JULY 2010
UIE Wells
Basics for Compliance
with
Site Safety Standards
Document Owner:
Derek Redman
Wells Operational Excellence Team Leader.
Foreword
Well activities carry risk. UIE Wells Leadership is committed to provide people, systems and procedures to ensure that all activities can be completed without hurting people or damaging the environment.
We use the UIE Wells HSE management system to accomplish this. The management system, and others like it belonging to our major service providers, defines controls and stipulates how to make them effective. When we are operating on a contracted installation, there is a preference to use the HSE management system of the Duty Holder (e.g. Drilling Contractor) and – when necessary – use bridging documents to meet Shell standards.
The HSE management system refers to standards and mandatory procedures to manage the risk to people, asset and reputation down to acceptable levels (ALARP). These can be seen as the ‘Rules of the Game’.
Site supervisors are accountable for an incident free workplace. The purpose of this document is to help them understand how to exercise their accountability. It sets out clearly our expectations for preventative workplace activities e.g. for compliance and pro-active interventions with site personnel.
This document does not contain ‘more rules’ and does not increase the roles or responsibilities of site supervisors. It is nothing more than a summary of the absolute minimum requirements as already set out in existing standards and mandatory procedures for well activities.
Continuous feedback by UIE Wells Site Supervisors to the document owner about its contents should maintain a quality document, which makes it easier for Site Supervisors to make every day a Goal Zero day.
Sjoerd Brouwer
Wells Manager
Upstream International Europe
Basics for Compliance with Site Safety Standards
JULY 2010
Table of Contents
1.0 Objectives 3
2.0 Expectations 4
2.1 Contractor 4
2.2 Shell Drilling or Completion & Well Interventions Supervisor 4
2.3 Shell Senior Well Engineers and Senior Completions and Well Intervention Engineers 7
3.0 Mandatory Requirements 3
3.1 Life Saving Rules 8
3.2 Management of Change (MOC) 11
3.3 Job Safety Analysis (JSA) 14
3.4 Permit to Work (PTW) 16
3.5 Contractor Management 18
3.6 Short Service Employee (SSE) 19
3.7 Emergency Response 21
3.8 Environmental Management and Hazardous Materials 23
3.9 Incident Management 25
3.10 Lifting and Hoisting 27
3.11 Temporary Pipework 29
3.12 Dropped Object Prevention Scheme (DROPS) 31
3.13 Well Control 33
3.14 Fitness to Work 35
4.0 Training 37
5.0 Document Control 37
1.0 Objectives
This document clarifies what is expected from UIE Drilling Supervisors and Completion & Well Interventions Supervisors to comply with existing standards and procedures. The requirements reflected in this document are deemed to be the most critical and the absolute minimum for delivery of safe and efficient well operations. Some of these activities will not be appropriate to all UIE WELLS worksites and it is expected that each Supervisor and Line Manager (Senior Engineer) will formally agree the activities that will apply to their operations.
Goal Zero (no incidents) is one of our values. Our vision of 'no harm to people' can be achieved if everyone takes individual responsibility for their actions. The purpose of this document is to assist in making those responsibilities clear. This document, in conjunction with the Golden Rules (Comply, Intervene and Respect) and the Lifesaving Rules, is a key enabler in achieving a workplace without harm.
Major incident root cause analysis shows that non-compliance and lack of leadership consistency in communicating and enforcing standards is one main reasons why people get injured or even killed in the execution of well activities This document aims to help in clarifying the controls and to achieve consistent communication of expectations such that they are understood and valued by the workforce. This clarity will greatly enhance Shell’s / Contractor’s efforts to sustain an incident free workplace.
2.0 Expectations
This document summarises minimum requirements that are non-negotiable and must be implemented. It is expected that each Supervisor and Line Manager (Senior Engineer) will agree site-specific requirements based on Section 3. It is also expected that efficient compliance methods will be agreed that will NOT generate additional record keeping by the Supervisor.
The document does not contain “more rules” and does not increase the roles or responsibilities of Site Supervisors. It is nothing more than a summary of the absolute minimal requirements as already set out in existing standards and procedures for well activities.
