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Foreword
JULY 2010
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
Objectives...............................................................................................................................2 Expectations............................................................................................................................3 Mandatory Requirements........................................................................................................8 Training.................................................................................................................................41 Document Control.................................................................................................................41
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010
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 Shells / Contractors efforts to sustain an incident free workplace.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010
Expectations
This document summarises minimum requirements that are nonnegotiable 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. 1.1 Contractor
Major contractors have their own HSE Management Systems (MS). Shell will verify that Contractors 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.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 of all personnel on board. However, for onshore locations, the Drilling or Completion & Well Interventions Supervisor carries this responsibility directly.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 The primary responsibilities of the Shell Drilling or Completion & Well Interventions Supervisor are: 1.2.1 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.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 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.
1.2.2 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.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 Fitness to Work. Lifting and Hoisting. Short Service Employees. Temporary Pipework (and Temporary Equipment offshore). Well Control.
1.3 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.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010
1 2
Conduct gas tests when required. Verify isolation before work begins and use the specified life-protecting equipment. Obtain authorisation before entering a confined space. Obtain authorisation before overriding or disabling safety critical equipment. Protect yourself against a fall when working at height.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 Do not smoke outside designated smoking areas.
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While driving, do not use your phone and do not exceed speed limits. Wear your seatbelt when driving or riding in a car. Follow the prescribed Journey Management Plan.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010
1.4.1 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 observation processes (e.g. SHAPE, 24/7, START, etc). and
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010
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. 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. 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.
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3.
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.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 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.
1.5.1 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. 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. If identified as a reviewer by a Contractors MOC process, provide comment and input when requested. 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 Contractors 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. Do not allow changes to be implemented without adherence to the relevant MOC process.
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6.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 1.5.2 Links to Standards / Guidelines / Tools Shell Technical Standard TS-01: Standards Deviation Procedure UIE Facility Status Reporting Weblink How to Use EPE Wells Technical
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 Consideration is given to possible conflict with other activities occurring at the site.. Consideration is made in the JSA with regards to incorporation of pre-defined pauses in the job at critical steps. All participants involved in the evaluated task sign-off on the agreed to JSA. 4. Assure yourself, via discussions with the OIM or Toolpusher, that it is clearly understood by all worksite supervisory personnel that it is a requirement to stop work and revise the JSA when the job changes, new personnel join the task, or environmental changes occur (see Section 3.2: Management of Change). 5. Assure yourself, via spot checks, that there is a system in place that prevents work from beginning until it has been verified that the JSA process in use will be complied with. 6. Assure yourself of JSA compliance by observing the implementation of tasks on a regular basis, to ensure that controls are properly executed. Should there be concern regarding JSA implementation, make a request to your Senior Engineer for an audit to be conducted, in order to identify any areas requiring improvement. 7. Inform the Senior Engineer of contractors who do not apply their JSA process.
1.6.2 Links to Standards / Guidelines / Tools Shell Activity Risk Assessment Standard 3604-001 Step Change in Safety Task Risk Assessment Guide
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 All permits shall have a Job Safety Analysis. (In some PtW systems, the JSA is required to be attached. In all systems it is required to exist.) Concurrence and approval for the work to start must be obtained from the named Supervisor on the permit. Pre-job walk throughs are conducted prior to the commencing work. Actions required to ensure permits are properly closed out are conducted. 6. Verify, through site visits or spot checks, that permitted activities are conducted as specified on permits signed for approval by the Drilling or Completion & Well Interventions Supervisor. Occasional checks of other permits are recommended. 7. For locations where the Drilling Contractors permit system applies (i.e. semi-submersible or jack-up drilling rigs), verify that the Contractor has an audit plan for confirming permit compliance. When a permit system audit is planned, ensure that you or your representative joins the audit team. 8. Inform the Senior Engineer of Drilling Contractors who do not apply their PTW process.
