PEC Training Policies and Procedures - PEC Premier Safety Operations, LLC

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PEC Training Policies and Procedures - PEC Premier Safety Operations, LLC
PEC Training Policies and Procedures
                                  PEC Premier Safety Operations, LLC

Copyright ©2015‐PEC Premier Safety Operations, LLC                     Version Rev. January 2015 | Final
Table of Contents
Summary of Changes                                                                              1

The Summary of Changes outlines any information that differs from the previous version
of the PEC Training Policies and Procedures.

Article I.     Purpose of the PEC Training Policies and Procedures                              9

Article II.    Applicability                                                                    9

Article III.   Definitions                                                                      9

The definitions listed in Article III contain commonly-used terms within PEC and their
meaning. Listed in alphabetical order, this list can be used as a guide to help with some
of the terminology used within other Articles of the PEC Training Policies and
Procedures.

Article IV.     Related Documents                                                             14

All PEC training materials are related to this document.

Article V.      Training Authorizations                                                       14

Section 5.01        Prerequisites to Become an Authorized PEC Instructor                      14
Section 5.02        Application and Scheduling                                                15
Section 5.03        Train-the-Trainer Program Classroom Requirements                          16
Section 5.04        Instructor Authorization                                                  16
Section 5.05        PEC Annual Instructor Update                                              17
Section 5.06        Unauthorized Instructor                                                   18
Section 5.07        Instructor Reactivation                                                   18
Section 5.08        Military Service Update Exemption                                         18
Section 5.09        Transfer of Instructor Status                                             19

Article VI.     Training Materials                                                            19

Section 6.01        PEC Copyrighted Material                                                  19
Section 6.02        SafeGulf and SafeLandUSA Accredited Material                              19
Section 6.03        Other PEC Training Materials                                              20
Section 6.04        Program Accreditation                                                     20
Section 6.05        Training Materials Licensing                                              20
Section 6.06        Use of Training Materials                                                 20
Section 6.07        SafeGulf and SafeLandUSA Credentials                                      20
Section 6.08        Transfer and Distribution                                                 21
Section 6.09        Storage and Security                                                      21

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Article VII.    Training Delivery                                                              22

Section 7.01        Class Scheduling                                                           22
Section 7.02        Facility and Classroom Requirements                                        22
Section 7.03        Training Fulfillment                                                       23
Section 7.04        Course Delivery                                                            23
Section 7.05        Proof of Identity                                                          24

Article VIII. Test Administration                                                              25

Section 8.01        Test Security                                                              25
Section 8.02        Prior to Testing                                                           25
Section 8.03        Testing and Grading                                                        26
Section 8.04        Class Completion                                                           27
Section 8.05        General Administration                                                     27

Article IX.     Documenting the Class                                                          28

Section 9.01        Training Documentation                                                     28
Section 9.02        Student Photographs                                                        29
Section 9.03        Submittal of Training Documentation                                        30
Section 9.04        Temporary PEC Identification Cards                                         30
Section 9.05        Permanent PEC Photo Identification Cards                                   31

Article X.      Customer Service                                                               31

Section 10.01        Order Processing                                                          31
Section 10.02        Training Fees                                                             32
Section 10.03        Training Support                                                          32
Section 10.04        Record or Document Research Fees                                          32
Section 10.05        Web Listings                                                              32

Article XI.     Quality Control                                                                32

Section 11.01        Package Validation                                                        32
Section 11.02        Policy Violations                                                         33
Section 11.03        Business Ethics                                                           34
Section 11.04        Anonymous Tip Line                                                        34
Section 11.05        Record Retention and Destruction                                          34

Article XII.    Training Provider and Instructor Evaluations                                   35

Section 12.01        Evaluation Types                                                          35
Section 12.02        Evaluation Frequency                                                      35
Section 12.03        Training Provider and Instructor Evaluation Protocol                      35
Section 12.04        Non-Compliance and Findings                                               35

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Section 12.05        Challenging Evaluation Results                                    36

Article XIII.    Attachments                                                           36

The End User License Agreement (EULA) is an agreement between PEC Premier
Safety Operations, LLC (PEC) and a PEC Authorized Instructor. The EULA includes the
PEC Training Materials License, Description of Other Rights and Limitations, Limited
Warranty, and Miscellaneous information. Each PEC Authorized Instructor is required to
sign the EULA.

Copyright ©2015‐PEC Premier Safety Operations, LLC                  Version Rev. January 2015 | Final
Summary of Changes

General Note on Changes
The format of this PEC Training Policies and Procedures document has changed from an
outline format to a paragraph format. Any information contained herein has remained the same
as revision B.0.0. unless noted in this Summary of Changes.

Article I.        Purpose
        Formerly Section I
        PEC/Premier Safety Management Inc. has changed its name to PEC Premier Safety
         Operations, LLC (hereafter called “PEC”).
        References to Subscriber Companies have been removed.
        The reference to separate procedure documents has been clarified.

Article II.       Applicability
        Formerly Section II
        References to Subscriber Companies have been removed.
        References to SafeGulf-only Training Providers and Staff have been removed.

Article III. Definitions
        Formerly Section III
        Active Instructor has been redefined and renamed as Authorized Instructor. The new
         definition clarifies that successful completion of the Train-the-Trainer program
         determines the PEC courses each Instructor is authorized to teach as well as which PEC
         material is available through the Instructor Portal.
        Audit has been renamed Instructor Evaluation and moved to Article III, Section 3.09.
         Additional information regarding this type of evaluation has been added.
        Audit Team has been renamed as Evaluation Team and moved to Article III, Section
         3.06.
        Background Verification definition has been changed to include E-verify as an example
         of the Social Security Number Verification Service that companies may use for
         verification.
        Credit Units have been renamed Activity Credits and have been moved to Article III,
         Section 3.01. The definition has been changed to accurately reflect the renamed
         Materials section in the Instructor Portal.
        Contractor (In-House) Instructor has been renamed In-House Instructor/In-House
         Training Provider and has been moved to Article III, Section 3.07. The definition has

