OFFSHORE MAJOR ACCIDENT REGULATOR

Offshore Petroleum Regulator for Environment & Decommissioning

The Offshore Wells Personnel Competency Management System Inspection Guide Open Government Status

Fully Open

Publication Date

19/01/2021

Review Date

19/01/2027

Review History

Date Changes

19/01/21 Issue 4 - Minor changes – transition to new IG format. 24/02/22 Issue 5 – Rebranding from OSDR to OMAR. 08/07/24 Issue 6 - 3 yearly review – minor changes.

Target Audience

OMAR Inspectors / ED Offshore Inspectors / ED Specialist Inspectors

Contents

Summary.......................................................................................................................................... 2 Introduction .................................................................................................................................... 2 Relevant Legislation ...................................................................................................................... 3 Action .............................................................................................................................................. 5 Background .................................................................................................................................... 5 Other relevant Inspection Guides ............................................................................................... 11 Organisation ................................................................................................................................. 11 Targeting ................................................................................................................................... 11 Timing........................................................................................................................................ 11 Resources ................................................................................................................................. 11

Recording and Reporting ........................................................................................................ 11 Appendix 1 Pre-visit information request ....................................................................................... 12 Appendix 2 Sample Inspection Agenda ......................................................................................... 13 Appendix 3 Inspection Questions and Success Criteria ................................................................. 14 Appendix 4 System Review ........................................................................................................... 31 Appendix 5 Application of EMM and Duty holder Performance Assessment ................................. 33 Appendix 6 References / Further Reading ..................................................................................... 35

Summary This inspection guide (IG) outlines an approach to the inspection of dutyholder’s arrangements with respect to the management of competency of wells personnel engaged in oil or gas well operations either offshore on the UK Continental Shelf (UKCS) or onshore in Great Britain, and the key areas that inspectors should consider when inspecting this topic. It also sets out the criteria for satisfactory and unsatisfactory performance factors against which dutyholder performance will be rated. References are made to technical standards and guidance that inspectors will use to form an opinion of legal compliance.

The Offshore Installations and Wells (Design and Construction, etc) Regulations 1996 (DCR) Regulation 21 requires well operators to have all personnel working on a well suitably informed, instructed, trained, and supervised so that risks associated with the well operation are reduced to as low as is reasonably practicable (ALARP).

The Borehole Sites and Operations Regulations 1995 (BSOR) Regulation 9 Schedule 2(2) requires the borehole site operator to have a competent person appointed to be in charge of every borehole site where employees are present, also there shall be sufficient competent persons appointed by the operator to exercise immediate supervision of borehole operations with a view to ensuring the health and safety of the persons at work at the site. BSOR Regulation 9 Schedule 2(3) requires that where borehole operations are being carried out, then a sufficient number of competent persons shall be provided with a view to enabling those operations to be performed safely.

Introduction The purpose of this IG is to provide information and guidance to ED / OMAR Inspectors to support the delivery of consistent and effective inspection of dutyholder arrangements to comply with The Offshore Installations and Wells (Design and Construction, etc) Regulations 1996 (DCR) and The Borehole Sites and Operations Regulations 1995 (BSOR).

This IG highlights key areas for inspection and provides a framework against which inspectors can judge compliance, assign performance ratings, and determine what enforcement action should be taken with respect to legislative breaches that may be found.

Competence is a very broad subject area that may span the length and breadth of an organisation, and the competency requirements for personnel involved in well engineering and operations activities will be different dependent upon the organisation’s activities, the job position, the tasks to be undertaken and the associated risks. The work activities and tasks carried out by different organisations will be different dependent upon their roles as mobile and fixed installation drilling rig dutyholders, or as well operators, or as third-party service providers.

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

‘Competence’ means the ability to undertake responsibilities and perform activities to a recognised standard on a regular basis. Competency is a combination of practical and thinking skills, experience, and knowledge, and may include a willingness to undertake work activities in accordance with agreed standards, rules, and procedures. Competency depends on the context and the environment in which the activity is performed, and on the working culture of the organisation.

‘Competence Management’ means the arrangements to control, in a logical and integrated manner, a cycle of activities within the organisation that will assure, and develop, competent performance. The aim is to ensure that individuals are clear about the performance that is expected of them, that they have received appropriate training, development, and assessment, and that they maintain, or develop, their competence over time.

