1. Safety management
1.1 Safety meetings
Rig site meetings held on a weekly basis with short 'toolbox' meetings subject to operational requirement. 5-10 minute safety briefing before each shift or between each job phase (e.g. tripping and logging or casing running and cementing).
Office meetings involving management and senior operational staff, held on a weekly or monthly basis.
Deficiencies
- Minutes of meeting are not made and distributed.
- Action items are not reviewed to final close-out.
- No evidence of involvement by management in the site meetings and inclusion of site supervisors in the management meetings.
- Service companies and sub-contractors are left out or forgotten.
1.2. Permit to work
The most commonly used permit to work used is the hot work permit. In most cases the company drilling supervisor is the ultimate signatory for the permit to become effective. The system is intended to provide proper control of work under hazardous conditions and to ensure adequate supervision of such work after necessary precautions have been taken and to establish that the correct procedures are followed.
Deficiencies
- The permit to work system is used only for hot work. Operations which involve vessel entry, working at height, unusual operations/tasks, diving operations are not included in the system.
- Many personnel employed on site remain ignorant of the purpose, use and application of the permit to work system
- Only the principal signatories of work permits are aware of the need for the permit; the work force is ill-informed as to the permit system.
- Permits (hot work) are being written for time spans exceeding one shift.
- Permits in force are not kept in a visible place such that all work being performed under the permit system can be seen together in one location (e.g. toolpusher's office).
1.3. Induction
A system of induction for new arrivals of personnel should cover:
- Site rules.
- Emergency alarms and response required.
- Who is in charge, who to report to?
- Safety requirements, e.g. hard hats, ear defenders, boots, goggles, etc.
- Information concerning specific hazards, e.g. H2S, chemicals, heat hazards.
Deficiencies
- System for recording arrival and departure of personnel on site (POB) is often unreliable.
- No information for new arrivals who to report to or who is in charge.
- Alarm signals and muster station locations are often left to the imagination of the new-comer.
- Site-specific hazards are not highlighted during induction briefings.
1.4. Communications
Good communication between rig supervisors and crew is essential. In areas where English is not commonly used, front-line supervisors should know sufficient of the local language to be of practical value. Where this is not possible a bilingual foreman should be appointed to each crew.
Deficiencies
- Crews have to be employed with no language in common with their supervisors.
- Crews are unaware of the basic site rules, the meaning of many notices and do not understand information supplied to them in writing. Often because of the language problem there is no information supplied at all (particularly sub-contractors).
- Warning signs with written messages used with illiterate crews.
1.5. Drills
Drills are used to train and optimise response to emergency situations. To be effective, there must be a concise report logged down on the type of drill, the response achieved and any shortcomings. Copies of such reports are sent to the drilling office where the quality of response as well as the significance of any shortcomings should be discussed at scheduled safety meetings. Unsatisfactory drills should be repeated at the earliest opportunity and rehearsed until successful. Drills should be planned to include different scenarios at different times of the day. It is good practice to 'take out' a key supervisor to test fall-back plans. Above all, drills should be as realistic as possible.
Deficiencies
- Most drills held are reported, but there is rarely any comment on the quality of response or shortcomings
- Performance and shortcomings of drills are not reviewed by management safety meetings
- Drills held are found to be of poor realism and do not follow stated procedures.
- The head count on location does not tally with the reported personnel on site.
- The duties of the person responsible for the head count conflict with other duties during an emergency. E.g. often the medic is responsible for the head count, with no deputy in case of an injury.
- Drills are held at the same time each week to the same scenario.
1.6. Accident reporting
All companies have an accident reporting system. The need for a parallel system of near-miss reporting and unsafe act auditing is becoming increasingly evident. The key product of accident investigation procedures is to take appropriate action to prevent recurrence.
Deficiencies
- Identification of accident causes is often lacking in reports.
- Results/minutes of accident investigation meetings are not passed down the line to front-line supervisors.
- Many near-miss events are not recorded at all - a key element in accident prevention.
- Contractor/subcontractor accident reporting, investigation, and follow-up procedures are often of poor standard, if they exist at all.
- After many cases of accident reports, much time (and money) is invested in the invested in the investigation but nothing changes as a result.
1.7. Contracts
The majority of work carried out in a drilling operation is by contract. Some of the work or services are done under sub-contract. It is therefore most probable that in addition to the main drilling contractor are several service contractors and a number of sub-contractors (e.g. catering staff, transports, drilling crew, general labourers, male nurse, radio operator, etc.). The content and quality of contracts entered into by the Company remains the responsibility of Company management, however, the sub-contracts entered into by contractors vary in quality and content considerably.