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been rewritten to clarify the primary business mission of In-House Instructors and In-
         House Training Providers.
        Designated Instructor has been renamed Designated (Assigned) Instructor.
        References to the Instructor Acknowledgement and Signature Form have been removed
         from the definition for the End Use License Agreement (EULA).
        The Instructor Acknowledgement and Signature Form definition has been rewritten.
        The Instructor Portal definition has been updated to include a new feature, FAQ
         (Frequently Asked Questions). The definition has also been expanded to include the
         ability to download instructor materials, update contact information, and pay invoices.
        Information regarding Instructor Reactivation can now be found in Article V,
         Section 5.07.
        Master Instructor has been renamed as Master Trainer.
        Acceptance of the EULA and PEC Training Policies & Procedures is now a requirement
         of the PEC Annual Instructor Update
        PEC, SafeGulf, and SafeLandUSA Training Materials have been updated to include
         USB drives in the list of training materials.
        Professional Instructor has been renamed Third Party Instructor and has been moved to
         Article III, Section 3.24. The definition has been rewritten for clarification.
        The SafeGulf definition has been updated to remove PEC Core Compliance Annual
         Refresher and SafeGulf Orientation as courses that provide the SafeGulf credential.
         References to the SafeGulf Photo ID card have been removed and replaced with a PEC
         Photo ID card with SafeGulf credentials. Additionally, the web address for SafeGulf has
         been updated and details addressing the renewal of training have been added.
        The SafeGulf/SafeLandUSA Database definition has been updated.
        The SafeLandUSA definition has been updated to remove PEC Core Compliance
         Annual Refresher and SafeLandUSA modules for SafeGulf as courses that provide the
         SafeLandUSA credential.
        The Safety and Environmental Management System (SEMS) definition has been
         clarified.
        A definition has been added for Schools.
        The Student Information Test Answer Sheet (SITAS) definition has been updated to
         require students to complete all requested information.
        The Supplemental Test Answer Sheet definition has been updated to remove references
         to SafeGulf Orientation and to require that all requested information be completed.
        The Training Provider definition has been rewritten and now includes references to In-
         House, Schools, and Third Party Training Providers.
        A definition has been added for Training Provider Evaluation.
        The Training Tracker Database definition has been redefined to specify that the
         database is owned by PEC and includes the Advanced Training Tracker.
        The Train-the-Trainer Program has been updated to include a sentence outlining the
         process of the program.
        The following definitions have been removed:
              Audit Cycle

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    Background Verification Letter
                 Contractor Assistance Program (CAP)
                 Expired Instructor
                 Indemnification Agreement
                 Instructor Authorization
                 Instructor Reactivation
                 PEC Annual Instructor Log
                 Subscriber Company

Article IV. Related Documents
        Formerly Section IV
        References to SafeGulf Orientation have been removed.

Article V.        Training Authorization
        Formerly Section V
        The following changes to Prerequisites for Basic Orientation and PEC Core Compliance
         have been made:
              High School diploma or GED requirement has been removed.
              Added a requirement that the Applicant be currently employed as a safety
                 professional or trainer.
              HSE experience requirement has been rewritten.
              Other HSE-related industry/trainer certifications have been added to the
                 prerequisite for PEC Core Compliance.
        Prerequisites have been added for PEC Basic/10, GHS, JSA, and PEC Basic
         Orientation – Introduction to Pipeline authorizations.
        Changes to Application and Scheduling include:
              Contact information for the PEC Training Support Department has been added.
              The signature on the application should be original and not a computer font.
              Resumes must be updated and should include applicable training certifications
                 and instructor authorizations.
              References to Background Verification Letters have been removed.
              Applicants will be scheduled upon application approval and notified via email.
              Information about the non-refundable, non-transferable registration fee has been
                 added. Additional information regarding this fee has been added.
        Changes to Train-the-Trainer Classroom Requirements include:
              Late arrivals may be subject to dismissal from the class at the discretion of the
                 Master Trainer.
              Authorized PEC Instructors are required to sign the EULA along with the
                 Instructor Acknowledgement and Signature Form.
        Changes to PEC Annual Instructor Update include:

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   Note addressing required update activities based on Train-the-Trainer completion
                 date has been moved to the end of the section.
              Acceptance of the EULA is now a requirement of the Annual Instructor Update.
              Industry-related training certifications have been added to the list of acceptable
                 Activity Credits.
              Attending the Annual Instructor Update webinar is encouraged, but no longer
                 required.
        Inactive Instructor has been renamed Unauthorized Instructor and redefined.
        Instructor Reactivation has been redefined and the conditions have been added to
         further clarify which Instructors are eligible for reactivation.

Article VI. Training Materials
        Formerly Section VI
        Changes to PEC Copyrighted Material include:
             References to the SafeGulf Instructor Manual have been removed.
             References to SafeGulf and SafeLandUSA test questions have been removed.
             A list of copyrighted material has been updated and expanded.
        Changes to SafeGulf and SafeLandUSA Accredited Material include:
             References to SafeGulf Orientation have been removed.
             PEC Core Compliance-Spanish, Basic Orientation-Spanish and Basic/10 have
                been added to the list of accredited material.
             PEC Core Compliance Annual Refresher has been removed from the list of
                accredited programs.
        Other PEC Training Materials have been added as Article VI, Section 6.03, including
         GHS, JSA, PEC Basic Orientation – Introduction to Pipeline and the SEMS II DVD.
        Changes to Training Materials Licensing include:
             References to SafeGulf have been removed.
             Information regarding EULA acceptance has been removed. Article V, Section
                5.03 contains more information regarding this.
             References to revocation of PEC training materials in this section only (Training
                Materials Licensing) have been moved to Article XI, Section 11.02.
        Use of Training Materials has been removed and is now referenced in the EULA.
        Changes to SafeGulf and SafeLandUSA Credentials include:
             References to SafeGulf-only training materials and SafeGulf Training Providers
                have been removed.
             PEC Basic Orientation-Spanish has been added as a program that is both
                SafeGulf and SafeLandUSA accredited.
             References to PEC Core Compliance Annual Refresher being an accredited
                program have been removed.
             PEC Core Compliance-Spanish has been added as a program that is both
                SafeGulf and SafeLandUSA accredited.