Relevant Legislation There is a general duty under DCR Regulation 13 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 escape of fluids from the well; and

b) risks to the health and safety of persons from it or anything in it, or in strata, 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 which requires:

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

a) from an installation, the duty holder, and b) otherwise than from an installation, the well operator,

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

a) have received such information, instruction and training; and b) are being so supervised, that the risk to health and safety from such operation is reduced to the lowest level that is reasonably practicable.”

The regulation seeks to promote competence in those carrying out well operations by ensuring that they receive appropriate training (including on-the-job training), initial and refresher, information, and appropriate supervision. It requires the installation duty holder or well operator (when the well is being worked on other than from an installation) to ensure all staff are capable of carrying out the tasks allocated to them.

Duty holders can discharge their duties for personnel and third parties, other than their own by checking that specialist contractors carrying out operations have suitable policies, procedures, and management controls for the operations foreseen.

BSOR Regulation 9 Schedule 2(2) requires the borehole site operator to have a competent person appointed to be in charge of every borehole site where employees are present, also there shall be sufficient competent persons appointed by the operator to exercise immediate supervision of borehole operations with a view to ensuring the health and safety of the persons at work at the site. BSOR Regulation 9 Schedule 2(3) requires that where borehole operations are being carried

out, then a sufficient number of competent persons shall be provided with a view to enabling those operations to be performed safely.

Action Inspectors should review relevant documentation (see Appendix 1 Pre-visit Information Request) prior to the installation visit and test compliance during the installation visit against the “success criteria” given in Appendices 3 and 4.

Inspectors undertaking a wells competency management system inspection will need to be familiar with the OEUK Guidelines on Competency for Wells Personnel.

The questions contained in Appendix 3 were developed from the EI Research Report: Human Factors Performance Indicators for the Energy and Related Process Industries, and the survey questionnaire commissioned by the OSPRAG Technical Review Group.

By the conclusion of the inspection, it should be possible to

• determine if the competency management system for well engineering and operations personnel is suitable and sufficient.

When carrying out inspections covered by this IG inspectors should:

• assess duty holder responses against the success criteria in Appendices 3 and 4. • use the performance descriptors in Appendix 5 to: o determine the appropriate performance rating. o the initial enforcement expectation. o consider how and when the issues raised during an inspection are to be closed out.

Background The Oil Spill Prevention & Response Advisory Group (OSPRAG) was set up in the UK in response to the Macondo incident in the Gulf of Mexico in April 2010. The recommendations by OSPRAG’s Technical Review Group were accepted by Oil and Gas UK (now called Offshore Energies UK - OEUK) and led to the publication of Guidelines on Competency for Wells Personnel by them.

The OSPRAG Technical Review Group published the following recommendations 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 critical well integrity issues. We recommend that all CMS ensure that they effectively address the following minimum criteria within their systems:

• Leadership and Supervisory Competencies should be established and assessed 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 Offshore Driller Slick Line Supervisor Assistant Driller Completions Supervisor Derrickman Subsea Engineer Mud Logger BOP/LMRP Engineer Drilling Fluids Engineer Well Integrity Engineer Cementer Production Supervisor Drilling Manager Senior Completion Engineer Onshore Drilling Superintendent Completions Engineer Senior Drilling Engineer Petroleum Engineer Drilling Engineer Rig Manager Geology and Operations Geologist Reservoir Engineer Geophysics Development Geologist Subsurface Lead/Manager ** Position or Role titles will vary across organisations

• It should be recognised that appraisal systems alone do not constitute an effective competency assessment and CMS should clearly demonstrate competency is assessed. • Competency assessments for all positions listed above should demonstrate 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 for positions listed above are selected and assessed.”

Offshore Energies UK (OEUK) Guidance The Well Life Cycle Practices Forum (now called the Wells Forum) produced guidance on competency for wells personnel for OEUK. They were written by the Competency, Behaviours and Human Factors workgroup which included representatives from 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 GB.

The work-group has also produced example competency profiles for selected well personnel roles. They established key risk areas and skill elements defined 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 are applicable.

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

IADC Competence Assurance Accreditation Programme The International Association of Drilling Contractors (IADC) runs an accreditation system for drilling and service companies, which provides accreditation of companies Competence Assurance Program to assure these programs meet accepted practices to develop and ensure the skills of their personnel. Accreditation focuses on policy and procedures documentation, identification of job positions and definition of competencies, the assessment system, 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 by which workers can demonstrate their capabilities.