Deficiencies
- Contract supervisors and contractor representatives do not have copies of the relevant parts of their respective contracts.
- Sub-contractors do not have copies of their contracts, neither do the contractor site supervisors or the Company drilling supervisor. In most cases a copy of the sub-contract is not available in the Company office.
- Work schedules, relief schemes and required levels of skills and language ability are frequently omitted in the text of the sub-contract.
- Relevant safety clauses and compliance with Company/contractor safety standards is often not mentioned. This is particularly evident in relation to personal protective equipment such as helmets, overalls, and safety boots. Similarly, the requirements for able swimmers offshore is frequently not mentioned.
- Contractors do not include or enforce safety clauses in their subcontracts.
1.8. Contingency plans
Comprehensive contingency plans are often prepared well ahead of drilling operations. Routine matters such as weekend duty rosters, emergency contact numbers, local emergency contact numbers are normally all contained in the contingency manual. In some cases, plans are tested with a dry run to check procedures, communications and to iron out any bugs in the procedures. A dry run exercise often takes considerable time to review as there are many personnel involved (medivac).
Deficiencies
- Contingency plans are in the hands of the key line supervisory staff but are not available to other staff (e.g. radio operator, medic, chief pilot, duty pilot, stand-by boat captain, etc.).
- Contingency plans prepared in advance describe contradictory duties, e.g. camp boss to man both the radio-room and conduct a head count at the upwind muster area.
- Company and contractor have conflicting plans.
2. Operations
2.1. Lifting equipment
All equipment used for lifting must have the safe working load clearly marked on it. This essential detail is valid even for consumable items such as slings and shackles. Additionally, lifting equipment should be carefully inspected monthly and thoroughly NDT tested every 12 months.
It is also necessary to keep a register of all slings and shackles with latest inspection dates on the rig. So that individual slings can be easily identified, each sling should be tagged/marked with its unique identity code. (Similar to a movable number).
Deficiencies
- No register of slings and shackles kept on the rig.
- Newly purchased slings and shackles are uncertified and are not proof tested.
- The SWL is not marked on lifting equipment, e.g. BOP lifting trolleys, air winches.
- Pre-slung cargoes are manifested without including the slings - e.g. 'l lot' slings is not adequate.
- Damaged and potentially dangerous slings are mixed up with good slings.
2.2. Weight control
Consignments of materials to and from the rig are commonly loaded onto and from transport vehicles by crane. It is essential that crane drivers, supervisors and rig stability staff know the weight of each lift. Unusually heavy lifts should be done under the permit to work system using certified lifting slings.
Deficiencies
- Materials are loaded and consigned with the wrong weight on consignment notes. In some cases the weight is not mentioned at all.
- Most material yards have scales for verifying loads. However, this equipment is often not used and load weighs are overestimated instead.
- Crane drivers offshore are obliged to pick up loads 'blind' if there is no weight given on the consignment note.
- Rig stability calculations are incorrect due to overestimated weighs quoted on consignment notes.
2.3. Fork-lift trucks
Most palletised materials are handled with fork-lift trucks. The truck used should be suitable for working in hazardous Zone 2 areas or the permit system is required for work in a classified area. There are many instances of accidents associated with fork-lift trucks and they are usually caused by one or more of the deficiencies listed below.
Drivers of fork-lift trucks should always be experienced and verified competent. To avoid unauthorised drivers 'having a go', there must be a visible list of authorised drivers on the notice board with published rules stating clearly that persons not on the authorised list may not use the vehicle for any purpose.
A reversing alarm should be fitted to the vehicle though care should be taken to select equipment suitable for hazardous Zone 2 area classification.
Deficiencies
- ·The fork-lift truck is unsuitable for hazardous area Zone 2 use (e.g. electric starter motor with battery).
- ·Reversing alarm not fitted.
- ·Unauthorised persons driving the vehicle (e.g. the contract mud technician).
- ·List of authorised drivers not published and visible.
- ·The fork-lift is used for lifting personnel.
2.4. Chemicals
At any time on a rig there are a large variety of chemicals which are used for:
- ·drilling muds;
- ·completion fluids;
- ·formation stimulation;
- ·cement slurry additives;
- ·maintenance solvents and cleaning fluids;
- ·water treatment agents.
As many chemicals are harmful if used incorrectly, it is clearly a requirement that data sheets are available for all chemicals on site. Such data sheets should also be available at the material/transport yard, to any contractor handling the chemicals, and to any driver or supply vessel captain transporting chemical to and from the rig.
