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control duties. 412 MMS could evaluate operator well control training programs
by auditing the operator’s training program, conducting written and hands‐on
413
testing, witnessing well control drills, and other methods.

Prior to August 2000, the regulations regarding well control training were
prescriptive. The rule prescribed the content of the well control training
curriculum and the length of the training class that each individual was required
to complete according to responsibilities. Additionally, MMS required that all
well control training providers needed to be approved by MMS.

In August 2000, MMS promulgated a performance‐based rule that
required lessees to develop and implement their training programs. This
regulation, which became effective on October 13, 2000, required each operator
to prepare a training plan laying out the company’s training philosophy
including the type, method, length, frequency and content of its training
program. Under this rule, MMS did not review and approve the training
providers nor did it specify the content of the training program. Rather, the
lessee/operator was responsible for determining the content, length, and
frequency of training programs.

Since implementing this performance‐based approach, MMS has used a
series of measures to periodically assess the quality of operator and contractor
training programs. Such assessments have included a review of operator
training plans, records, and methods. MMS has also reviewed the ways in which
operators verified the training conducted by contractors.

After the Macondo blowout, BOEMRE reviewed BP’s training plan, on‐
line training records, the methods by which BP evaluated Transocean and the
methods by which BP verified that contract personnel were trained. BOEMRE
also reviewed the contractor evaluation of Transocean. BP required all
individuals with well control responsibilities (both BP employees and contractor
employees) to be trained every two years. BOEMRE reviewed the training
records of all drilling personnel stationed on the Deepwater Horizon and all BP
personnel who had well control responsibilities. The Panel concluded that BP’s

412 30 CFR § 250.1503.
413 30 CFR § 250.1507.

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