How to survive a rig inspection: Health & Safety / SMS Inspection
In this addendum to our 16 part series, inspection engineer Billy McBain talks Health & Safety and SMS inspections.
As a pre-cursor to the Health & Safety inspector’s rig visit, it is often advantageous to attend the drilling contractors offices ashore. This gives the inspector an opportunity to meet the company HSE manager and assess and comment on HSE Leadership at a more corporate level. This would also be a suitable time to commence review of the Safety Management System.
Dependent on rig location, the inspector would look at the how the SMS has been developed; for example, is it as per UK Safety Case Regulations and UK HSE Guidelines for Managing Health & Safety if operating in the UKCS?
Many of the company’s HSE-related policies and procedures will be read and assessed by the inspector during the inspection period; policies and procedures would be assessed against the requirements of numerous regulations and references including UK HSE, IADC and industry best practices. This can be adjusted for area of operation (e.g. OSHA & BSEE in the United States).
Due to the volume of policies and procedures, drilling contractors could do a lot worse than grant the inspector guest access to their online SMS system to allow them to view policies and procedures as required.
It may be an old cliché, but first impressions do carry weight. A good health and safety inspector will assess before and during boarding the rig, whether it be by helicopter or Frog/Billy Pugh, to ensure procedures are followed.
Following on from this, the inspector will assess and comment on the rig safety inductions, focussing on the quality, content and effectiveness.
Risk assessment, task planning and control of work rightly receive attention. These encompass everything from reviewing procedures, auditing permits to work and energy isolations, reviewing risk control measures, reviewing the TBT and AAR process. Practically, the inspector may seek to follow a selected task from beginning to end. These can include planning, risk assessment, PTW (if required), energy isolations, attend the TBT, carrying out the task and any AAR. All of the aforementioned will be assessed against company policies and procedures – do they do as they ‘say on the tin’?
In a similar vein, the inspector would look at lifting operations and lifting equipment from a health and safety perspective. Practically, this could involve following a lifting task from inception to completion, including lifting plans and categorisation, TBT, personnel qualifications, random check of equipment, conduct of the lift and any AAR. In the UK, this is assessed against LOLER, company procedures and industry guidance.
How the company looks after its personnel will be examined, including occupational health policies such as control of noise, LEV, HAVS, manual handling, medical and health and hygiene. Are the policies and procedures in line with HSE requirements? Does your company follow these policies and procedures?
Other specific health and safety-related aspects the inspector will show an interest in include Emergency Response & Preparedness, Management of Change, Hazardous Substance Management, Accident & Incident Investigation & Reporting. As before, these are assessed against UK HSE requirements and Company Policies.
Communications play a huge part in any company achieving and exceeding Health & Safety standards and expectations. The inspector will continually assess communications over the inspection period, including observing the top-to-bottom and bottom-to-top communications culture, attendance and assessment of rig safety meetings, assessing the effectiveness of the Company Observation & Stop Work Authority programs and general Health & Safety Leadership & Communication on the rig.
Additional work-scope items, as required by the client can include sample PUWER inspections of equipment and DROPS management system assessments.
By the end of the inspection period, the inspector will undoubtedly have a feel for the overall Health & Safety culture of the rig. The development and maintenance of a positive safety culture should be part of your vision and strategy.