Chemical data sheets should include all relevant properties of each substance, the known hazards, e.g. harmful vapours, inflammability First aid and subsequent medical attention recommended in the event of contact with the chemical should also be stated on the data sheet. Personnel handling and transporting hazardous chemicals should be fully informed and should be aware of first aid treatment necessary in case of an accident.
The use of protective equipment when handling and mixing chemicals should be mandatory with provision of deluge shower and eye wash facilities easily accessible. High corrosive, toxic and flammable chemicals must be kept separate and identified with suitable warning signs. Oxidising agents (e.g. potassium dichromate) must be kept away from any form of combustible material (e.g. grease). In areas where local labour may be of particularly low educational standards and with no industrial background, it is often better to prohibit local labour from handling particularly dangerous chemicals (e.g. caustic soda). It is almost impossible to explain to an uneducated person what a caustic or corrosive chemical is.
Deficiencies
- Data sheets on all chemicals stored or in use are not available.
- The rig medic does not have a copy of chemical data sheets.
- Eye wash and douche facilities are not available in the mud mixing area.
- Mud mixing crews are not warned of the hazards of particularly dangerous chemicals, e.g. caustic soda, soda ash.
- The use of protective equipment is not enforced.
- Little is done about significant residues of chemicals left in 'empty' sacks and drums.
- Information concerning chemical hazards is almost always lacking during transport.
2.5. Hazardous area classification
The control of sources of ignition in areas around sources of hydrocarbon emission is vital for the purpose of protection against fire or explosion. Close control of hot work within hazardous area is also mandatory. There are a number of hazardous area classification systems, the one most applicable being the I.P Model Code of Safe Practice (Drilling and Production) and the minimum standard which should be adhered to.
Deficiencies
- Hazardous area drawings are generally not available.
- The local rules and standards applicable to hazardous area classification are not known to supervisory personnel on site.
- Trucks unsuitable for operating in a hazardous zone enter the location without the permission of the Company drilling supervisor. The permit system is not used.
2.6. Mud-gas separators
The minimum recommended dimensions for a mud-gas separator is given in Pressure control manual for drilling and workover operations. The most significant hazard with this equipment is the possibility of gas venting via the mud line to the rig mud tank and shale shaker area - there being usually no provision in the design of the mud gas separator to prevent this.
It is essential therefore that details of the design of the separator are scrutinised to verify that there is a mechanism to prevent gas escape via the mud line. In the past, serious injury has resulted from hydrocarbon ases entering the shale shaker area - a problem even more lethal if H 2S is involved.
Deficiencies
- Inadequately designed mud-gas separator.
- Drawings and specifications for the separator are not available.
- Overall separator dimensions are below the sizes recommended in Pressure control manual for drilling and workover operations.
2.7. Gas cylinders
Gas cylinders are used and stored on all drilling locations. In the industrialised world the rules for handling and using gas cylinders are well known. In some remote areas, codes of practice and standards applied to the use of gas cylinders may be inadequate and it is under such conditions that special attention must be paid to the standards of local welders and local suppliers of compressed gases and gas cylinders.
Deficiencies
- Oxygen cylinders are stored together with acethylene cylinders.
- Cylinders are not kept upright in a shaded area.
- Caps of bottles are missing
- Full and empty bottles are mixed.
- Bottles are wrongly colour coded.
2.8. ESD systems
Emergency shut-down systems are generally used to isolate all power from hazardous areas including the drill floor, mud pits and slush pumps. The system is normally function-tested once per well or per rig-up.
Toolpushers, drillers and assistant drillers must all know the location and function of the ESD actuator situated in the immediate vicinity of the drawworks.
Deficiencies
- Most supervisory staff on the rig, including drillers do not know exactly what happens when the ESD function is actuated.
- There are rarely any documents anywhere describing ESD procedures.
- ESD systems should include isolation of AC power to the rig floor and derrick area.
2.9. Alarm systems
The same can be observed with alarm systems as with ESD systems. Although the major fire and muster alarms are generally known through drills, the many other alarms such as gas, H2S, Halon release, etc.) are not always known or understood. It is essential that new-comes and visitors are initially trained t recognise alarms and know the required response. It is especially important that all staff on a drilling installation are fully aware of the functioning of all types of alarm.
Deficiencies
- ·Key staff do not know all the different alarms or what they mean.
- ·Crews, contractors and sub-contractors do not know sound of all alarms or the response required.