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 Successful completion of PEC Core Compliance chapters 1-24 provides
               SafelandUSA credentials only, while completion of PEC Core Compliance
               chapters 1-25 provides SafeLandUSA and SafeGulf credentials.
             PEC Basic/10 is SafeLandUSA accredited only. Language has been added to
               address SafeGulf credentials.
        Changes to Transfer and Distribution include:
             Contact information for SITAS transfers has been updated.
             Training Providers with multiple transfer requests will be subject to PEC
               management approval.
        Changes to Storage and Security include:
             References to SafeGulf training materials have been removed.
             Licensed Instructors have been renamed to PEC Authorized Instructors.
             Outdated or unlicensed materials are no longer required to be returned to PEC.
               These materials should be destroyed.

Article VII. Training Delivery
        Formerly Section VII
        Class Scheduling has been updated to accurately reflect PEC’s role in scheduling
         classes. All Training Providers are required to schedule their own training classes.
        Training Fulfillment has been moved to Article VII, Section 7.03.
        Changes to Facility and Classroom Requirements include:
              The classroom must have identifiable emergency exits.
              Maximum class size has been defined as 25 students.
              Contact information for one-time variances has been updated.
              For classes greater than 74 students, Instructors must contact PEC.
              Instructor’s conduct has been updated to accurately reflect PEC’s expectation.
              Instructor responsibilities in regard to inappropriate student behavior have been
                expanded and are now a requirement.
        Changes to Course Delivery include:
              References to SafeGulf Orientation and training materials have been removed.
              General Guidelines have been added for all PEC classes taught.
              PEC Basic Orientation can be split up to meet client needs, though normal
                delivery is expected to be one continuous session. The requirement that all
                modules of PEC Basic Orientation be taught within one week of the start date
                has been removed. All applicable modules must be completed within 30 days of
                the start date.
              PEC Basic/10 course delivery requirements have been added.
              PEC Core Compliance can be split up to meet client requirements. The class
                must be completed within its entirety within 90 days of start date.
              Information has been added about PEC Core Refresher.
              Spanish materials can be ordered from PEC or downloaded from the Instructor
                Portal.

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  PEC Instructors can use a Translator for classes presented in languages other
                than English, however the PEC Instructor maintains responsibility for overall
                class delivery, test review and grading, and completion of class documentation.
                It is prohibited for a student in class to act as translator.
        Changes to Proof of Identity for PEC SafeGulf/SafeLandUSA Accredited Programs
         include:
              References to SafeGulf Orientation have been removed.
              Students must provide their date of birth as part of their identification.
              Acceptable forms of identification have been clarified.
              An In-House Instructor is required to check identification, even if the Instructor
                knows the students as fellow employees of the Training Provider.
              Copies of student documents, such as a driver’s license, passport, or other forms
                of identification, are not required to be submitted to PEC. Third Party Instructors
                and Training Providers are no longer required to maintain copies of identification
                documents such as driver’s license, passport, etc.
              Identification requirements for students with no company affiliation and
                international students have been clarified.
              The requirement for background verification letters has been removed.

Article VIII. Test Administration
        Formerly Section VIII
        The Test Types section has been removed.
        Changes to General Administration include:
             Information has been restructured and divided among the following sections:
                    Section 8.02 Prior to Testing
                    Section 8.03 Testing and Grading
                    Section 8.04 Class Completion
                    Section 8.05 General Administration
             References to SafeGulf Orientation have been removed.
             The PEC Core Compliance administration policy has been moved and redefined
               to include administering tests at the end of each chapter, not module, as
               previously written.
             A policy regarding reading test questions aloud has been added.
             Student responsibilities for completing SITAS have been added.
             Students are not allowed to use red ink to complete the test. Students are only
               permitted to use blue or black ink.
             The student must make any corrections or changes before submitting the test.

Article IX. Documenting the Class
        Formerly Section IX
        Training Documentation requirements have been expanded and clarified.

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    Effective January 1, 2015, PEC is no longer authorizing Training Providers to directly
         enter photos into the PEC Training Tracker database.
        The section containing Student Photographs has been moved to Article IX, Section 9.02.
        Information has been added regarding submitting student photographs via USB drive.
        GHS and JSA courses do not have permanent PEC Photo Identification cards. The
         tear-away cards on GHS and JSA SITAS are the student’s permanent PEC paper ID
         cards.
        Special handling of cards is no longer available.

Article X.        Customer Service
        Formerly Section X
        Order Processing now includes shipping and handling information.
        The department for placing training material orders has changed to the PEC Training
         Support Department.
        Changes to Fees and Compensation include:
              This section has been renamed Training Fees.
              The contact department for training provided by PEC has changed to the
                 Training Support Department.
              References to Subscriber Companies have been removed.
        Contact information for the PEC Training Support Department (Article IX, Section 10.03)
         has been updated.
        Specifics regarding web listings for Third Party Training Providers have been removed.
         Instructors should contact the PEC Instructor Administration Department for more
         information.

Article XI. Quality Control
        Formerly Section XI
        Business Ethics has moved to Article XI, Section 11.03.
        Information regarding Package Validation has been added.
        Policy Violations has been redefined and relocated to Article XI from Article VI.
        An email address for reporting tips has been added.

Article XII. Training Provider and Instructor Evaluations
        Formerly Section XII
        Formerly titled Auditing
        Instructor Audits have been renamed Instructor Evaluations.
        Facility Audits have been renamed Training Provider Evaluations.
        The location of Additional Information available on the Instructor Portal has been
         updated.
        Evaluations are now scheduled through the PEC Training Department.

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    The requirement that PEC provide notice of probation in writing within 48 hours has
         been removed. Additional references to probation have been removed and/or redefined.

Attachment A. Shipping and Handling
        Attachment A has been deleted. Information on Shipping and Handling can be found in
         Order Processing, Article X, Section 10.01.

Attachment B. End User License Agreement (EULA)
        This document has been rewritten to accurately reflect PEC’s expectations and is now
         Attachment A of the PEC Training Policies and Procedures.

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Article I.        Purpose of PEC Training Policies and Procedures
Section 1.01                Purpose
The purpose of this document is to set forth the policies to guide Instructors, Training Providers,
and PEC Premier Safety Operations, LLC (hereafter called PEC) in the conduct of training and
the use of PEC training materials. Documents that elaborate on the actions to implement these
policies can be found on the Instructor Portal.

Article II.       Applicability of Document
Section 2.01               Applicability
This document applies to all Instructors, Training Providers, and PEC, engaged in the training,
the use of, and sale of PEC training materials.

