Rigless Risk Management Plan
Table of contents
- HARC Implementation
- Permit to Work System
- HARC and Permit to Work System
- Risk Management of Critical Rigless Hazards
- Rig Move Top Hazards
- Working under poor weather conditions
- Working at Heights
- Manual Handling
- Well Site Operations Top Hazards
- Confined Space entry
- Working at Heights
- Mechanical Lifting Operations
- Hydrogen Sulphide
- Hazardous Materials
- HSE Meetings and communications
- Tools Box Meeting
- HSE Meeting
- Safety Notice Boards
- Risks Reporting HSE Cards
- Rigless Operation Risk Register
This procedure outlines the responsibilities and activities required to ensure the risk management process is carried out consistently and effectively on a rigless site and that appropriate records are maintained.
Implementation of this procedure will ensure that risks are assessed, identified, controlled, monitored, documented and reviews are carried out when required.
Covers all hazards, risks, control measures, documentation, maintenance measures and responsibilities associated with an activity or process conducted on a rigless sites.
The identification of hazards and the assessment of risks is a key part of rigless operations processes. Risk assessment is carried out on an ongoing basis and to be effective it is essential that all our employees co-operate wherever they can in the risk assessment process to ensure that the assessment accurately reflects the process, which is undertaken.
- Managers and supervisors are responsible for ensuring the hazards analysis is conducted, regularly reviewed and remedial issues identified and actioned.
- If at any time an employee considers that there is a serious hazard in their area or there are deficiencies in existing HSE measures, or an Opportunity For Improvement has been identified, the employee must inform their line supervisor as soon as possible.
- QHSE function shall work in line with rigless operations team to identify hazards and assesse potential risks and address adequate control measures for elimination of identified hazards.
- HARC IMPLEMENTATION
Each segment shall set up a program for hazard analysis to be conducted with their team by identifying the various tasks performed by their segment on a rigless site and producing a HARC register. The method for conducting Hazard analysis and Risk Control is defined in the company Standard SLB-QHSE-S020.
All generic HARC shall be reviewed and approved by the line management for consistency . For activities which involve a significant risk, reviews are carried out more frequently. Some extremely high risk operations will require a risk assessment to be carried out each time the activity is undertaken.
The basic approach to the management of risk is summarized by the following stages:
- Consider all tasks and situations conducted
- Consider all hazards identified in the workplace Identify job steps involved in completing the task
- Identify those who may be exposed to the hazards
- Identify the hazards which are, or may be, involved
- Identify the control measures already in place
- Analyze the risks of injury or loss from the hazards
- Evaluate if the risk is adequately controlled
- Consider methods which may eliminate or further reduce the risk in line with the basic principles of hazard control
- Implement the risk control measures Monitor the measures
- Review and feedback of any Corrective Actions or Opportunities For Improvement
The Project PTW procedure will be applied to plan and execute all non-routine / high risk activities. The procedure describes roles and responsibilities, work flow, list of activities subjected to PTW and applicable training requirements.
The rigless site coordinator is the ultimate authority at the Well Site for the application of the PTW process.
All personnel working in the rigless site shall receive a training on the Permit to work System (PTW Level 1) as part of the HSE minimum training
Personnel with a specific role in the Permit to Work process (“signees”) will shall complete an advanced Permit to Work Training (PTW level 2) as per SLB-QHSE-S020-G001-PTW Guideline.
HARC AND PERMIT TO WORK
All activities requiring a PTW to be used; a detailed HARC shall be already prepared for the task and approved the by the line management and supported with the PTW completed for the task.
Activities requiring a PTW as defined in the company Standard SLB-QHSE-S020; shall not be conducted unless the following steps are completed:
- A PTW is completed on site as per the PTW procedure
- A valid and approved HARC is available on site
- A pre-job meeting is held with team conducting the task
- Appropriate supervisory level is continuously present during task execution.
Hard copies of the approved HARC file shall be always maintained on a rigless site by the segment supervisor.
I. RIG MOVE TOP HAZRDS:
a) Poor weather conditions
Weather condition can enormously affect the execution of the rig site move by increasing adverse condition and therefore combined risks to this activity. Project team shall assess weather conditions prior to any rig move to prevent unexpected risks during the operations. Weather condition can increase potential risks in driving; lifting; handling; stepping and all activities planned in rig move job. Adequate control measures shall be taken to leverage the likelihood of conducting the rig move under poor weather conditions.
The Driving Policy SLB-QHSE-L002 and Journey Management Standard SLB-QHSE-STD-S001 shall be implemented for on rigless site. This will include:
- Driver training and qualification
- Seat belts
- Journey Management
- Substance abuse
- Driver improvement monitors and performance monitoring
- Cellular phones
- Discipline enforcement
Any commuting between site and camps shall be assessed and correct measures are taken to avoid driving related risks
Any driving movement outside the geozone shall be done through the e—journey. Trips between camp and site shall be in compliance with local journey management procedure if driving geozone is not required.
- Working at heights
Working at heights during rig move operation presents high risk of personnel fall from elevation if not managed properly. WAH can result in drops risks on location if appropriate control measures are not assessed properly. WAH activity is associated mainly with slinging and lifting and mechanical lifting jobs. Refer to Working At Heights HARC.
- Manual handling
Employees are continuously exposed to risks of falling and body injuries during their work. Use of Schlumberger injury prevention tools does enormously help the employee in prevention of accidents related to stepping; manual lifting and handling. All employees should have completed the required SIPP training and assessment prior to work on a rig site.
