Driving remains one of the highest risk activities carried out within the oil and gas exploration industry on a daily basis (according to OGP). Driving risk increases in countries where driving habits and road conditions are not consistent with international accepted road and driver safety standards (which lower the risk of motor vehicle accident (MVA)). Road safety has been identified as a high risk event from the commencement of Company operations in country. A recent MVA during the drilling operations at Topkhana 1 has again highlighted this risk and identified the requirement to put in to place a Road Safety Plan (RSP) to ensure, as far as reasonably practicable, adequate road safety for all Company workplace vehicles. Some vehicle risk mitigation measures included in this RSP are already functional, such as the Journey Management Plan and No Night Driving Policy.
A high volume of vehicle journeys are required for any Company project, ranging from seismic operations to drilling operations. Vehicles are required to transport people and equipment to the workplace, distances as short as a few hundred metres, to distances in excess of a thousand kilometers. Moving drilling rigs could exceed 180 heavy loads in single trucks or multi-vehicle convoys in short time periods. Seismic operations have included up to 140 vehicles in use daily. Travel routes vary from multi-lane paved highways to newly constructed gravel roads or potentially off road 4x4 driving. Hazards include both poor drivers and challenging road conditions (steep grades, sharp corners, uneven roads, poor road visibility, etc). Travel routes in remote areas are frequently on poor public gravel roads which pass through small villages which are occupied by unwary children and seniors. To reduce the risk of motor vehicle and pedestrian accidents, vehicles must be sound and be driven carefully at appropriate speeds by competent, unimpaired and alert drivers.
Purpose
The purpose of the RSP is to reduce the risk associated with motor vehicle travel and to define practical actions which can be put in effect to mitigate road safety risk. This document does not include detailed procedures, but specifically highlights the methods which will be employed by Company to mitigate the risk of MVA’s. All Company personnel must accept full responsibility for managing our own road safety and that of our contractors and subcontractors.
Company has identified high risk activities and subsequently developed a strategy to highlight these activities (The 10 Golden Rules) with the goal of reducing future incident frequency. The Golden Rule which highlights vehicle safety is:
Golden Rule # 9 – Operate Vehicles Safely.
We never operate vehicles without:
- Conducting a pre-trip vehicle inspection, assessing the risks and planning accordingly.
- Ensuring the driver is properly licensed for the class of vehicle and free from fatigue, drug or alcohol impairment.
- Driving with care at appropriate speeds for road conditions, and ensuring all occupants fasten seatbelts.
- Avoiding the use of all mobile communication devices and other driver distractions, while using any company-leased vehicle on company time.
- Designating safe areas while working around moving vehicles.
This Golden Rule and associated requirements will be reviewed regularly with Company personnel and Company Contractors (and Subcontractors) in various forums such as:
- Contract kick-off meetings
- Pre-spud meetings
- Pre-job safety meetings for operations requiring vehicle movements
- Daily Security meetings (Company Security manages most personnel vehicle movements)
- Worksite weekly safety meetings
- Monthly contractor HSE meetings
- Service quality meetings
It is the responsibility of every Company Site Supervisor to ensure that the mandatory requirements of this Golden Rule are followed for every journey. All Company personnel have a right and a duty to intervene (ie Stop the Job) if these requirements are not being met.
All Company vehicle operators and Contractors must be informed of the requirements of the Road Safety Plan prior to their commencement of work. Such orientation must be documented and concluded with the agreement that the requirements of the RSP are understood and will be followed.
Responsible: Company contract owner.
All Company's operations are required to follow a Journey Management Plan (JMP). The JMP is a requirement for all personnel, equipment and supplies movements. The purpose of the JMP is to regulate motor vehicle journeys, to assist vehicles if incidents occur while travelling, to ensure that all vehicles arrive safely and according to schedule at the work site, to enforce the no night driving policy and for security control purposes.
Responsible: Company Logistics Coordinator, in cooperation with the onsite logistics and security team and with Company Security Office.
Vehicle Inspections
All vehicle operators (drivers) will be required to conduct a documented pre-trip vehicle inspection prior to commencement of any journey or start of shift. The pre-trip walk around will inspect for any deficiencies such as fuel, oil, tires, water, lights (headlights, brake lights, signal lights), brakes, seatbelts, etc.
All vehicles must be mechanically sound and fit for purpose. Vehicles that arrive on site in poor mechanical condition are to be refused entry and will not be used under any circumstances.
Vehicles are to be maintained and inspected according to the requirements stipulated in the Contract, in the Project HSE Plan, or as a minimum, all vehicles must be inspected on a monthly basis by a qualified inspector.
Company and all Contractors are required to use a documented vehicle inspection process. Company will review/audit Contractor’s inspection procedures and inspection records.
Responsible: Vehicle operators.
Road Safety Equipment
Company will provide recommended minimum equipment checklists for Company and contractor operated vehicles to allow for response to mechanical problems, a MVA and potential injuries to people in the event of a MVA or onboard medical emergency. The checklists will cover items such as first aid equipment, tire jacks, spare tires, tool kits, warning triangles, drinking water, mobile telephone, satellite phones, Track 24, etc.
Responsible: Vehicle operators.