Article III. Definitions
Section 3.01               Activity Credits
Activity Credits are used to measure activity required to maintain status as an authorized PEC
Instructor. See the PEC Annual Instructor Update and PEC Activity Credit Requirements
documents in the Materials section (under Common Documents) of the Instructor Portal for
additional details on obtaining Activity Credits.

Section 3.02               Authorized Instructor
An Authorized PEC Instructor is currently associated with a Training Provider or PEC and in full
compliance with all PEC Annual Instructor Update Requirements. Upon successful completion
of the Train-the-Trainer program, Instructors are authorized to teach various PEC courses
depending on the level of authorization. Applicable course materials are available in the
Instructor Portal.

Section 3.03               Background Verification
The SafeGulf and SafeLandUSA Advisory Groups endorse the requirements for Background
Verification. This definition applies to workers who wish to work in the Gulf of Mexico and have
received a PEC Photo ID card with SafeGulf credentials and to workers who wish to work on
land-based (continental U.S.) facilities and have received a PEC Photo ID card with
SafeLandUSA credentials. These workers must provide evidence that they are who they say
they are. This constitutes the definition for background verification. The Advisory Groups
do not require a criminal or financial background check as part of this background verification.
The evidence provided by the worker and supported by their company indicates background
verification has been performed and that this verification included a Social Security Number
validation. For Social Security Number validation, companies are required to operate in
accordance with applicable state and federal laws. Companies may use the Social Security
Number Verification Service (ex. Form I-9 Employment Eligibility Verification-Department of

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Homeland Security or E-Verify to document compliance). The background verification
requirement applies to all companies or personnel wishing to receive accredited programs.

Section 3.04               Designated (Assigned) Instructor
Assigned Instructors are designated by PEC management to conduct specialized training
classes based on their qualifications. Assigned Instructors may not fill the role of a Master
Trainer unless designated by a written agreement.

Section 3.05               End User License Agreement (EULA)
The End User License Agreement (EULA) (Attachment A) applies to all PEC training materials.
By signing the EULA, the Authorized Instructor confirms that the EULA has been read, that all
parts are understood, and signifies agreement to comply with this license and with the PEC
Training Policies and Procedures.

Section 3.06               Evaluation Team
The Evaluation Team is a group of Evaluators, or a single Evaluator, who have been designated
to perform a given Evaluation. The Evaluation Team may include technical experts, Evaluators-
in-training, and/or an Operator from the SafeGulf/SafeLandUSA Advisory Groups. One of the
Evaluators on the Evaluation Team performs the functions of the lead Evaluator.

Section 3.07               In-House Instructor/In-House Training Provider
An In-House Instructor is employed by an In-House Training Provider. An In-House Training
Provider is a PEC-authorized organization that provides PEC training courses and whose
primary business mission is something other than teaching or delivering safety training. In-
House Instructors may present PEC training materials only to their own employees or their
subsidiaries. This does not include subcontractors. In-House Training Providers may use Third
Party Training Providers to supplement their training when necessary.

Section 3.08               Instructor Acknowledgment and Signature Form
This is a form signed by Authorized PEC Instructors that documents the PEC training materials
received and acknowledges the requirement for the Annual Instructor Update.

Section 3.09               Instructor Evaluation
This is a series of planned, independent, and documented assessments to determine whether
agreed upon requirements are being met. The first Instructor Evaluation is conducted during
the Train-the-Trainer program. Successful completion of the initial evaluation is necessary to
become an Authorized PEC Instructor.

Section 3.10               Instructor Portal
The Instructor Portal contains training news, FAQ (Frequently Asked Questions), material
downloads, common documents, PEC Annual Instructor Update invoices, recorded webinars
and a summary of Activity Credits received. Authorized Instructors can download Instructor
materials, upload Activity Credit documents, update contact information, and pay invoices
through the Instructor Portal. To login to the Instructor Portal, go to www.pecinstructors.com.

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Section 3.11               Master Trainer
Master Trainers conduct the Train-the-Trainer programs that include an evaluation of the trained
Instructor candidates, in addition to other delegated responsibilities. Master Trainers are
designated by written agreement and may not delegate their role to other Instructors (i.e., A
Master Trainer may not create another Master Trainer to conduct Train-the-Trainer programs).

Section 3.12               PEC Annual Instructor Update
The purpose of the PEC Annual Instructor Update is to keep Instructors informed about new
PEC training materials, new regulations, and changes to PEC Training Policies and Procedures.
PEC requires an Annual Update exam, Annual Instructor Update fee, annual acceptance of the
EULA and PEC Training Policies and Procedures, and submittal of the required Activity Credits
based on the Instructors’ level of authorization. For more information on the PEC Annual
Instructor Update and Activity Credit requirements, see the PEC Annual Instructor Update
document, which can be downloaded through the Instructor Portal.

Section 3.13               PEC Class Roster
The PEC Class Roster is an important part of the class documentation package and contains
specific information to aid in the tracking and validation of the class. The PEC Class Roster is
also the endorsement by the Instructor(s) that all information submitted is correct. All
information must be completed accurately and legibly.

Section 3.14               PEC Photo Identification (ID) Card
The PEC Photo ID card with the SafeGulf and SafeLandUSA credentials is intended to be
carried by the worker and is necessary to gain entrance into participating Operator facilities.
The PEC Photo ID card provides basic identification information, shows the level of safety
training achieved, indicates SafeGulf and SafeLandUSA credentials as applicable, and contains
a bar code traceable to the PEC Training Tracker Database.

Section 3.15               PEC Training Materials
PEC has a portfolio of training materials. This includes all PEC training manuals, workbooks,
DVDs, CDs, USB drives, tests, test keys, SITAS, supplemental test answer sheets and any
other related training materials produced by PEC. All PEC training materials are copyright
protected and are designed for use by Authorized PEC Instructors.

Section 3.16               Professional Liability Insurance (Errors and Omissions)
Third Party Instructors and/or Third Party Training Providers are expected to carry Professional
Liability Insurance (Errors and Omissions). Limits should be $500,000 per incident and
$1,000,000 aggregate. The insurance carrier should be rated A.M. Best A- or better.

