Health and Safety
Executive / Commission
Freedom of Information
SPC/TECH/OSD/32
Author Unit/Section: OSD 2.4
Version No: 2
Target Audience: OSD Inspectors
This document provides guidance on the assessment of risks from tubular handling on the drill-floor of drilling rigs.
1 The guidance in this SPC is in addition to, but does not conflict with, the guidance given in the Guidance for the Assessment of Safety Cases - Engineering Topics (GASCET) or in the Assessment Principles for Offshore Safety Cases (APOSC).
2 Tubular handling on the drill-floor of drilling rigs has historically carried a significant risk of personal injury. Due to the size and age of the drilling rigs working in the UKCS, it is not possible to mechanise all of the manual handling tasks and to remove people from the danger zone. However, it has been difficult for Duty Holders to demonstrate that the existing levels of mechanisation mean that the risks to people are as low as is reasonably practicable (ALARP).
3 HSE has worked with Duty Holders and equipment manufactures to develop a tool to assist in assessing what level of mechanisation is appropriate for a particular rig carrying out specific types of operations.
4 The tool is known as the Tubular Handling Appraisal Tool and, with the International Association of Drilling Contactors (IADC) having taken ownership it, the tool can be downloaded for free from their IADC website. Although disc versions exist, the web version should be used for preference, as it will be the most recent version.
5 Traditionally tubular handling has involved much manual handling. The Manual Handling Operations Regulations 1992 require manual handling to be avoided where practicable and where there is risk of injury. Some manual handling of tubulars has already been reduced by the use of equipment such as top drives. However, the retrofitting of mechanised equipment may eliminate certain incidents but may also introduce new risks of injury.
6 Under the regulations, it is not necessarily possible, or desirable, to introduce mechanised equipment wherever it could be installed. An assessment is required to determine whether the overall risks to people are ALARP when considering the retrofitting of mechanical handling devices.
7 The creation of the tubular handling assessment tool was undertaken by a workgroup consisting of experienced industry professionals from the drilling contractors, fixed installation owners, North Sea Regulators and equipment manufacturers. The rig owners (whether a MODU or on a fixed installation) have endorsed the use of the tool to assess whether the risks are ALARP. It is therefore expected that most, if not all, Duty holders will use the tool. Of course there is no legal requirement to use the assessment tool but it does provide a consistent method of demonstrating ALARP.
8 Although the use of the tool is not mandatory, HSE sees it as an efficient method for Duty holders to demonstrate that the risks are ALARP. HSE intend to check that all installations have been assessed as part of a process to ensure that the risks associated with tubular handling operations are ALARP.
9 Inspection Management Teams should raise the subject of tubular handling with their Duty holders to check whether an assessment has been carried out. This should be done as part of routine visits. Any planned or recent changes to the level of mechanisation on the rig should be noted and this information passed to OSD 2.4 for collation and action, if necessary, by Wells Inspectors.
10 The assessment of a safety case will act as a trigger for the Wells inspectors to assess the handling of drilling tubulars and they may request to see the tubular handling spreadsheet completed by the Duty holder. Some assessments may require the Wells Inspector to seek information or guidance from other specialists such as Mechanical Handling or Human Factors.
11 Any deficiencies that are found will be dealt with by the individual Wells Inspector. Generic issues will be co-ordinated by OSD 2.4.
Further information can be obtained from Head of Discipline - Well Engineering and Operations OSD 2.4, VPN 525 2581.