Title: Subpart
1Subpart O Training Plan
Basic Production Safety System (T-2)
Recent changes to Shell's Subpart "O" Training
Plan will have the following impact for SEPCo
employees and Core Contractors
21) All Shell and contract personnel working for
SEPCo in the GOM will now attend T-2 (Basic
Production Safety Systems) or T-2 Test out every
three years (prior requirement has been every two
years). 2) Core Contractors working for SEPCo in
the GOM will be allowed to participate in the one
day T-2 Test out provided they meet the criteria
in Shell's Subpart "O" Training Plan.
3Well Control training requirements and frequency
has not changed.
4For the purpose of Shell's plan, the terms used
have the same meaning as the MMS Subpart O
document. Shell has added three additional
terms, "experienced employee", "critical wells",
and "core contractors". Experienced employee and
critical wells have been defined in Shell's
Subpart "O" definitions. Shell is adding the
following definition for core contractor. Term
is as follows
5Core Contractor means a production employee of a
contractor, who while under contract for Shell,
successfully completes two "basic qualification"
API Training Provider Certification Program
(TPCP) approved Production Safety Systems courses.
6Procedures for training employees in production
safety
In general, Shell has adopted the American
Petroleum Institute (API) Training Provider
Certification Program (TPCP) for Production
Safety System Training (PSST) as a minimum for
all direct employees and core contractors
assigned production safety duties.
7Shell has been actively involved with its own
in-house production safety training program
since 1974. Many of our experienced employees
and core contractors have attended production
safety system training since that time.
As Shell is confident in the production safety
system capability of its experienced employees
and core contractors, our plan will offer them
the option of testing out of recurrent basic
production safety system training.
8Experienced employees and core contractors can
either attend a Basic Production Safety System
course (PS 2282) or a refresher course (PS 2293).
Course outlines are shown in Appendix D. The
refresher course will include a test out
requiring a score of 85 or above. Employees
must be able to demonstrate adequate retention of
production safety systems skills and knowledge
during hands-on demonstrations conducted during
the refresher course.
9Experienced employees and core contractors
failing to meet these requirements will not be
allowed a retest. They must attend a basic
production safety systems training course.
Certification cards issued through Shells TPCP
PSST course (PS2282) and Refresher (PS2293) are
valid for three years from date of issue.
10In the event employees fail the refresher, they
can return to the field with no assigned PSS
duties. Alternately, they can work under direct
supervision of an employee who 1) has current
certification from a TPCP certified program, or
2) has successfully completed a TPCP PSST
Refresher course. The employee will be required
to attend the three day Basic Production Safety
Systems Training course during their next work
cycle or the next available school date.
11Shell will require contractors to attend and
successfully complete PSST training at schools
currently approved by the API Training Provider
Certification Program. PSST Certification Cards
are also valid for three years from date of
issue. Shell will require all contractors to
attend API TPCP approved schools that include
hands-on exercises as part of their training
curriculum.
12To receive credit for completing any of the Shell
training courses referenced in this plan,
students must successfully pass written tests in
addition to other criteria (e.g., hands-on
demonstration in the lab). Shells criteria for
passing written tests is as follows For Test-Out
credit associated with refresher training -
minimum 85 Basic Production Safety System 70
13Refresher training is geared for experienced
employees and core contractors, and in general
will be only one day in duration. Since classroom
time is minimal, but to ensure mastery of content
material, Shell expects these students to perform
at a very high level on written testing.
14SEPCo MMS Subpart O Training Matrix For
Production Employees (Shell and Core Contractors)
15SEPCo MMS Subpart O Training Matrix For
Production Personnel (Contract)
16Training Provider Certification Program (TPCP)
TPCP Announcement 003-06 Subject PSST T2
Refresher/Test-Out Course Requirements The API
TPCP Subcommittee discussed the many comments
from industry respondents on improving the
training effectiveness of API certified
Production Safety Systems Training (PSST)
courses. The Subcommittee decided that the
following supplemental training requirements will
be added to TPCP requirements for all PSST T2
Refresher/Test-Out courses and will be subject to
audit review along with other TPCP and RP-T2
requirements. Courses should comply with these
supplemental training requirements immediately
and are subject to scheduled audits occurring
after May 17, 2006.
17- PSST (T2) Refresher/Test-Out Course (Typically a
one-day course) - 1. Frequency 3 years
- Prerequisites for test-out eligibility a.
6 Years offshore (OCS) oilfield experience
b. Successful completion of two
instructor-led PSST (T2) courses c. Must
possess valid PSST (T2) Certification - Minimum of ½ day Instruction with written and
practical test following (one day total) - 4. Minimum written exam score 85
- 5. Minimum hands-on (practical) exam score
100 - 6. Minimum number of questions 50
- 7. Written exam must be closed book
- 8. No re-test allowed. Refresher/Test-Out
failure requires attendance in a Basic T2
instructor-led course (typically three days)
18Basic Production Safety System Test-Out Training
Course Content Governmental Regulations
30 CFR 250 Subpart O 30 CFR 250
Subpart C 30 CFR 250 Subpart E
30 CFR 250 Subpart F 30 CFR
250 Subpart H 30 CFR 250 Subpart J
30 CFR 250 Subpart N
19 NTLs (Notice to Lessees) API Recommended
Practice 14-C Undesirable Events
Safety Analysis Tables (SAT)
Safety Analysis Checklist (SAC)
Safety Analysis Function Evaluation Chart (SAFE)
Process Component Analysis
Emergency Support System Written Test
20 Updates New Technology New
Equipment Best Practices
Hands-on Competency
21Basic Production Safety System Training (3
Day) Day 1 Governmental Regulations MMS Web
site Access and Information Locations API-RP-14-C
Discussion
22Day 2 API-RP-14-C Valves (SDVs and SSVs),
Actuators and Check Valves Auxiliary
Devices Pressure Relieving devices Sensors
23Day 3 Sensors Gas Detection Platform Pneumatic
Safety Shutdown Systems Electronic Safety
Shutdown Systems Surface Controlled Subsurface
Safety Valves Test