- ·Alarm systems often conflict, e.g. PA system used for alarm signal but must be used to give directions at the same time.
- ·Visitors and new saff are not briefed on the alar signals used on site.
2.10. Radioactive sources
For wireline logging operations radioactive source have to be used. Radioactive materials are therefore often stored on or close to the drilling location. Levels of radioactivity around the storage area should be carefully monitored and verified to be within acceptable levels, and warning signs used to control access.
It is also necessary that a register available of radioactive substances is kept on the rig and updated when there are any changes to the radioactive source inventory. Updated copies of the registe should be forwarded to the senior operations engineer.
Deficiencies
- ·There is no register available giving a description of radioactive sources on the location.
- ·The level of radioactivity around the storage box is not known, either above or below SSC acceptable limits.
- ·No signs warning of radioactivity.
- ·No boundary fence to indicate a no-go area.
2.11. Radio silence
The procedure for radio silence whilst connecting and handling armed explosive devices is fully described and documented in EP 55000. The need for radio silence is well-known and all radios must be accounted for including portable radios.
In addition DC power should be isolated along with any welding sets or transformers. Such equipment must be electrically disabled and a clearly visible notice attached to prohibit use. It is important to eliminate all potential sources of stray current around the rig floor area, this includes electrically driven cathodic protection systems.
Other sources of radio transmission must be warned in adequate time before operations with electrically detonated explosives commence, e.g. helicopters, police, militia, etc.
Deficiencies
- ·There is no register of portable radio transmitters on the location.
- ·Notices to indicate isolated equipment not in use.
- ·DC power isolation sometimes omitted.
2.12. Electrical earthing
Proper earthing of electrical equipment and drilling equipment throughout the mud system is important. Without an effective earth, dangerous potentials could build up and result in electrical discharge in areas classified as hazardous. Such a potential source of ignition can be eliminated by interconnecting all tanks and mud mixing systems and ensuring that resistance to earth is low (< 1 ohm). Sensitive equipment such as computer, instrument logic boards and digital recorders can also be adversely affected by poor earthing. Concern on these problems is usually restricted to dry desert environments.
Deficiencies
- ·Mud tanks and mixing skids are not interconnected or earthed.
- ·The quality of earth is not checked with a Mega insulation tester.
3. Questionnaire
The following questions are produced under headings to fit with parts of the standard audit check list. Common audit findings listed in sections A and B of this paper are addressed by the questions in this section.
3.1. Communication and motivation
·Are rig site and office based safety meetings minuted?
·Distributed to all involved/concerned parties?
·Are identified action items reviewed and formally closed out?
·Do field supervisors attend the office-based meeting?
·Do management attend the rig site meeting?
·Are all contractor representatives invited to attend?
·Do supervisors and crew have a common language?
·Are translators with work experience available in the crews?
·Are any of the supervisors proficient in the local language?
·Are signs and information available in the local language?
·Is there a requirement for bilingual foremen in the contracts?
·How is the quality of communication on the rig site verified?
3.2. Work permit
·Does the work permit system cover all aspects of hazardous work?
·Are the requirements known to all the work force & supervisors?
·Are permits in force on display in a central location?
·Is the location reserved for this purpose?
·Is there any system of review of the use of the permit system?
·Who in the organisation sees copies of permits issued?
3.3. Safety training and induction
·Are there notices instructing all arrivals to report in/out?
·Is there a system of induction - is this recorded?
·Who is identified as the focal point for induction?
·How is the emergency signal demonstrated?
·How is the use of emergency safety equipment demonstrated?
·Are there printed cards giving muster locations and site rules?
·Are these handed out to every new arrival?
·Are they printed in the local language as well as in English?
·Are there clear hazard signs in appropriate place on location?
·Are escape routes clearly visible?
3.4. Contingency plans
·Are reports of drills prepared and distributed after each drill?
·Is the drill performance reviewed?
·Is there a system of shortcoming correction?
·Do the drills follow published procedures - how is this checked?
·Is the quality of drills discussed by management?
·What are the instructions in the event of an unsatisfactory drill?
·Are the contingency plans available to all key staff?
·Including those involved in the plan?
·Has there been feedback from all personnel involved?
·Have the plans been changed and the changes distributed?
·Do the contractors have their own contingency plans?
·Any conflict?
·Are there dry runs of contingency plans?
·Is so, how is the exercise reviewed?
·Who is focal point for amendments, to contingency plans?
·Does the head count check with meal sheets?
·How are short-term visitors include in POB at all times?