1.7.2 Links to Standards / Guidelines / Tools UIE Integrated Safe System of Working (ISSOW) EP71.MA.0112-003 UIE Field Operations - Permit to Work Manual Step Change in Safety, HSE : Permit-to-Work Essential Rules HSE Guidance HSG250
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010
2.
3.
Assure yourself that Contractor personnel implement their MS effectively, and are aware of any variations as specified in the MS Bridging Document. Audits may be requested to assist with HSE MS verification.
4.
Verify that findings identified on Contractor audits are being actioned, or have been closed out. For Service Company interfaces, provide contractor performance and MS compliance feedback via the Service Report (field ticket). For all Contractors (i.e. Drilling Contractors and Service Companies), report significant MS compliance performance issues to the Senior Engineer.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 1.8.1 Links to Standards / Guidelines / Tools UIE Contractor HSSE Management Webpage
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 6. Assure yourself, via discussions with the OIM or Toolpusher, that there is a system in place to ensure that SSE are visibly distinguishable from experienced employees (e.g. via the green hard hat policy).
1.9.2 Links to Standards / Guidelines / Tools Link to Guidance on Competence Assurance in UK Offshore Locations EP HSE Competence Standard 2005 0120
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 5. Confirm that routine emergency response exercises and drills are conducted and documented on a regular basis. Assure yourself that: The exercises and drills are relevant and effective. There is a system in place to record and close out all issues identified during drills. 6. Assure yourself, via spot checks, that emergency response equipment (i.e. well control equipment, H2S cascade systems, oil spill contingency equipment, etc.) is prepared for use and properly maintained in accordance with manufacturers specifications and regulatory requirements.
1.10.2
UIE Emergency Response Webpage UIE Emergency Response & Crisis Management Standard UK North Sea Operations : Onshore Oil Spill Response Procedures Norway : Oil Spill Contingency Plan
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 5. Assure yourself, via spot checks and audit if required, that explosive management, transportation and storage procedures are being implemented. 6. Assure yourself, via spot checks and audit if required, that radiation management, transportation, storage and personnel protection procedures are being implemented. 7. Ensure that any environmental incident is reported to the relevant statutory authorities, as required by the applicable laws and permitting requirements. Note: Environmental incident reporting must comply with the statements contained in 3.9: Incident Management.
1.11.2
UIE Waste Management Webpage EPE 2005 0620 7830 Waste Management Standard EP 2004 1120 3337 Waste Policy Material Safety Data Sheet Online System Radiation Expertise Group Webpage
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 UIE Fountain Incident Reporting System Webpage UIE Hipotracker
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 identification number that can be traced back to the Lifting Accessory Register. Lifting accessories correspond with the colour coding system in place at the wellsite. Lifting accessories are properly stored. Systems are in place to prevent personnel walking under suspended loads, as per the Life Saving Rules. Dedicated man-riding winches are labeled and are only used for man riding. Man-riding is considered a Critical Lift and requires the following: Rescue from Height Plan. Permit to Work, including OIM or Toolpusher approval. JSA.
1.13.2
EP 2005-0264 Lifting & Hoisting HSE Standard Lifting & Hoisting Livelink Area EPE Operational Standard for Lifting and Hoisting Operations EPE 10 Questions for a Safe Lift
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 testing. The responsible person should also confirm that the temporary pipework is: Banded to indicate that it has been inspected, and is within the in inspection period. Restrained by an engineered restraint system that has been assembled correctly as per the manufactures recommendations, visually inspected prior to use, and is suitable for the job. Suitable for service. 4. Assure yourself that the inspection of all hammer unions has been performed using a Go-No-Go gauge rings, to assure a proper match. This may be achieved via spot checks by the responsible person when walking the lines 5. Assure yourself that flanged connections have been torqued up as per the recommended guidelines. 6. Ensure that personnel exclusion zones have been established using physical barriers before pressure testing operations commence, and that these barriers are only removed when the job is complete and the temporary pipework has been removed.
