One of the most important elements of the Safety and Environmental Management System (SEMS) regulation requires operators to verify that workers have the skills, knowledge and experience to perform their jobs safely and effectively. However, it has become clear that some operators are having a difficult time complying with this SEMS requirement. Operators ask contractors to prove that their workers have the skills and knowledge to work under the SEMS regulations, and the contractors will likely verify this by providing the operator with several pieces of paperwork for every worker. This poses a problem for the operator who needs one cohesive document for each worker, proving that he or she has been verified.
Between SEMS and the revised SEMS II, there are roughly a dozen sections that require operators to evaluate field personnel. Industry has struggled with this task since the SEMS regulation was first released, and, not surprisingly, it was one of the most frequent noncomformances in the SEMS audits that were completed in November of 2012.
It is not that Operators haven’t tried. They require class certificates, resumes, and training matrices. In other words, the industry is drowning in paper. Operators need to prove that contractors have verified their workers meet the necessary requirements and they are finding that attending a class does not prove the student received adequate training or knows how to do the actual job.
The industry is trying to address the SEMS rules in a number of ways. Some operators require annual evaluations of workers’ skills and knowledge, but so far the results have been inconsistent. The Center for Offshore Safety (COS), which represents deepwater operators, is working on guidelines for individual company skills and knowledge management systems.
While those guidelines will give general direction to industry, contractors are still faced with the enormous responsibility of identifying the critical tasks that make up a worker’s job. The majority of jobs performed offshore do not have standardized job titles or descriptions, much less, critical tasks. If you ask two different companies what a “Maintenance Tech” worker does, it is likely that you will get two different answers. Once a company determines the skills and knowledge requirements for a worker to do his or her job, it faces the difficulty of determining how to properly evaluate the worker. An informal survey of contractors recently found that even the companies that do regular evaluations have no standards or training for the people who perform those evaluations.
OQSG and Lifeline Strategies are addressing the skills and knowledge challenge with a program called SEMSReady™. SEMSReady™ teaches company administrators and evaluators how to design and execute a documentable and auditable Skill and Knowledge Verification (SKV) program. The program is based on the 20-year process that the pipeline industry has undergone in developing its competency program, called Operator Qualification (OQ). Under OQ, each task is broken down into specific criteria and then trained subject-matter experts evaluate workers on those criteria.
The SEMSReady™ program offers a class for people who will administer the Skills and Knowledge Verification (SKV) Plan and the subject-matter experts who will evaluate workers under that plan. The administrator might be in the HR department, but the evaluators must have hands-on experience with the jobs they will evaluate. In many companies, supervisors or other qualified personnel are good candidates to become evaluators.
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