This article present some guidelines for setting up HSE policy and procedures for exploration projects.

1. General

1.1 Policy

"Health, Safety and Environment" are the aspects of activities which relate to how work is carried out rather than to what is done. They must be given equal priority with the technical aspects of any operation. This is a primary responsibility of the Management to ensure that all the contractors involved, as well as all staff members, are aware and adhere to this policy.

1.2 Implementation

A specific HSE policy document must be prepared and communicated, based on the Company Guidelines. It should demonstrate commitment, understanding of HSE-critical areas, and control mechanisms. It should be signed by the Country Manager, displayed in premises and sites, and distributed.

Key features of an HSE policy:

1. Clearly identifies the company and the business areas to which it refers.
2. Should be produced in a bold, easy to read format.
3. Should be consistent in appearance with other company policies.
4. Should be restricted to one A4 page display of concise, action-oriented statements.
5. For an HSE policy to work it must have the following characteristics:

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  • High HSE awareness, understanding and commitment.
  • Supervisory capabilities and skills appropriate to the job.
  • Consistency, clarity, and realism in standards and procedures.
  • Pragmatic HSE management structures for each business area.

In addition to the general HSE policy, a new Company will need to establish specific policies for drugs and alcohol abuse, smoking, road safety and others.

2. Health

2.1 Medical care requirements

For general medical services, consider a staff doctor or a contract with a local doctor.

For specialized medical services, a contract with local hospitals/clinics and an evacuation plan must be in place. Generally organisations like embassies have private clinics and it might be possible to get an arrangement for their use by Company staff.

In the field the medical support to be provided depends on the operation. For an onshore operation, depending on the situation (seismic or drilling), activities can be concentrated in one site, or spread out during road construction or mobilisation. The type of medical support required for each worksite will depend on specific health risks, risk of injury, communications and access.

In some areas the provision of doctors on offshore drilling units is covered by local regulations.

As a rule each working group must contain someone who has had first aid training. This can be met by means of training courses given on site by the Company doctor or paramedic.

As a guideline, first aid should be available to all staff within four minutes, advanced first aid within one hour, and there should be access to a fully qualified doctor or hospital within four hours.

There must be a fully reliable telecommunications system, 24 hours/day availability of ambulance transport and doctor. If this cannot be guaranteed a qualified doctor must be on site with facilities to stabilise a badly injured patient to enable a medical evacuation even under difficult circumstances. The doctor should have at least five years relevant experience.

Replacement of the doctor(s) should be addressed.

Requirement for paramedics in addition to the doctor depends on the spread of the operation and the ease of movement between sites. If it is decided not to have a doctor on site then there should certainly be one on call from the office.

Remember that "part-time" doctors have different priorities except for obvious life-or-death situations.

2.2 Preventive measures

Preventive measures should be discussed and a guide for staff, contractors and visitors should be prepared. Copy of the guide should be issued to contractors and visitors, highlighting the period for which prophylactic drugs and vaccinations should be taken before arrival and continued after leaving.

Staff should be requested to visit a medical centre for a briefing and check-up.  Note that acceptable dental care may not be easily available in isolated areas and any necessary work should be done before departure.

2.3 General preventive health

An assessment of health risks associated with work and the work environment should be made.

There are a few additional practical points which may be mentioned:

• Advice may be given that domestic servants are medically examined before being taken on, with emphasis on the prevention of infectious diseases.
• The spraying or fogging of gardens may be considered.
• Drinking water quality should be assessed.
• A water filter of the type which filters the water through earthenware candles is commonly used. If this is done the water should be boiled after filtering rather than before.
• Water condensing out of air-conditioners gives a useful supply of safe water, as long as the container is covered, and it has the advantage of being free of colour and sediment.
• Avoid salads, peel fruit and eat well cooked meat.
• The quality of local restaurants can only be judged by experience, and the advice of other expatriates and senior local staff should be sought in the first instance.

2.4 Health in field locations

It is the responsibility of the Company to ensure that the relevant contractor maintains proper standards of hygiene, drinking water quality, etc. This must be done by audits conducted by the line supervisor and the doctor.

3. Safety

3.1 Safety management

The HSE Case, in addition to documenting SMS, provides a description of the hazards associated with the particular installation or operation and the means by which they have been assessed and are controlled. It details emergency preparedness and contingency planning measures aimed at safeguarding life, the environment and the asset as well as recovering from any emergency situation.

