS wrote: "MMS commends IADC for the WellCAP program
and acknowledges
the value WellCAP could bring in providing minimum well
control training requirements to lessees and contractors
worldwide."
MMS stated they intend to publish a proposed rule
which would incorporate WellCAP into the Subpart O regulations.
On 5 November 2001, MMS issued a Notice
to Lessees clarifying certain parts of the training rules. This
NTL discusses validity
of training certificates during the transition
period, and addresses questions concerns over "alternative training
methods."
 Click
here to download the NTL (PDF format, 70K)
Click
here to download the MMS Subpart O Guidance Document (PDF format, 218K)
(Second edition, November
2002)
MMS recently opened a
discussion board for operators and contractors to post questions
regarding Subpart O regulations.
The board is located at http://www.mms.gov/subpartODiscussion/
Additional information on
Subpart O can be accessed
from the Lessee
Training section of the MMS web site.
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