Dropped Object Prevention Scheme Recommended Practice

www.dropsonline.org REVISION

Revision Record

Revision Date Comment Issued by: Issue 1 06.23.2017 First formal issue DROPS Issue 2 03.31.2020 Widen scope, add Maintenance and Equipment DROPS Selection, update information based on feedback and changing stakeholder policy, elimination of components not integral to a management system, inclusion of clear and concise minimum requirements.

COVER IMAGE: Courtesy Photographic Services, Shell International Ltd.

DROPS Guidance and Best Practice These documents represent ‘Best Practice’, as agreed by a consensus of the members of the DROPS Workgroup. Certain processes and procedures detailed in these documents may require modification to suit specific locations, activities or facilities. However, the underlying guidelines are a recommended component of any integrated dropped object prevention scheme. These guidelines are subject to regular review and update in response to improved methodologies and technologies.

NOTE: Any industry organisation or body may apply the Recommended Practices offered by the DROPS initiative throughout their own operations and activities. The Recommended Practices guidance and elements are available for free download from the DROPS website (www.dropsonline.org) and may be copied in part or in full as required and employed in the prevention of dropped objects worldwide. These are available copyright free and include editable electronic templates. Where appropriate, credit may be given to the DROPS initiative as the global resource for dropped object prevention guidance. However, under no circumstances shall the DROPS name, brand or identity be used to promote or endorse any service, product, programme, promotion or publication.

Disclaimer

The information herein is provided in good faith. Users of the information contained within this publication, neither DROPS Online nor any of its members past, present or future warrants its accuracy or will, regardless of its or their negligence, assume liability for any foreseeable or unforeseeable use made thereof, which liability is hereby excluded. Consequently, such use is at the recipient’s own risk on the basis that any use by the recipient constitutes agreement to the terms of this disclaimer. Nothing herein is intended to conflict with any governmental laws, rules or regulations now in effect or hereinafter enacted: such laws, rules and regulations always take precedence

Table of Contents 1 Introduction ................................................................................................................................. 6 1.1 Background ................................................................................................................................... 6 1.2 Purpose ......................................................................................................................................... 6 1.3 Scope ............................................................................................................................................ 6 1.4 Definitions .................................................................................................................................... 7 1.5 Abbreviations.............................................................................................................................. 11 2 Dropped Object Prevention Scheme.......................................................................................... 13 2.1 DROPS SMS Minimum Requirements......................................................................................... 13 2.2 Risk Assessments ........................................................................................................................ 14 2.3 DROPS Calculator........................................................................................................................ 15 2.4 Hierarchy of Controls.................................................................................................................. 16 2.5 Company Roles and Responsibilities .......................................................................................... 17 2.6 Safety Management System Bridging ........................................................................................ 18 2.7 DROPS Zone Management – No Entry and Restricted Access Zones ......................................... 19 2.8 Monitoring and Measurement of Safety Performance .............................................................. 20 2.9 Training ....................................................................................................................................... 21 2.10 Human Performance ................................................................................................................ 22 3 DROPS Inspection ....................................................................................................................... 24 3.1 Independent Dropped Objects Inspections................................................................................ 24 3.2 Systematic DROPS Inspection Program ...................................................................................... 25 3.3 Unplanned Inspections ............................................................................................................... 27 3.4 Transportation of Equipment and Loads .................................................................................... 28 3.5 Assurance ................................................................................................................................... 29 4 DROPS Hazard Management...................................................................................................... 30 4.1 Engineering Design & Equipment Selections ............................................................................. 30 4.2 Reliable Securing ........................................................................................................................ 31 4.3 Tubular Handling ........................................................................................................................ 32 4.4 Lifting and Hoisting ..................................................................................................................... 33

4.5 Portable Tools and Equipment ................................................................................................... 34 4.6 Local Containment...................................................................................................................... 35 4.7 Permanent Equipment at Height................................................................................................ 35 4.8 Temporary Equipment at Height ................................................................................................ 37 4.9 Temporary Work Platforms ........................................................................................................ 37 4.10 Maintenance ............................................................................................................................ 38 5 Reporting and Performance ....................................................................................................... 39 5.1 Minimum Reporting Requirements ............................................................................................ 39 5.2 Self-Assessment .......................................................................................................................... 40 6 Other Industry Standards ........................................................................................................... 41 6.1 Industry Standards and Document Number .............................................................................. 41 DROPS Calculator ............................................................................................................... 42 Training Matrix ................................................................................................................... 43 Post Jarring Checklist ......................................................................................................... 44 Tubular Handling Checklist ................................................................................................ 47 Portable Tools and Equipment ........................................................................................... 49 Figure E.1 - Tool Inventory Log......................................................................................................... 49 Figure E.2 - Tools and Equipment At Height Register ...................................................................... 50 Permanent and Temporary Equipment At Height ............................................................. 51 Transportation and Equipment Loads ............................................................................... 53 Dropped Object Prevention Scheme Bridging ................................................................... 54 10 Questions to a Safe Lift .................................................................................................. 55 Performance Influencing/Shaping Factors ......................................................................... 56 Human Performance Online Resources ............................................................................. 57 DROPS Recommended Practice Gap Analysis .................................................................... 58

1 INTRODUCTION

1.1 Background

Dropped Objects pose the number one risk of serious injuries, fatalities, and equipment damage in industries across the globe. DROPS is the global initiative focused on preventing Dropped Objects by providing supporting engagement and learning materials as well as setting recognized best practices. The goal of this Recommended Practice is to consolidate and promote the minimum criteria of a dropped object prevention management system as agreed by the consensus of DROPS Members.