Section 3.17               SafeGulf
An orientation training course that develops health, safety, and environmental (HSE)
requirements for the community of contractors supported by many of the major exploration and
production Operators in the Gulf of Mexico. A PEC Photo ID card with SafeGulf credentials is
issued upon completion of training requirements that allows contractors to travel offshore.
SafeGulf Orientation credentials can be achieved through the successful completion of PEC

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Basic Orientation (including the Offshore and SEMS module), PEC Core Compliance, or a
SafeGulf Training Provider accredited program that includes SEMS. For additional information,
refer to the SafeGulf website at www.safegulfweb.com. The SafeGulf Advisory Group does not
require annual orientation training to refresh or renew SafeGulf credentials once achieved.

Section 3.18               SafeGulf/SafeLandUSA Database
PEC has a web-based database that houses both PEC and SafeGulf/SafeLandUSA records.
Student credentials can be validated through two different webpages, www.peccard.com or
www.pectraining.com/card. You may search for a student by their PEC Photo ID card number
or by their first and last name and either their date of birth or the last four digits of their Social
Security Number.

Section 3.19               SafeLandUSA
The SafeLandUSA Advisory Group approved an orientation syllabus from which programs are
accredited, thereby creating orientation training courses that develop HSE requirements for the
community of contractors supported by many of the major exploration and production Operators
in the U.S. PEC courses are accredited by the SafeLandUSA Advisory Group. SafeLandUSA,
through the PEC Training Tracker Database, issues Photo ID cards when training requirements
are completed that allow the workers to enter land-based facilities. SafeLandUSA credentials
can be achieved through the successful completion of PEC Basic Orientation (Modules 1-4),
PEC Core Compliance, or a SafeLandUSA Training Provider accredited program. For more
information, refer to the SafeLandUSA website at www.safelandusa.org. The SafeLandUSA
Advisory Group does not require annual orientation training to refresh or renew SafeLandUSA
credentials once achieved.

Section 3.20               Safety and Environmental Management System (SEMS)
SEMS is a performance-focused tool for integrating and managing offshore operations. The
purpose of SEMS is to enhance the safety of operations by reducing the frequency and severity
of accidents. SEMS applies to all outer continental shelf (OCS) oil, gas, and sulfur operations
and the facilities under Bureau of Safety and Environmental Enforcement (BSEE) jurisdiction,
including drilling, production, construction, well workover, well completion, well servicing, and
U.S. Department of Interior (DOI) pipeline activities.

Section 3.21               Schools
A School is an authorized Training Provider organization whose primary mission is education. A
school can be a state or federal university, college, community college, adult education learning
center, career center, high school, or vocational school. Schools are considered Third Party
Training Providers. To become authorized, a School must do the following:

          a) Have a written agreement with PEC which defines how PEC training materials will
             be delivered and administratively controlled in accordance with PEC Training
             Policies and Procedures.
          b) Send a qualified applicant through the PEC Train-the-Trainer program (see
             Article V) or employ or contract with an Authorized PEC Instructor.
          c) Submit applicable Training Provider Evaluation fees.

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Section 3.22               Student Information Test Answer Sheet (SITAS)
The Student Information Test Answer Sheet (SITAS) documents test results, student evaluation,
and other student information. SITAS are required for all PEC training courses. Students are to
complete all requested information, including the student evaluation section. Each SITAS
contains a unique number used to track student training and is incorporated in the PEC Training
Tracker Database and on the PEC Photo ID card. SITAS must be procured though PEC prior to
training.

Section 3.23               Supplemental Test Answer Sheet
This is the form used to document retests or as a supplement to the original SITAS. The
Supplemental Test Answer Sheet is supplied for PEC Basic Orientation, PEC Core Compliance,
and PEC Core Refresher. When used, the Supplemental Test Answer Sheet must contain all
requested information, including signatures, and be stapled to the student’s original SITAS.

Section 3.24               Third Party Instructor/Third Party Training Provider
A Third Party Instructor is employed by a Third Party Training Provider. A Third Party Training
Provider is a PEC authorized organization that delivers training as its primary mission and offers
training services for compensation. Third Party Instructors may present PEC training materials
to their own employees, employees of Oil & Gas Contractors and Operators, or any other
individuals or organizations requiring their services. Instructors who teach for Schools fall into
this group (see Article III, Section 3.21). Third Party Instructors are expected to carry
Professional Liability Insurance (Errors and Omissions). Insurance details are provided in
Article III, Section 3.16.

Section 3.25               Training Provider
See Article III, Section 3.07 for definition of In-House Training Provider, Article III, Section 3.21
for definition of Schools, and Article III, Section 3.24 for definition of Third Party Training
Provider. The term Training Provider is also used in conjunction with organizations that provide
PEC SafeGulf accredited or PEC SafeLandUSA accredited programs.

Section 3.26               Training Provider Evaluation
This involves planned, independent, and documented assessments to determine whether
agreed upon requirements are being met.

Section 3.27               Training Tracker Database
This is a PEC-owned database designed to track any safety and training records submitted by
PEC and Training Providers. The Training Tracker Database includes the Advanced Training
Tracker, which is fee-based.

Section 3.28               Train-the-Trainer Program
This program sets forth a process of raising the competency of Instructors by requiring training
in the technical, business and instructional aspects of filling an Instructor role teaching PEC
courses. The Train-the-Trainer program authorizes Instructor candidates through successful
completion of either PEC Basic Orientation (referred to as the PEC Basic Orientation Train-the-
Trainer program) or PEC Core Compliance (referred to as the PEC Core Compliance Train-the-

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Trainer program). Instructor candidates must be approved via an application process prior to
entering either Train-the-Trainer program.

Section 3.29               Webinar
This is a web-based seminar or presentation format used by PEC to disseminate information to
Instructors on topics such as policy, procedures, PEC or industry news, materials development,
and release dates.

Section 3.30               Web Listing
The PEC website includes a “Find An Instructor” link to a U.S. map. Each Third Party Training
Provider is provided one web listing on this map for their main training facility. Additional web
listing may be provided for other company locations after required Training Provider evaluations
have been performed.

Article IV. Related Documents
Section 4.01               PEC Training Materials
All PEC training materials are related to this document.