The IADC has also developed, at the request of HSE, guidance on the management of third-party competence for safety critical positions offshore. This guidance is targeted at any personnel who

are not direct employees of the drilling contractor; such as agency personnel provided by the drilling contractor, operator personnel and their sub-contractors providing drilling support and other associated services to the operator.

The guidance on the management of third party competence for safety critical positions offshore can be found at the following link IADC Guidance on the Management of Third Party Competence for Safety Critical Positions Offshore.

In addition to drilling contractors, some major service companies e.g., Baker Hughes and Halliburton have obtained IADC accreditation for their Competency Assurance Programmes.

Team Competence Well operations are usually team-based activities rather than individuals working in isolation. Assuring an appropriate mix of competencies at an individual level may be used to assess the competency of the team. A risk and task-based approach will facilitate efficient gap analysis for team competency assessment.

OEUK competency guidelines require all roles with a supervisory or project management element, should be assessed for leadership and supervisory competency.

Contract and Third-Party Contract Personnel OEUK competency guidelines require the competency of contract staff in the team to be assured. Contract staff should be assessed prior to hiring, 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 a temporary 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, and well operators), need to assure themselves that all personnel, including third party contractor personnel involved in well operations, are competent for the proposed work. OEUK guidelines require an audit prior to the start of operations to assure themselves that the contractors have suitable policies, procedures, and management controls (including competency assurance for their employees) in place.

Installation duty holders are required to ensure that no well operation is started unless personnel have received appropriate information, instruction and training prior to the commencement of well operations. This requires cooperation between well operators and installation duty holders to ensure that all personnel including 3rd parties are properly assessed, and competence is demonstrated prior to their joining a well operation.

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

The audit results supported the view that industry was providing key well control personnel with clear and comprehensive ranges of relevant information, and with adequate designs of displays, control panels, alarm and data systems. Although there were some rigs where practices needed improvement, overall the control panel and associated engineering system aspects from the audit were good.

Similarly, those aspects linked to how drilling personnel would be able to make the right judgement and the decisions on well control issues were good. Encouragingly, the audit received strong assurance on the driller’s authority to shut in wells when necessary. However, there was a broader range of performance here, and hence the need for those at the lower end to emulate the more advanced operators and drilling contractors, particularly in the wider use of scenario-based training.

The audit, however, identified a particular issue caused by the general shortage of experienced drilling personnel and although drilling activity has slowed since the audit, the prevalence of Drillers with less experience that was historically the case remain and industry wide skills shortages continue.

To ensure that the drilling operation is safe and successful, the drilling crew must continuously monitor displays and other information and make decisions on how they perceive and interpret that information. This ‘situation awareness’ of how circumstances are at the time and how they might develop in the future is a crucial element. Such activities take place within a complex relationship of client and contractors, both onshore and offshore, and with an intermeshing of different procedures, objectives, and technical monitoring arrangements. The relationship between

all the people and organisations involved must be clear so that everyone knows and understands their role and can deliver their contribution competently.

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

The drilling contractors reported having training and competency matrices in place, including job descriptions with continuous evaluation and competency assurance 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 competent assessors. However, because of the general shortage of experienced drilling personnel, it was acknowledged that personnel were often being promoted into positions early on in their training and development. This caused some organisations difficulties in keeping planned competency assurance programmes for drill crews fully effective.”

There was some variation in the type of drill training undertaken, ranging from task and IWCF- focused to scenario-based training. The audit identified a welcome improvement from solely ‘routine’ training towards the latter approach, which is designed to prepare crew for the range of information and decisions they will face. The wider involvement of third-parties in that learning approach was also acknowledged as an improvement.

‘Drill Well on Paper’ (DWOP) exercises were considered an excellent way for identifying unfamiliar elements in the well programme and hence exploring the offshore crew competence. Any gaps could be addressed, for example by bespoke onshore courses or adding experienced supervisors to the offshore crew to support learning offshore until it was clear that the crew had the required competence. It was acknowledged though, that there was a need to extend scenarios to later phases and further handling of a loss of well control situation.

Organisational factors addressed the safety management systems within the drilling contractor where issues were highlighted. Drilling operations and well interventions were usually under the direct control of the drilling contractor but there was close involvement with the client who often maintained overall responsibility for installation safety. Although all audited companies had bridging documents in place, the content and quality of these documents varied.

There was often a lack of GAP analysis of the systems / standards used by the drilling contractor and client / operator, and this reflected a lack of attention at the contract stage to