Local Benefits Hired Vehicles
All vehicles and drivers hired from local communities which are designated local benefits according to the Company Local Benefits Requirements shall be required to meet or exceed all requirements herein defined. Any inspections or audits shall comply with this RSP in every respect. Minimum vehicle inspection standards or operator competency standards will not be lowered because the vehicles or operators are from the local community.
Responsible: Company supervisory, HSE & community relations (CR) personnel.
Required Documentation
All vehicles must have valid vehicle registration and all drivers must have valid driver’s licences to meet minimum Iraqi requirements. All inspections or assessments must be recorded on paper and the information filed for future reference.
Any vehicles carry hazardous goods are required to carry a copy of the Material Safety Data Sheet(s).
Responsible: Vehicle operators.
Control of Approved Vehicles and Operators
There is a requirement to ensure all vehicles and operators working on Company work sites are approved. The control procedures put in place (to be defined) will confirm (by visual means) that vehicles and vehicle operators meet the minimum requirements of this RSP.
Responsible: Company Site Supervisor.
Road Safety Assessments
A road hazard assessment is an inventory of road hazards that exist along a documented route. It is used to identify high-risk roads, to communicate road hazards to employees and contractors, and to identify any additional driver training which may be appropriate for the road conditions. This will ensure that hazards are identified in advance and mitigation measures (warning signs, guard rails, etc) are put in place prior to the road being authorized for use in Company operations.
Potential road safety hazards could include:
- In vehicle use of hand held communication devices.
- Driver fatigue.
- Areas of habitation. For example, small towns, villages and other smaller habitation areas, where the rise in the amount of vehicular traffic creates an increase in risk to the population (consider by-passing these areas).
- Pedestrians.
- Bridges (width, capacity and approaches).
- Adverse road conditions (e.g., gravel, lease roads and poor weather conditions).
- Narrow road sections, blind corners and hilltops.
- Areas with reduced speed.
- Sloped and cambered surfaces.
- Wildlife and livestock.
Control measures may include:
- Road signs depicting speed limits, manmade or topographical hazards, and advisories such as steep grades, overhead power cables, hidden intersections, etc.
- Ongoing road maintenance, including repair.
- Watering of gravel roads when dust becomes a safety hazard.
- Requirement for vehicles to operate with headlights and taillights “on” at all times for improved visibility.
Adequate controls will put in place to mitigate any identified hazards. The road hazard assessment will be provided to relevant road users to assist with trip planning.
Responsible: Company HSE.
Training
Company contracts include the requirement for Contractors to ensure equipment operators (drivers) are trained in off road driving, highway driving, defensive driving and vehicle recovery. Company may also conduct additional Defensive Driving training for contracted vehicle operators.
Assessments
All vehicle operators (drivers) are required to pass a driver assessment prior to commencing work. A designated Company or third party assessor will perform driver assessments as required. The format of the assessment will be as follows:
- Pre-departure vehicle checks.
- Driver competence (road test).
- Minimum vision requirements.
- Duty time exceeded?
- Identification of future training requirements.
- Confirmation of valid driver`s licence for vehicle type.
All operator (driver) assessments will be documented. All tested operators will receive a final competency rating according to the following scale:
- Distinction
- Credit
- Pass
- Weak pass
- Fail
A written report for each operator will summarize the assessment, and will include individualized assessment information such as strengths, weaknesses and requirements for additional training. The minimum requirement to pass the operator assessment is Weak Pass. Operators achieving a Fail assessment will not be allowed to operate vehicles on Company work sites until a minimum passing grade is obtained.
Enforcement
All vehicle operators (drivers) are required to meet the minimum competency assessment. Failure to meet the requirements herein contained will result in immediate dismissal.
Responsible: Company vehicle contract owner.
Vehicles will make use of either benzene or diesel fuel in their vehicles. All vehicle operators (drivers) or designated re-fueling personnel shall be familiar with safe re-fueling procedures and hazards, including flammability hazards, and environmental spill hazards.
Responsible: Company vehicle contract owner.
In the event of a spill of environmentally sensitive products, there are limited resources available for clean up. If the spilled products are deemed hazardous, the Company Emergency Response Plan will be activated and followed accordingly. All vehicles transporting hazardous substances are required to have in the same vehicle the relevant MSDS.
Responsible:
To maintain clear communication and to provide contractors with the minimum requirements necessary to mitigate the risk of road traffic incidents the following information, which forms the Road Safety Plan, will be provided to contractors operating vehicles on Company work sites.
- Company’s 10 Golden Rules with specific reference to Golden Rule #9 – Operate Vehicles Safely.
- Orientation
- Journey Management Plan.
- Vehicle Inspection
- Road Safety Hazards & Risk Assessment.
- Driver Assessment and Training.
- Fuel Management and Hazards.
- Environmental Hazards.
All contractor vehicle operators should be qualified and trained to carry out their duties in a safe and effective manner.
The compliance to the RSP will be audited every 6 months to ensure the requirements are being followed by Company and its contractors. The verification process is required to ensure compliance to this RSP and most importantly to reduce the risk of motor vehicle accidents.
Responsible: Company HSE Team Lead.
This Road Safety Plan is to be reviewed and revised on an annual basis.
Responsible: Company HSE Manager.