II. RIGLESS SITE OPERATIONS TOP HAZRDS:
a) Confined Space Entry
Entering a confined space presents a high risk to personnel and should be avoided by all means and solutions. If a confined space entry job has to be conducted; recommended prevention and mitigation measures shall be provided to ensure safety of personnel. Only trained and qualified personnel shall be involved in confined space entry activities. Appropriate HARC shall address rescue plan from CS in case of emergency; and shall be reviewed and approved by the management.
b) Working at Heights
Working at heights during well operations shall be identified and assessed in HARC. Rigging up / and down rig equipment involve access of personnel to elevated platforms and areas. If a job has to be conducted on elevated areas; appropriate control measures shall be followed as per the site Fall Prevention Plan. Refer to Rigless Site Fall Prevention Plan.
Schlumberger Pressure Standard, SLB-QHSE-S014 will prevail for all Project Operations.
- All connections on high pressure circulation lines shall be snubbed with adequate means to prevent them from swinging or kicking in case of sudden release of pressure.
- Mud pumps must be equipped with relief valves and bleed off devices.
- All pressure vessels (pneumatic or hydraulic) and pipe work shall be factory made and certified, equipped with a pressure release mechanism and a pressure gauge They shall be regularly inspected and retested after any repair of modification. Pressure equipment needs to be uniquely identified and traceable to certification.
- Compressed air can only be used with pneumatic tools and equipment designed for its use.
- A Permit to Work shall be obtained prior any pressurized Operations such as, but not limited to, BOP testing, Frac or Acid job, etc.
The Rig shall maintain a pressure equipment register.as per Schlumberger Pressure Standard, SLB-QHSE-S014.
On a rigless site; elements of fire ignition can be easily combined if required precautions are not taken. Storage of chemicals; control of hydrocarbon; electrical equipment and all sources of energy and fire ignition shall be identified; assessed and controlled. The site location shall put in place a fire HARC and implement preventive measures in the design and set up of the site operation. Equipment for the detection of fire shall be also considered in the design of facilities and equipment. Mitigation measures shall be designed to face any fire incident on well location. The site personnel awareness about the potential risks of working around flammable products and gases shall be instilled through trainings and exercises program to mitigate the fire hazards.
Drops hazards can result in fatal accidents to personnel if proper preventions are not in place. It can result in damage to assets and environment as well. A drops plan shall be put in place to prevent unsafe condition from combining personnel or objects from falling from heights. Preventive measures shall include compliance of equipment design to drops requirement; awareness program and assessment and auditing actions on well site locations.
f) Mechanical Lifting Operations
All mechanical lifting operations will be conducted according to the requirements established in the Mechanical Lifting Standard SLB-QHSE-S013
As a minimum all Segments and other Contractors and Subcontractors involved in lifting operations shall comply with the following requirements:
- All lifting equipment and gear shall be certified and regularly inspected and maintained. A lifting register will be maintained at Rig site for tracking purpose.
- Homemade lifting gear is banned from Operations.
- Lifting plans will be established for all critical Lifting Operations as defined in the Project Permit to Work Procedure
- Crane and forklift operators will be trained and certified as per Saudi ARAMCO training requirements
- Tag-lines shall be systematically used to guide loads while maintaining helpers at a safe distance.
- Personnel lifts with winches shall only be performed using a certified and designated “man-riding” winch which shall be inherently safe
- All Critical Lifts needs to be supervised by segment supervisor and HSE Field.
Segment supervisors and HSE Field should be certified on “Onshore Mobile Crane Supervisor Level 2” training.
H2S is a high potential risk when working in known rigless operations H2S areas. When operating in suspected or known H2S areas the site shall be fully compliant with H2S Standard SLB-QHSE-STD15,
All employees and visitors are required to complete H2S Level 2 training prior to work/visit an H2S known/suspected rigless site.
- Hazardous Materials
The use and storage of hazardous materials is widely involved on rigless site. Handling chemicals shall be conducted as per the materials safety data sheets of chemicals. Personnel shall be fully aware and trained on use of chemicals provided on well site operation and appropriate mitigation measures in case of contact with hazardous materials. Storage of chemicals shall be compliance with the manufacturer recommendations to prevent potential impact on personnel and environment as well.
- HSE MEETINGS AND COMMUNICATIONS
Prior to starting any non-routine or major Operation, a toolbox (pre-job) meeting shall be held by the Supervisor in charge to acquaint each person involved in the Operation with the scope of work, the hazards and the specific Procedures to be followed.
The nominated supervisor shall ensure, after consulting any appropriate guidelines or task based risk assessments (HARC or TRA/JSA), and that an adequate Tool Box Meeting is held to address the job in detail. The quality and scope of the discussion at the meeting shall ensure that all personnel involved fully understand:
- All hazards associated with the task.
- The control measures to be put in place.
- Specific responsibilities as regards the task.
- Detailed work instructions.
Upon completion of work, learning points shall be discussed and Documented by the work party, in order to enable the update of any relevant Procedure, Guideline or risk assessment and provide feedback.
All staff on site shall take an active role in the daily, weekly and monthly HSE meetings at the well, and any other formal and informal meetings addressing Q&HSE matters.
Third party personnel shall be invited to the QHSE meetings. The content and attendance will be documented and records maintained at the well site.
The Rig shall have a dedicated safety bulletin board presenting as a minimum the applicable HSE Policies, Emergency Procedures, and latest Safety Alerts etc. Such board will contain relevant HSE material from either party (Saudi ARAMCO and/or Schlumberger).
8. RISK REPORTING AND HSE CARDS
For the reporting of hazardous situations, unsafe conditions and unsafe acts will implement a combination of 3 tools:
- Risk Identification Report : Incidents, near incidents and high potential hazardous situations
- Stop Cards : Unsafe conditions
- Observation/ Interventions : Safe/Unsafe acts
All above reports will be captured in QUEST and appropriate Action Items will be created and assigned whenever follow-up is required.
- Refer to Rigless Operation Risk Register document.