2.1 Contractor
Major contractors have their own HSE Management Systems (MS). Shell will verify that Contractor’s HSE management system meets Shell standards through assessment prior to procurement and auditing during contract start up / execution. Where a contractor is not following their own HSE MS or when gaps have not been closed as agreed, the Shell Drilling or Completion & Well Interventions Supervisor must intervene. In case people are at risk of being hurt, work needs to stop until relevant controls have been put in place. If compliance cannot be assured at the wellsite the issue shall be escalated to the relevant Senior Engineer.
2.2 Shell Drilling or Completion & Well Interventions Supervisor
The Shell Drilling or Completion & Well Interventions Supervisor will be held accountable for an incident free workplace.
On offshore locations, he / she will exercise his / her accountability through the OIM who has (sometimes statutory) responsibility for safety of all personnel on board. However, for onshore locations, the Drilling or Completion & Well Interventions Supervisor carries this responsibility directly.
The primary responsibilities of the Shell Drilling or Completion & Well Interventions Supervisor are:
2.2.1 Safety Leadership Expectations
Safety leadership expectations are set out in the Advanced Safety Leadership process, and are summarised in the following statement:
‘Safety Leaders are expected to create an environment in which safe behaviours are promoted and unsafe acts challenged – a workplace without harm.’
Set the Standard:
· Show Exemplary behaviour.
· Set clear HSE expectations.
· Possess a good knowledge of safety.
· Consistently raise safety standards.
· Recognise and act on poor safety conditions.
· Regularly observe, assess and intervene in the workplace.
Communicate Effectively:
· Understand your people and demonstrate a real concern for their well being.
· Commend good safety performance.
· Give and receive constructive feedback.
· Be able to hold a difficult conversation.
· Go beyond your own team.
· Demonstrate an enthusiasm for safety.
· Assuring the Key Safe Systems of Work.
Assure yourself, via discussions with senior Contractor personnel and spot checks, that the following specific safe systems of work are working effectively:
· Job Safety Analysis (JSA) or Task Risk Assessment (TRA).
· Permit to Work (PTW).
· Management of Change (MOC).
In the event that significant issues arise during the assurance process, discuss with the Senior Well Engineer or Senior Completion and Well Intervention Engineer, and decided whether a system audit is required to identify and correct shortcomings.
2.2.2 Execute Work According to Standards
Mandatory requirements are specified for the following critical aspects of HSE management. These must be complied with at all times:
· Life Saving Rules.
· Incident Management.
· Contractor Management.
· DROPS.
· Emergency Preparedness.
· Fitness to Work.
· Lifting and Hoisting.
· Short Service Employees.
· Temporary Pipework (and Temporary Equipment offshore).
· Well Control.
2.3 Shell Senior Well Engineers and Senior Completions and Well Intervention Engineers
The Shell Senior Well Engineer and Senior Completion and Well Intervention Engineer (Both referred to as Senior Engineer from this point forward) shall be fully accountable for the following:
· Briefing of the Drilling and Completion & Well Interventions Supervisors with respect to the requirements of this document.
· Validating compliance with this document.
· Taking action to correct any identified gaps.
3.0 Mandatory Requirements
3.1 Life Saving Rules
The Life Saving Rules set out clear and simple “do’s and don’ts” covering activities with the highest potential safety risk. The Life Saving Rules do not replace or invalidate the Golden Rules (Comply, Intervene & Respect) or any other business, operational, and safety rules in force.
The 12 Life Saving Rules are:
1 / / Work with a valid work permit when required.2 / / Conduct gas tests when required.
3 / / Verify isolation before work begins and use the specified life-protecting equipment.
4 / / Obtain authorisation before entering a confined space.
5 / / Obtain authorisation before overriding or disabling safety critical equipment.
6 / / Protect yourself against a fall when working at height.
7 / / Do not walk under a suspended load.
8 / / Do not smoke outside designated smoking areas.
9 / / No alcohol or drugs while working or driving.
10 / / While driving, do not use your phone and do not exceed speed limits.
11 / / Wear your seatbelt when driving or riding in a car.
12 / / Follow the prescribed Journey Management Plan.
3.1.1 Mandatory Requirements for Drilling and Completion & Well Interventions Supervisors
1. Review the 12 Life Saving Rules with your Senior Engineer. Ensure that you know the purpose and application of each Life Saving Rule, and the consequences for non-compliance.