Article V.        Training Authorization
Section 5.01               Prerequisites to Become an Authorized PEC Instructor
Basic Orientation Instructor Authorization.               Prerequisites for PEC’s Basic Orientation
Instructor Authorization are as follows:

          a) Experience in classroom instruction
          b) Currently employed as a safety professional or trainer
          c) Minimum of six months relative experience in the oil and gas industry
          d) Minimum of one year experience in providing HSE-related services or an HSE-
             related college degree from an accredited institution
          e) At least 50% of work with current employer dedicated to providing services related
             to the company HSE program(s)

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PEC Core Compliance Instructor Authorization. Prerequisites for PEC’s Core Compliance
Instructor Authorization are as follows:

          a) Experience in classroom instruction
          b) Currently employed as a safety professional or trainer
          c) Minimum of one year relative experience in the oil and gas industry
          d) Minimum of two years’ experience in providing HSE-related services or an HSE-
             related college degree from an accredited institution
          e) At least 50% of work with current employer dedicated to providing services related
             to the company HSE program(s)
          f) Other HSE related professional certifications and/or trainer certifications

PEC Basic/10 Instructor Authorization.                Prerequisites for PEC’s Basic/10 Instructor
Authorization are as follows:

          a)   PEC Basic Orientation or Core Compliance Instructor Authorization
          b)   Submit current OSHA 501 General Industry card or certificate
          c)   Sign PEC Basic/10 Instructor Acknowledgement and Signature Form
          d)   Procure Basic/10 Instructor materials

PEC GHS/JSA Instructor Authorization.                 Prerequisites for PEC’s GHS/JSA Instructor
Authorization are as follows:

          a) PEC Basic Orientation or Core Compliance Instructor Authorization
          b) Attend web-based training

PEC Basic Orientation – Introduction to Pipeline Instructor Authorization. Prerequisites
for PEC’s Basic Orientation – Introduction to Pipeline Instructor Authorization are as follows:

          a) PEC Basic Orientation or Core Compliance Instructor Authorization
          b) View the Pipeline Video in the Instructor Portal
          c) Successfully complete online Pipeline quiz available in the Instructor Portal

Section 5.02               Application and Scheduling
Instructor applicants should contact the PEC Training Support Department for information about
the application process.          The Instructor application can be obtained online at
www.pecsafety.com/training or by contacting the PEC Training Support Department at
(844) 848-5884. Each application must be completed in its entirety. Any incomplete information
will result in a delay in processing the application. The signature on the application should be
original and not a computer font. Each application must be accompanied by a copy of the
applicant’s valid state- or federal-issued photo ID (e.g., a Driver’s License), and a current, up-to-
date resume containing requested information, including but not limited to applicable training
certifications and instructor authorizations. Submission of the application or completion of the
application process does not guarantee acceptance into the Train-the-Trainer program.
Applications will be reviewed to determine whether qualifications and prerequisites have been

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met to enter the Train-the-Trainer program. Applicants will be scheduled for Train-the-Trainer
program upon application approval and will be notified via email. After application approval is
obtained, a non-refundable, non-transferable registration fee is required to reserve a position in
the class. Registration priority is based on the order in which PEC receives registration
payment from approved applicants. Registration is limited because of small class sizes so each
participant may receive individual attention and feedback from the Master Trainer. The
registration fee, payable by credit card, will not be applied to the cost of the Train-the-Trainer
program. In the event a class is cancelled by PEC, registration fees will be refunded.

Payment for the Train-the-Trainer program is due prior to class. Confirmation information will be
sent via email after payment has been received. Applicants that are not accepted into the Train-
the-Trainer programs will receive documentation outlining reasons why via email and will also
receive a follow-up phone call.

Section 5.03               Train-the-Trainer Program Classroom Requirements
Instructor candidates must:

         a)   Be present in the Train-the-Trainer program each day for the entire day. Late
              arrivals may be subject to dismissal from the class at the discretion of the Master
              Trainer.
         b)   Successfully complete the classroom portion of the PEC Basic Orientation Train-
              the-Trainer program and/or the PEC Core Compliance Train-the-Trainer program as
              applicable.
         c)   Successfully complete an Instructor Evaluation.

Instructor candidates are strongly encouraged to have access to a laptop computer for
assignments to be completed outside the Train-the-Trainer class. The Master Trainer evaluates
each student as they teach their assigned sections. Successful completion of the Train-the-
Trainer program is at the discretion of the Master Trainer. At the end of the Train-the-Trainer
program, Authorized PEC Instructors will receive all applicable PEC training materials, a blue
backdrop for photos, and associated documentation. Authorized PEC Instructors will be
required to sign the EULA, as well as complete an Instructor Acknowledgement and Signature
Form (see Article III, Section 3.08).

Section 5.04               Instructor Authorization
Instructor candidates who successfully complete the PEC Basic Orientation Train-the-Trainer
program will be eligible to teach the PEC Basic Orientation (including the Offshore, TRAP and
SEMS modules).

Instructor candidates who successfully complete the PEC Core Compliance Train-the-Trainer
program will be eligible to teach the PEC Core Compliance, PEC Core Refresher and PEC
Basic Orientation (including the Offshore, Terrorism Response Awareness Program (TRAP) and
SEMS modules).

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Section 5.05               PEC Annual Instructor Update
The PEC Annual Instructor Update is a requirement for all Instructors and must be completed by
January 31st each year. Completion of the Annual Instructor Update consists of completing the
following tasks:

         a)   Take the Annual Update exam, which will be an online process and consist of PEC
              Basic Orientation and/or PEC Core Compliance content and PEC Annual Instructor
              Update Webinar content.

         b)   Pay an Annual Instructor Update fee determined by PEC management. This fee
              will be invoiced to the Instructor directly through the Instructor Portal.

         c)   Accept EULA and PEC Training Policies and Procedures through Instructor Portal.

         d)   Submit proof of Activity Credits based on the level of authorization that the
              Instructor currently holds. Activity Credits measure activity required to maintain
              status as an Authorized PEC Instructor and can be obtained from the following
              categories: PEC specific (teaching classes and completing online webinar quizzes),
              attending related courses (student credit), attending related meetings and
              conferences, holding industry-related professional certifications (e.g., CSP, CIH,
              etc.) or by having industry-related training certifications or instructor authorizations
              from other organizations. Activity Credits earned during the course of the calendar
              year should be submitted to the PEC Training Department prior to December 31st.

                     i. PEC Basic Orientation Instructors must submit 3 Activity Credits annually.

                     ii. PEC Core Compliance Instructors must submit 5 Activity Credits annually.

         e)   Attend or view the PEC Annual Instructor Update Webinar, typically held in January.
              PEC management encourages webinar attendance, but it is not required. The
              webinar schedule will be sent via email to all Authorized PEC Instructors and will be
              posted in the Instructor Portal. If unable to attend the webinar, Instructors will have
              the opportunity to view the webinar content in the Instructor Portal,
              www.pecinstructors.com.