·Is the POB list available to the person responsible for the head count?
·What other duties/responsibilities does he have?
3.5. Accident investigation
·Are accident reporting and investigation procedures fully described?
·Are they distributed to all supervisory staff?
·Does contract oblige participation in accident investigation?
·How are contractors informed of other's near miss accidents?
·Are procedures, rules or specifications changed as a result of accident investigations?
3.6. Contractor safety
·Are copies of all contracts with site supervisors?
·With contractor representatives?
·Is the content of sub-contract terms vetted by the Company?
·How is agreement to the sub-contract by the Company specified?
·Are the work schedules of the sub-contractor compatible with safe practice?
·Is there a relief schedule?
·How is the skill and experience level of sub-contract staff checked?
·Are medical requirements met by sub-contract staff?
·Can the sub-contractor communicate with the contractor supervisor?
·How is a language problem identified?
·Are personnel required to work over or near water?
·Is there a system for verifying swimming capability?
3.7. Maintenance procedures
·Is a register kept on the rig of all slings and shackles in use?
·Is lifting equipment marked with the SWL?
·Are slings marked with an ID number?
·Is there a system for regular inspection of lifting equipment?
·Is there certification of inspection of lifting equipment?
·Is responsibility for sling selection clearly understood?
·Are the rules pertaining to lifting procedures known to all crews at all levels?
3.8. Weight control
·Is there a system used for checking loads?
·Is there an instruction how often loads are to be checked?
·Are rig stability calculations required?
·Is there a deck-load limitation?
·Is there a system for checking the actual loads on the rig?
3.9. Fork-lift trucks
·Is there a system for authorisation of fork-lift drivers?
·Is a list of authorised drivers available?
·Does the fork-lift work in Zone 2 area?
·Is there a work permit system to cover this?
·Is the vehicle suitable for Zone 2 work?
·Is a reversing alarm fitted and working?
·Do the rules forbid lifting of personnel with the fork-lift?
·Are these known to the supervisors and crews?
3.10. Industrial hygiene
·Are chemical data sheets for all chemicals available?
·Are they distributed to transport and rig supervisors?
·Are hazardous chemicals identified and isolated?
·Are personnel working with these chemicals aware of the hazards
·Do they know what to do in the event of a spillage or accident?
·Are shower and eye wash available in mud mixing/handling areas?
·How are 'empty' drums and sacks dealt with?
·What happens to excess chemicals on site?
·Are 'removal' or waste disposal personnel aware of the dangers?
3.11. Hazardous area classification
·Is the hazardous area classification according to the IP code?
·Is the IP code applied on the drilling location?
·Is a hazardous area diagram available on the rig?
·Is it clearly visible where current work permits are on display?
·Do key personnel on the rig know the hazardous area boundaries?
·Are cars allowed to be parked on the location?
3.12. Flares and vents
·Is the rig fitted with a mud-gas separator?
·Does it conform to Company's Policy?
·Are drawings available?
·Is there a mechanism to prevent gas venting through the mud-line?
·What are the operating instructions to the drillers?
·Can a gaseous influx be circulated out safely through the separator?
3.13. Gas cylinders
·Are local gas supplies to a recognised standard or code of practice?
·Are gas cylinders stored upright in a shaded area?
·Is oxygen separated from fuels?
·Are cylinders properly colour coded and fitted with caps?
·Are there records kept of the location of each bottle used?
3.14. ESD systems
·Do all supervisory staff know how to actuate the ESD function?
·Do they know what equipment is actually shut down?
·Are there written description of the ESD system available?
3.15. Radioactive sources
·Are there regulations governing use of radioactive materials?
·If so, who is identified as legally responsible?
·What is the limit of radiation around the source storage container?
·Is radiation verified below the maximum permissible level?
·How is this verified?
·Is there a register of radioactive sources kept on the rig?
·Who is responsible for updating the register?
·Is copy held by the senior operations engineer?
3.16. Telecommunications
·How is the use of portable radio-transmitters controlled?
·Is a register of all portable radios available on the rig site?
·Are isolation notices available?
·Is there a procedure for informing others of radio silence?
3.17. Electrical earthing
·How is rig equipment earthing tested?
·Are all individual tanks and skids properly earthed?
·Is equipment of service companies included?
3.18. Service contractors
·Do all service contractors receive a site safety induction?
·Are Company transport standards complied with?
·Do service staff have copies of relevant Company standards?
·Are they all included in safety meetings?
·Do all personnel know their emergency response duties?
·Is participation in emergency drills routine?