The HSE Case concludes with a Statement of Fitness which explains that the hazards associated with the installation or operation have been evaluated and measures have been, or will be taken, to reduce the risks to the lowest level that is reasonably practicable. The Statement of Fitness must affirm that conditions are satisfactory to carry out the operation.

The Safety Management System should be in place, and the HSE Case documented, before any operation can commence.

3.2 Implementation

Visible consistent management commitment is essential. Weekly meetings must be held between the Country Manager, the Department Heads and the major contractors (drilling, transport, engineering, etc.). These meetings should inculcate a team approach to operations and ensure that procedures involving more than one company are jointly discussed and agreed. Weekly site safety meetings should be reviewed and action agreed.

Some tenderers know that they won’t be able to comply with all the conditions of contract but, to improve their chance of being awarded the contract, says that they will comply. Regular inspections may not work as the contract will pretend that he has everything in order will be ready on the required date. To counter this, consider including  a provision in the contract award notification that the award is subject to orders for equipment being placed or delivered by a certain date, and key personnel to be in place by a given time. Penalty for missing items should also be considered.

In practice even if the Company has the option to terminate the contract, there is never enough time to re-tender and re-award - and the contractor knows this. He has to be persuaded that compliance with the standards is in his best interest, which in the short term is not always the case. The best method is good communication from the beginning, using the assurance that non-compliance with contractual standards will reduce profits.

The translation of safety procedures and guidelines into practice is the greatest challenge to the Management Team.

In the context of an operation in a remote area it has to be remembered that the objective of safety management is the reduction/elimination of accidents.

A policy which creates a major problem in every land-drilling operation in bush areas is that of wearing protective footwear. Labourers may be tripping all the time, which is counter-productive. The solution is to identify the risk and use the locally accepted method of small scale bush clearance. The most common injuries among bush clearers are likely to be cuts on the lower leg caused by their machetes being deflected. They may also be at risk from snake bites or scorpion stings. Some foot/lower leg protection is thus required, but not necessarily safety boots.  The optimum "protective footwear" is thus jungle boots with the lightest possible sole and foot, and canvas upper sections. If possible, a representative of the labourers should be involved in the discussion. If the wearing of special footwear can be associated with the status of the wearer there will be much less resistance to wearing them.

Note that labourers may "lose" the boots every night. Positive steps should be taken to prevent this.

It is likely that a transport contractor will not have seat belts in his trucks, or reversing alarms, or roll-over bars on his personnel carriers. This must be checked early so that these items can be imported and their fitting supervised. Alternatively, vehicles should be imported on a temporary basis.

3.3 Hazard identification

As part of the HSE Case a Hazard Register should be prepared to address all identified hazards associated with the location and operation planned.

An effort should be made to develop an atmosphere in which all staff and contractors can bring unsafe acts and situations to the attention of the responsible supervisor without creating ill-feeling. Also everyone (including supervisors) should be permanently on the look-out for any such act or situation and that if one exists it should be corrected immediately.

3.4 Reporting

All incidents, including environmental incidents and occupational illnesses must be reported through the "line", in exactly the same way as for technical operational data. The Company site representative must generate an atmosphere in which he is informed about even first aid incidents from the contractor supervisors, rather than hearing about them from the site doctor or medic.

Minor accidents should be included in the morning report; significant medical treatment cases, and lost time accidents, should be reported immediately to the Department Head concerned.

There is a natural reluctance among staff to report accidents. It must be emphasized that future accidents are avoided by learning from experience and this is the purpose of the reporting procedure and not to produce statistics. Note that supervisors/managers should not discuss in public the categorisation of specific accidents.

3.5 Incentives

The question of safety bonuses is a difficult subject. People do not deliberately have accidents so payment for avoiding accidents will not affect their behaviour - it is only training which can do that. However, the publicity attached to the bonuses will raise general safety awareness.

If the bonus is not earned individually but by groups, it should encourage labourers to watch over each other, but if one has an accident, the others may be upset for loosing their bonus. There could also be incentive not to report accidents.

If only one of the contractors have a bonus scheme, the others will be unhappy and so will company workers.

Disputes may also arise that the accident is caused by factors outside the control of the contractor.

In general “no accident” bonus payments are not recommended. A better approach may be to give out prizes (preferably in kind) for safety-related suggestions, mutually agreed training targets, etc. The management of this process will take a lot of administrative effort as all suggestions must be followed through and discussed with their originator. In any case, the system adopted must be simple and visible.

3.6 Audits

External Audit

Technical HSE Audit of the Company operations (transport, seismic, drilling, etc.) should be carried out by a combined team of external auditors, a Company representative and a representative of the relevant Contractor. Not only the hardware and the procedures should be audited, but also the supervisory and management control.