Additional information on the PEC Annual Instructor Update requirements can be found in the
Instructor Portal at www.pecinstructors.com listed in the Materials section (under Common
Documents).

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Note
       An Instructor who attended a Train-the-Trainer program between January 1st and
       June 30th must submit Activity Credits by December 31st of the current year and
           complete the Annual Update exam by January 31st of the following year.

        An Instructor who attended a Train-the-Trainer program between July 1st and
     December 31st of the current year must submit Activity Credits by December 31st of
     the following calendar year. In addition, these Instructors must begin taking Annual
                  Update exams after completing the next full calendar year.

Section 5.06               Unauthorized Instructor
An Instructor will become unauthorized for failure to be in compliance with the Annual Instructor
Update document or with PEC Training Policies and Procedures, or for not being associated
with a Training Provider. PEC will not process training packages or allow material orders to be
placed for Unauthorized Instructors.

Section 5.07               Instructor Reactivation
The PEC Instructor Administration Department may reactivate an Unauthorized Instructor if the
Instructor has not missed two consecutive PEC Annual Instructor Updates and meets the
following conditions:

         a) Transfers or associates with a PEC Authorized Training Provider, and
         b) Completes applicable/current Instructor Update requirements which may include:
                  i. Annual Update Fees (current and previous year)
                  ii. Annual Update Exam
                  iii. Acceptance of the EULA
                  iv. Annual Activity Credit Requirement

                                                  Note
        If two consecutive years pass without completing the PEC Annual Instructor Update,
       the Instructor must repeat the Train-the-Trainer program in its entirety at the expense
                       of the Instructor. This is not considered a reactivation.

Section 5.08               Military Service Update Exemption
Military members returning from overseas have 90 days from their return date to renew their
PEC Instructor authorization. Proof of military status must be shown. This includes a copy of
military orders for returning to the U.S. Reservists who serve more than 30 days and leave their
active duty must furnish a copy of their DD214.

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Section 5.09               Transfer of Instructor Status
In-House Instructors or In-House Training Providers may contact the PEC Instructor
Administration Department if they wish to transfer to Third Party Training Provider status.

PEC Basic Orientation Instructors who wish to become PEC Core Compliance Instructors must
be approved in accordance with Instructor prerequisites. Contact the PEC Train-the-Trainer
Department for more information.

Instructors changing companies or starting their own company must contact the PEC Instructor
Administration Department to update their records. This applies to changing of any personal
information, including address, phone numbers, email address, etc. The PEC Instructor
Administration Department can be reached during normal business hours at (985) 801-4157.

Article VI. Training Materials
Section 6.01               PEC Copyrighted Material
The following are considered copyrighted by PEC, whether marked or not and are not to be
used outside PEC Training Policies and Procedures and the EULA provided by PEC or the
companies owning the copyright unless expressly provided in writing from PEC:

         a)   PEC Instructor Manuals and training material
         b)   PEC Student Workbooks and Manuals
         c)   Videos provided through PEC
         d)   Graphics and photographs in all training material
         e)   PEC test questions
         f)   Student Information Test Answer Sheets (SITAS)
         g)   Supplemental Test Answer Sheets
         h)   PEC Class Roster
         i)   PEC Training Policies and Procedures
         j)   EULA
         k)   Instructor Acknowledgement and Signature Form
         l)   Any documents located on the Instructor Portal

Section 6.02               SafeGulf and SafeLandUSA Accredited Material
The following PEC courses are considered to be SafeGulf and SafeLandUSA accredited:

         a)   PEC Basic Orientation with the addition of Offshore and SEMS modules
         b)   PEC Basic Orientation-Spanish with the addition of Offshore and SEMS modules
         c)   PEC Core Compliance
         d)   PEC Core Compliance-Spanish
         e)   PEC Basic/10 with addition of Offshore and SEMS modules

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Section 6.03               Other PEC Training Materials
The following PEC courses are considered to be stand-alone and must be taught by Authorized
PEC Instructors:

         a)   GHS (Globally Harmonized System)
         b)   JSA (Job Safety Analysis)

The following PEC course must be taught by Authorized PEC Instructors and as an add-on
module to the PEC Basic Orientation, PEC Core Compliance or PEC Basic/10 courses. It may
be taught on a stand-alone basis to only students that have completed one of the courses listed
in the previous sentence.

         a)   PEC Basic Orientation – Introduction to Pipeline

The following PEC course is considered to be stand-alone and may be taught by Authorized
PEC Instructors:

         a)   SEMS II DVD

Section 6.04               Program Accreditation
Training Providers may have their training programs evaluated for SafeGulf or SafeLandUSA
against the PEC program accreditation protocol. Accreditation is granted after all protocol and
accreditation requirements are met. Contact the PEC Training Department for details.

Section 6.05               Training Materials Licensing
All PEC training materials are copyrighted and must be licensed for use.              Licensing is
authorized by the Instructor’s acceptance of the EULA.

Section 6.06               Use of Training Materials
Please reference the EULA for complete requirements for the use of PEC training materials.

Section 6.07               SafeGulf and SafeLandUSA Credentials
PEC Basic Orientation and PEC Basic Orientation-Spanish are both SafeGulf and
SafeLandUSA accredited. Successful completion of PEC Basic Orientation (Modules 1-4)
provides a student with SafeLandUSA credentials. Successful completion of PEC Basic
Orientation (Modules 1-4 and the Offshore and SEMS modules) provides a student with
SafeLandUSA and SafeGulf credentials. Students that have successfully completed the PEC
Basic Orientation (Modules 1-4) and have received the SafeLandUSA credentials need only
attend the Offshore and SEMS Modules of another PEC Basic Orientation class in order to add
the SafeGulf credentials. The student must be issued a new SITAS for the Offshore and SEMS
modules, pass the modules with a score of 80% of higher with only one retest and must sign the
PEC Class Roster in order to receive an updated PEC Photo ID card that includes the SafeGulf
credentials.

