Gulf of Mexico Challenges with Contractor Verification - Skills and Knowledge.

Gulf of Mexico Challenges with Contractor Verification - Skills and Knowledge

www.chaucer.com Copyright 2014 Chaucer 4 Objectives Genesis of Contractor Verification (CV) Skills and Knowledge Challenges for Operators and Contractors Trends Across Industry Skills and Knowledge Assessment Positive Direction for Future

www.chaucer.com Copyright 2014 Chaucer 8 Evolution of SEMS Fixborough Incident (1974) Development of Process Safety Piper Alpha Incident (1988) API 75 RP - Development of Safety and Environmental Management Program

www.chaucer.com Copyright 2014 Chaucer 10 Elements of SEMS 1.General Provisions (Background Info) 2.Safety and Environmental Information 3.Hazards Analysis 4.Management of Change 5.Operating Procedures 6.Safe Work Practices 7.Training 8.Mechanical Integrity 9.Pre-startup Review 10.Emergency Response and Control 11.Investigation of Incidents 12.Audits 13.Records and Documentation Contractor Verification Skills and Knowledge

www.chaucer.com Copyright 2014 Chaucer 11 Genesis of CV Skills & Knowledge 11 30 CFR 250 Subpart S 250.1901 - (b) All personnel involved with SEMS program must be trained to have the skills and knowledge to perform their assigned duties. 250.1914 - (c) SEMS program must include procedures and verification for selecting a contractor as follows: Operator is responsible for making certain that contractors have the skills and knowledge to perform their assigned duties and are conducting these activities in accordance with the requirements in SEMS program. Operator must make the results of (their) verification for selecting contractors available to Bureau of Safety Environment and Environmental Enforcement (BSEE) upon request.

www.chaucer.com Copyright 2014 Chaucer 12 DOT Pipeline Parallel OQ is performance based Operator's responsibility to ensure that every individual, (operator and contractor) who performs a covered task on an operator's pipeline facility must: Either be qualified to perform those tasks or Be directed and observed by a qualified person

www.chaucer.com Copyright 2014 Chaucer 13 "It is the intent of this rule [SEMS] to hold the operator accountable for the overall safety of the offshore facility, including ensuring that all contractors and subcontractors have safety policies and procedures in place that support the implementation of the operator's SEMS program and align with the principles of managing safety set forth in API RP 75." ~ Federal Register on Oct. 15, 2010

www.chaucer.com Copyright 2014 Chaucer 14 Challenges for Operators Heavy responsibility for interpreting regulation correctly No common industry solution Different existing processes Different organizational structures Define minimum skills and knowledge needed to perform a job safely No clear definition from BSEE regarding acceptable risk

www.chaucer.com Copyright 2014 Chaucer 15 Challenges for Contractors Complying with different Operator solutions Cost of complying Subscriptions Technology Augmented staff Assessing skills and knowledge

www.chaucer.com Copyright 2014 Chaucer 18 How Prescriptive Is Necessary? Company and Employee Verification? HSE and Technical Requirements? General or Role Specific? Daily Check or Spot Check? Quality of the Requirements? Minimum Duration for Course? Approved Training Providers?

www.chaucer.com Copyright 2014 Chaucer 19 Trends Operators ABCDE HSE-CentricYes Company Level Verification Yes (In progress) Yes Employee Level Verification Not yetYes Role Specific Requirements NoYesNoYes Go/No Go Decision No Yes Same process for Operators employees No Yes No

www.chaucer.com Copyright 2014 Chaucer 22 In the meantime Change Management It is important to approach change management with all aspects in mind: Strategic planning Business modeling Organizational and cultural change Communications and marketing strategy Project management Trend and market analysis Dealing with the outcome of change How do I efficiently fit the change into already existing processes instead of just adding to my plate SIMPLIFY?

www.chaucer.com Copyright 2014 Chaucer 24 If you want some help Chaucer People All are seasoned and proven, combining specialized expertise with business acumen Operate at both the strategic advisory and hands-on execution / implementation level All about accountability and responsibility for desired end-results Expertise Business transformation, change management, project management and M&A are our heritage Areas of deep expertise are formalized and delivered within the context of practice disciplines Most of our consultants are thought leaders in their respective fields Approach Our core operating philosophy revolves around long-term client relationships Maximum flexibility of approach we leverage our methodology, the clients or a blend of both Solution alignment with clients unique business context no square peg / round hole scenarios Value Major value-add emphasis on making our Knowledge Management System a client asset Attractive rates for comparable level and expertise of resources Knowledge transfer is a key component of every engagement i.e., sustainable business value

Gulf of Mexico Challenges with Contractor Verification - Skills and Knowledge.

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