Pre-start-up audit

A pre-start-up audit of each aspect of the operation (drilling, transport, finance, etc. ) must be conducted to enable the General Manager to sign a "Statement of Fitness". This audit will be carried out by the Country Manager and Department Heads, with equivalent levels of the relevant contractors. This audit should cover hardware and procedures.

Weekly Audit

The second type of internal audit is a weekly audit of a specific aspect of the operation. This is carried out during the weekly inspection visit from the head office by whoever makes the visit. Normally there is a team of three - the Company visitor, the contractor visitor, and the contractors site safety adviser. The objective is to confirm continued compliance with procedures and practices. It is not just a “walk around” to check cleanliness of the site, although it must also check that controls in place to ensure that hardware and housekeeping standards are maintained.

Follow up is essential and every audit should be reported in a document that describes what was done, when, by whom and include a list of deficiencies. The findings will be presented at the weekly safety meeting to decide on the action parties and deadlines. Progress should be reviewed in the subsequent weekly meetings.

3.7 HSE meetings

The safety culture within an operation as part of HSE MS has to be reinforced by:

• Emphasizing to everyone that the Organistion/Contractor is not some impersonal organisation but that it is a group of individuals each of whom has responsibility for his own safety and for that of his colleagues.
• Involving everyone in that operation in the management of safety.
• Ensuring that everyone knows why decisions are being taken, and has the opportunity to discuss these at an appropriate level, i.e. to feel part of the decision making process.

The method which has evolved is to have a series of cascading safety meetings at each of which there is always a representative of the next higher level and the next lower level.

4. Environment

It must be addressed during the preliminary and preparation phases e.g.

• road network selection
• whether the rig move/ mobilisation will be by road, river, rail, or helirig.,
• location of the operations base/ office.
• choice of drilling prospects

There is a requirement to make an Environmental Assessment in the very early stages of preparation. It is necessary to estimate what the effects of the operation might be and, afterwards, evaluate exactly what they were.

There should also be consultation at an early stage with local authorities and or government. Consultation with the local community may also be appropriate.

Always consider reducing the hole and casing diameters in exploration wells - i.e. towards slim hole drilling.

4.1 Land location

Generally, it is a requirement to prevent contamination of the soil and this will be addressed by the Environmental Assessment. In some cases, the only solution will be to remove the topsoil and cover the whole site with an impermeable membrane plus fill from elsewhere. At the end of the operation the fill and the membrane are disposed of elsewhere, and the topsoil is returned. The vegetation cover should be reinstated, or encouraged to restore itself.

Note that this approach is in fact a transfer of pollution to a different location. The Environmental Assessment should include not only the requirement for protection of the local environment but also guidance on acceptable fill material and disposal location.

The mud pit dug to receive waste mud and cuttings will have to be made impermeable, either naturally with clay or by using plastic sheets, particularly if there is a risk of contaminating ground water. The waste mud, cuttings, and the impermeable barrier itself will have to be removed and disposed of elsewhere in a pit dug in a more suitable area. The Environmental Assessment will cover this point.

4.2 Waste material

4.2.1 Drilling

If oil based mud is used, ensure that the offshore drilling unit is fitted with a total containment system.

It is preferable to have a dual drain system, one for rain water which can be discarded without treatment, and one for mud and wash down water which can be collected and recycled.

If a significant amount of free oil reaches the collecting tank it can be mixed with diesel fuel and burnt through the production test burner. If there is only a small quantity it can be pumped back down the well before abandonment.

On a land location it may be necessary to construct a dual drain system, one for rain water and one for mud and wash water.

A balance sheet of mud chemicals should be kept, to account for: what goes into the mud system, what is in circulation, what has been lost down hole/ over the shakers or discarded to the waste pit, what has been discarded to the environment and method of disposal.

The balance sheet is not an operational requirement, but will be required when queries concerning types and volumes of waste are raised by the authorities.

4.2.2 Cuttings

4.2.2.1 General

The best method of disposal is slurrification and re-injection, which is particularly adapted to a multiple well scenario. Injection must be at a level deep enough neither to break through to the sea bed offshore nor to contaminate any potential water sources onshore. Therefore the well must be drilled to at least the surface casing depth and at this point the majority of cuttings will already have been produced. In an exploration environment, limited information will be available about fracture gradient and injectivity of the formations so it is prudent to prepare a land location large enough to accommodate the full volume of cuttings expected.