PEC Core Compliance and Core Compliance-Spanish are both SafeGulf and SafeLandUSA
accredited. Successful completion of PEC Core Compliance (Chapters 1-24) provides a

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student with SafeLandUSA credentials. Successful completion of PEC Core Compliance
(Chapters 1-25) provides a student with SafeLandUSA and SafeGulf credentials.

PEC Basic/10 is SafeLandUSA accredited. Successful completion of all modules of PEC
Basic/10 provides a student with SafeLandUSA credentials. In addition, successful completion
of the PEC Basic Orientation Offshore and SEMS modules at the end of PEC Basic/10 course
provides the student with SafeGulf credentials.

Section 6.08               Transfer and Distribution
PEC training materials are to be purchased directly from PEC. SITAS are tracked by the
Training Provider who purchased them. In the event a Training Provider wishes to transfer
ownership of SITAS to another Training Provider, this effort must be coordinated with PEC
before the transfer takes place.

The transferring provider must verify with the PEC Instructor Administration Department that all
parties are in good standing with PEC. They must notify the PEC Instructor Administration
Department by phone prior to making the transfer, then follow up with an email to
instructor@pecsafety.com stating the Training Provider and Instructors involved (both parties),
the type and quantity of training material transferred, and the applicable PEC ID numbers from
the SITAS. Training Providers with multiple transfer requests will be subject to PEC
management approval.

If PEC receives a SITAS from a Training Provider and the SITAS cannot be tracked back to that
Training Provider, that SITAS will not be processed.

If an Authorized PEC Instructor transfers training materials by any means, without receiving
permission from PEC before the transfer takes place, the act will be in violation of this policy
and subject to disciplinary action up to revocation of the Instructor’s authorization (See Article
XI, Section 11.02).

Section 6.09               Storage and Security
All PEC training materials must be stored in a secure area. Access to PEC training materials
must be limited to PEC Authorized Instructors or company employees trained to handle and
secure training materials.

Computers containing PEC training material related files should have security controls to
prevent unauthorized use. All PEC training material related files should be permanently deleted
from all computers that are released from authorized control (e.g., If computers are sold or
returned from lease, all PEC files should be permanently deleted prior to releasing the
computer).

Outdated or unlicensed materials should be destroyed.

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Article VII.        Training Delivery
Section 7.01               Class Scheduling
In-House Training Providers schedule their own training classes. A Third Party Training Provider
may be used to supplement the In-House Instructors as applicable. Third Party Training
Providers schedule their own training classes.

Section 7.02               Facility and Classroom Requirements
The classroom must be an environment conducive to learning, which means it must meet the
following requirements:

         a)   Clean
         b)   At a comfortable temperature
         c)   Well lit
         d)   Free of distractions
         e)   Students will be provided a chair and writing surface
         f)   Writing surface must be large enough to accommodate materials and still have room
              to take notes
         g)   Must have identifiable emergency exits
         h)   A break area must be available to all participants
         i)   Restrooms must be available to all participants

The maximum class size is 25 students. One to five additional students may participate in the
class with a written one-time variance from the PEC Instructor Administration Department.
Classes with 26-49 students require two Authorized PEC Instructors. Classes with 50-74
students require three Authorized PEC Instructors. All PEC Instructors are required to be
present for the duration of the class and all Instructors are required to sign the PEC Class
Roster. For class size greater than 74, please contact PEC for a variance.

Instructors must conduct themselves professionally, including but not limited to:

         a)   Not being under the influence of drugs or alcohol
         b)   No profanity
         c)   No negative comments about specific companies or industry segments
         d)   No endorsements or disparaging remarks about specific brands of equipment
         e)   Wearing office casual attire to conduct the class
         f)   Encouraging students to interact and participate

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Instructor responsibilities regarding inappropriate student behavior include:

         a)   Not allowing students to engage in negative comments regarding Employers,
              Competitors, Customers, or Regulatory Agencies
         b)   Asking disruptive students to leave the class. If the student leaves the class,
              document the reason on the SITAS and submit to PEC with class documentation. If
              the student refuses to leave the class, recommend calling the local authorities to
              have the student removed.
         c)   Not allowing students to sleep in class
         d)   Not allowing smoking, drugs or alcohol use in the classroom
         e)   Personal electronic devices can be used only at the discretion of the Instructor and
              are strictly prohibited in the classroom during testing. Cell phone settings should be
              set on vibrate or turned off during class.

Section 7.03               Training Fulfillment
Fulfillment of the training is between the student and the Training Provider. Completion of
training requirements is the responsibility of the Training Provider. PEC Photo ID cards will not
be issued unless all requirements of the PEC Training Policies and Procedures are met.

Section 7.04               Course Delivery
General Guidelines. PEC Basic Orientation, Core Compliance, and Core Refresher are in-
classroom, Instructor-led courses. Distance learning is strictly prohibited. Modules or chapters
must be presented in their entirety and not broken across class sessions. A test must be
completed on the SITAS the same day the module or chapter is presented. A PEC Class
Roster must reflect all days and hours trained. Modules or chapters must be presented in the
order identified in the PEC Instructor Manual. Refer to Article VI, Section 6.07 for additional
information on SafeGulf and SafeLandUSA credentials.

If a student leaves a class early and returns another day to complete the class, the Training
Provider is responsible to secure the original SITAS and a copy of the original PEC Class roster
for that student along with the documentation for the date the student completed the training.

PEC Basic Orientation must have a minimum of 8 hours of training and must be presented in
the order identified in the PEC Instructor Manual. Normal delivery is expected to be one
continuous session. PEC Basic Orientation Instructors may vary course delivery to meet vendor
requirements (e.g., Two 4-hour days, one 4-hour day per week for two weeks, etc.). All
applicable modules must be completed within 30 days of the start date.

PEC Basic/10 must have a minimum of 13.5 hours of training and be covered in two
consecutive days. PEC Basic/10 must be presented in accordance with the PEC Basic/10
Course Outline, which includes the PEC Basic Orientation (Modules 1-4) and all applicable
videos and is available only to Authorized PEC Instructors who maintain OSHA General
Industry Outreach credentials. The Offshore and SEMS modules may be added after
completion of Basic/10 training to earn SafeGulf credentials. See Article V, Section 5.01 for
requirements to be authorized to teach PEC Basic/10.

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