2. Assure yourself that a working process is in place so that Shell employees and contractors on your wellsite have been briefed on the Life Saving Rules and the consequences for non-compliance by:
· Conducting spot checks with Contractor personnel to confirm that Life Saving Rules orientations have been conducted.
· Routinely discussing the importance of the Life Saving Rules.
3. Ensure that the Life Saving Rules are an integral component of operational procedures and practices at your location.
4. Report all non-compliance and violations of the Life Saving Rules to the Senior Engineer immediately, for further investigation.
5. Encourage and support wellsite peer-to-peer intervention and observation processes (e.g. SHAPE, 24/7, START, etc).
3.1.2 Links to Standards / Guidelines / Tools
UIE Life Saving Rules
3.2 Management of Change (MOC)
The direct and underlying cause of many incidents is the failure to properly recognise and/or manage change. The purpose of this section is to provide guidance on how to manage change at the wellsite.
Management of Change (MOC) falls into three broad categories, these being:
· Programme change
· Work instruction change
· Equipment change
For each category, change will be managed as follows:
1. Programme Change: Any change to a Shell generated programme must be subjected to the Shell management of change process, as specified in TS-01.
2. Work Instruction Change: Any change to agreed worksite plans, or operating instructions for their equipment, must be subjected to the local worksite management of change process.
3. Equipment Change: All changes that are not “replacement in kind” must be subjected to the relevant Contractor management of change process, regardless of whether the change is temporary or permanent.
Changes to Shell generated Drilling, Completion and Well Intervention Programmes will be managed as specified in Shell UIE Technical Standard TS-01: How to Use EPE Well Technical Standards – Deviation Procedure.
Contractors shall use their own MOC process for their equipment and work instruction changes. If requested, Shell will be included in the review process for contractors’ MOCs.
3.2.1 Mandatory Requirements for Drilling and Completion & Well Interventions Supervisors
1. All procedural changes to a Shell generated programme will be issued to the Drilling and Completion & Well Interventions Supervisors by their Senior Engineer. In the event that operations require a significant deviation to the operational steps contained in the Drilling, Completion or Well Intervention programme, the Drilling or Completion & Well Interventions Supervisor will inform their Senior Engineer that a programme amendment is required.
2. Assure yourself, via discussions with the OIM or Toolpusher, that the Contractors understand and implement their MOC processes, and are aware of when their MOC process must be applied.
3. If identified as a reviewer by a Contractor’s MOC process, provide comment and input when requested.
4. Assure yourself, via spot checks, that the Contractor executes and closes out change in accordance with the requirements of their MOC process.
· Should there be concern regarding the implementation of a Contractor’s MOC process, make a request to your Senior Engineer for an audit to be conducted, in order to identify any areas for improvement.
5. Ensure that execution and close-out of Shell assigned MOC tasks are always completed.
6. Do not allow changes to be implemented without adherence to the relevant MOC process.
3.2.2 Links to Standards / Guidelines / Tools
Shell Technical Standard TS-01: How to Use EPE Wells Technical Standards – Deviation Procedure
UIE Facility Status Reporting Weblink
3.3 Job Safety Analysis (JSA)
A Job Safety Analysis (JSA) or a Task risk Assessment (TRA) is a systematic analysis of a job, which identifies the hazards and mitigating controls for each step of a job, and ensures that the responsible parties understand their roles.
3.3.1 Mandatory Requirements for Drilling and Completion & Well Interventions Supervisors
1. Be knowledgeable of the JSA or equivalent process being used at the wellsite. This may be either the Drilling Contractor or Shell JSA process, depending on whether the location is an offshore contracted drilling rig or Shell owned site (offshore platform or land site).
2. Assure yourself, via spot checks and discussion with selected individuals, that all personnel are knowledgeable of the JSA or equivalent process being used at the wellsite.
3. Assure yourself, via spot checks or audit, that suitable JSA preparation is being conducted. The spot check or audit should confirm that:
· All personnel involved in the job are part of the JSA review prior to beginning the JSA process.
· The proper sequence of tasks is described.
· The identified hazards are appropriate for the task. A Risk Assessment Card (i.e. Task Risk Identification Card (TRIC)) is used to assist with hazard identification.