If slurrification and re-injection is not feasible wet cuttings have to be disposed of in large quantities. To minimise the wastes, use should be made of solids removal equipment like centrifugal cuttings dryer, so that fluids can be recycled into the mud system and solids to be disposed of are as dry as possible.

4.2.2.2 Using water-based mud

Offshore generally drilling fluids should not contain chrome-based lignosulphonates. In sensitive area (reefs, mud flats, areas with sea grass, active fisheries, presence of mammals or other protected species) cuttings must not be discharged overboard, but saved and disposed of elsewhere. If the water is naturally turbid it should be possible to discharge cuttings contaminated with water-based mud overboard. This should be addressed in the Environmental Assessment.

If the cuttings can’t be discharged overboard, it is necessary to discuss with the local authorities onshore to identify a suitable disposal site. Drying plus burial method requires a suitable climate.

Another possibility is to have the cuttings collected from the drilling unit in dump barges and discharged at sea in a non-sensitive area.

Both options will require the mobilisation of construction equipment or dump barges and tugs. Budget provision will have to be made at an early stage of the preparation.

From an onshore well, cuttings will be collected in the waste pit and dealt with at the end of the operation.

4.2.2.3. Using oil-based mud

The use of oil-based mud is in general discouraged. In some countries it is not allowed or total containment is required. This must be decided early in the project.

One alternative for oily cuttings is to wash them before discharge from the rig. This can be an economic solution if the equipment is already on the rig, so it is a factor to take into account at the tender evaluation stage. A second alternative is to use pseudo-oil based mud or incineration, if such facilities are available.

Note that cuttings from an oil reservoir drilled with a water based mud are not classed as "oily". The amount of oil will be close to residual levels when the cuttings go over the shakers.

If the cuttings cannot be dealt with offshore, they will have to be transported and dealt with in the manner described above for water based mud.

4.2.2.4 Packaging material

For consumables the ideal is to have the largest practical packages, which are returnable if unused. In a typical remote exploration operation there won’t be any bulk supply plant in the area so the largest packages are likely to be palletised 1.5 tonne expendable bags. The use of small bulk tanks should be investigated for consumables which would otherwise be provided in 25-kg sacks.

Offshore, pallets and empty sacks should be stored in neat bundles and sent ashore regularly. The most hazardous chemical is usually caustic soda. This should always be purchased in drums and empty drums should be rinsed out, punctured, and sent ashore.

On land the packaging of mud chemicals, must be disposed of in such a way that the local residents cannot be harmed and in agreement with local regulations. Caustic drums should be flattened by a bulldozer and disposed of in a deep pit, so that they can’t be used for roofing material, cooking, etc.

Sacks and pallets should be burnt daily, along with kitchen waste.

4.2.2.5. Sump oil and similar products

It is recommended to investigate the possibility of sale to local industries or workshops for re-use. Otherwise construct a small cement lined burning pit and burn the waste oil, along with the kitchen rubbish.

4.2.2.6 Metallic waste

Waste such as thread protectors, used bits, scraps produced by the welder, should preferably be taken to town and sold for re-cycling. If that is impractical because of the remoteness of the location, the best is to dump them in the cellar after abandonment and fill with cement.

4.3 Rehabilitation

The aim of rehabilitation is to leave the environment in such a state that it can recover to a situation similar to what it was prior to the operation. These should have been addressed in the Environmental Assessment.

Offshore there is normally little to be done other than cutting the casing below the mud-line level and leaving the sea-bed clear of large objects in order to prevent damage to fishing nets.

Onshore, the liquid contents of the waste pit have to be disposed of. The most convenient method is to pump it down the hole but this can only be done if it is certain that there will be no contamination of water sources. If this is not feasible the alternative is to fence the pit and leave until the liquid has evaporated. The cuttings can then be covered or treated further. Additional costs for mobilisation and demobilisation should not be ignored when budgeting for the operation.

Onshore, drilling locations should be cleaned up, debris should be buried into the mud pit or transported to a recycling site. The wellhead should be removed and a plate welded over the conductor. A vertical beam should be welded, extending above ground level, with the company name, well name and date. The cellar should be filled with cement and other metallic waste products. Pictures of the area must be taken and the local authorities must be informed of the position for inclusion on maps.

Any natural drainage which has been disturbed should be restored to the original channels, and any dams removed.

Generally roads constructed should be removed, however the national or local authorities should be consulted as people may want it left to assist in development of the area.

Roads may also give access for poachers and settlers to previously inaccessible or protected areas. If an area has an international protection status, consultation at local level may not be sufficient.