1.14.2
EP 2006 5393 Shell Global Standard for Temporary Pipework (Rev 4) EP 2009 3153 ABC Guide to Temporary Pipework (Rev 4) Hanging by a Thread Video
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 6. Assure yourself, via discussions with the Drilling and C&WI Contractors, that there are systems in place to confirm that all equipment that is not an integral part of the structure has a secondary method of retention to the structure (e.g. safety cables). Assure yourself, via spot checks, that an inventory is maintained of all temporary and permanent derrick and substructure equipment (e.g. lights, horns, etc.). All redundant derrick and substructure equipment must be removed. Assure yourself, via spot checks, that a system is in place that all hand tools required when working at height are logged prior to use, tethered during use, and recorded as having been removed upon completion of the job. Assure yourself, via discussions with the Toolpusher, OIM or C&WI Crew Chief, that No-Go and Red Zones have been identified. No-Go Zones are those for which there is a high potential risk for dropped objects, with access being controlled via the permit-to-work system. Red Zones are those for which there is a medium potential risk for dropped objects, and will be controlled by a designated person in charge (PIC) who is accountable for allowing personnel entry to the Red Zone.
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10. Assure yourself, via discussions with the Toolpusher, OIM or C&WI Crew Chief, that the Drilling or Wireline Contractors Management of Change (MOC) Process is initiated prior to adding fixtures to existing structures or installing new equipment at height.
1.15.2
EP 2009 9039 Prevention of Dropped Objects Manual UIE Dropped Objects Prevention Webpage Shell E&P Global DROPS Webpage
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 ABC Guide to Dropped Object Prevention Volume 1
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 7. Assure yourself, via spot checks and discussions with the Driller, Toolpusher or C&WI Crew Chief, that the BOP and the choke manifold are correctly configured. 8. Assure yourself that all pressure and performance testing of surface wellheads and BOP equipment are conducted, are documented, and are up to date. 9. Assure yourself, via spot checks that all drillpipe, tubing and/or casing shut-off devices are correctly configured for all connections, and that closing devices (i.e. kelly cock keys) are available, and their location known. 10. Ensure that at least two muster areas are established and communicated to all personnel at each wellsite. 11. Assure yourself, via spot checks that all essential staff (both Shell and Drilling or C&WI Contractors) have the required Well Control Certification, and that it is current.
1.16.2
EP 2002 1500 - Pressure Control Manual for Drilling, Completion and Well Intervention Operations UIE Technical Standard TS-04 Drilling and Workover Well Control UIE Technical Standard TS-10 Well Intervention Well Control
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010
extended to a maximum of 16 hours, only with the OIMs and the Shell Site Supervisors approval. Consecutive Days: The lesser of 150% of the regular trip, or 24 days.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 4. For onshore locations, assure yourself that a system is in place which checks that the driving duty hours requirements are met for drivers leaving the wellsite.
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010 5. Assure yourself, via discussions with the Medic and/or OIM, that a system is in place which ensures that previously injured or ill workers who are returning to duty following recovery and recuperation have the appropriate medical approvals to resume their duties. 6. Assure yourself, via discussions with the Medic and/or OIM, that a system is in place which ensures that workers who are returning to duty following compassionate leave are ready to resume their duties.
1.17.2
HSSE Control Framework : Fitness to Work EP2005-0120-ST Competence Assurance of HSSE Critical Positions Step Change in Safety: Periods OIM Guidance for Offshore Rota and Rest
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Upstream International Europe Basics for Compliance with Site Safety Standards JULY 2010
Training
As part of the UIE Well Departments onboarding process, the Senior Well Engineer or Senior Completion and Well Intervention Engineer shall brief all Shell Drilling and Completion & Well Interventions Supervisors on the mandatory requirements of this document prior to any job assignment. Support, as required, with be provided by the local HSE Focal Point. Additionally, the Senior Engineer shall review the contents of this document with the Drilling or Completion & Well Interventions Supervisor, and set expectations.
Document Control
The master copy is controlled as a web based document. All paper copies are uncontrolled. This is a live document and the intent is that it will be updated on an as- required basis.
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