1.2 Purpose

This Recommended Practice was developed by a coalition of oil and gas professionals with the aim of setting basic requirements for Dropped Object prevention that can be incorporated into existing company Safety Management Systems (SMSs).

This document sets out minimum recommended practices that support the prevention of Dropped Objects and the development of policies and procedures for company SMSs. It is not intended to be considered the finalized requirements of a company Dropped Object Prevention Scheme (Scheme).

1.3 Scope

The content in this document is intended to be applied to operations in which Dropped Objects could cause harm to people, equipment, and/or the environment, including both worksites and Company premises.

Operations need to be risk-assessed to determine applicability of these guidelines. Exclusions may apply (e.g., man overboard, tools lost in hole, aircraft operations, well control events).

This document may include examples from the oil and gas industry, but principles contained within may be applied across industrial bounds.

The recommended practices herein set out requirements to be applied within a Dropped Object Prevention Scheme. Additional Guidance sections provide best practice examples in the application of the recommended practices.

1.4 Definitions

ALARP As low as reasonably practicable, or ALARP is a term often used in the regulation and management of safety-critical and safety-involved systems. The ALARP principle is that the residual risk shall be reduced as far as reasonably practicable Area Owner A singular individual responsible for completion of scheduled DROPS inspections and required maintenance within a specified area per company standards

Assurance Systematic verification of one’s own activity

At Height 6 feet (1.8 meters) above ground level or where there is potential for a person or equipment to fall 6 feet or more below the work surface or into a body of water

Barrier A function or safeguard planned to prevent, control, or mitigate undesired events or accidents

Barrier Owner An individual responsible for creation or maintenance of a healthy barrier

Bridging Document (i.e., Interface Agreement) A documented plan that defines how diverse organizations agree on which safety management elements are used when co-operating on a project, contract, or operation Company The individual, partnership, firm, or corporation that incorporates dropped object prevention into existing safety management systems

Competent Person An individual who is capable of identifying existing and predictable hazards in the surroundings or working conditions and who has the authority to take prompt corrective measures to eliminate them

Contractor The individual, partnership, firm, or corporation that comes to a contractual agreement with an Operator to provide goods and services

DROPS An industry collaborative organization that supplies supporting material and recommended practices for managing dropped object hazards. This may refer to the organization itself or endorsed principles

Dropped Object Prevention Scheme (Scheme) A set of principles and methodologies that are put in place as part of a company’s safety management system to identify potential dropped object hazards, prevent their occurrence, and mitigate their outcome. In this document, the terms Dropped Object Prevention Scheme, Dropped Object Scheme, or Scheme, may be used interchangeably

Dropped Object Any item with the potential to cause injury, death, or equipment/environmental damage, that falls down or over from its previous position. Dropped Objects may be further classified as static or dynamic.

Dynamic Dropped Object Any Dropped Object whose failure may be attributed to applied forces (e.g., from the impact of equipment, machinery or other moving items, severe weather, helicopter downdraft, manual handling etc)

High Potential (HiPo) Incident A near miss or other incident that has a strong potential to cause a fatality, life altering injury, major equipment or asset damage, severe environmental harm, or significant operational loss

Human Factors The range of physical, psychological, social, or organizational influences which affect Human Performance and how people carry out their activities. It is also a scientific discipline that focuses on the design of equipment, processes and work activities to reduce mistakes and increase efficiency. Human Performance What individuals do as part of their daily activities and how they carry out individual and group tasks. Identification and management of Human Performance ensures robust operations. Incident An unexpected event or chain of events that has resulted in or has the potential to cause harmful consequences, such as injuries, illnesses, property damage, or environmental impact

Independent Auditors Independent auditors are recognized Subject Matter Experts and build assessments based on a company’s scheme as well as original equipment manufacturer (OEM) recommendations and recognized best practices. Independent auditors have no connections to the company which they are auditing

Jarring The process of dynamically transferring stored energy to free stuck drill pipe

Lagging Indicator Lagging indicators measure the impact of workplace incidents after an incident has occurred; examples include number of fatalities, number of injuries, and severity rates or potential severity rates Leading Indicator Leading indicators are proactive, preventative, and predictive measures that monitor and provide current information about the effective performance, activities, and processes of a health, safety, and environment (HSE) management system that drive the identification and elimination or control of risks in the workplace that can cause incidents and injuries Management of Change (MOC) A process utilized to ensure that safety, health, and environmental risks and hazards are properly controlled when an organization makes changes to their facilities, operations, or personnel

Maintenance Management Program A process utilized to keep specified equipment in proper working order. Specifically relating to dropped objects, inspection points during routine maintenance can be pointed out and verified in compliance

Near Miss An event or chain of events that has not resulted in injury, illness, physical damage, or environmental damage, but had the potential to do so in other circumstances

Operator The individual, partnership, firm, or corporation having control or management of operations on the leased area or a portion thereof

Original Equipment Manufacturer (OEM) A company that creates a part or subsystem that is utilized within another company's product or package

Picture Book A detailed visual guide showing specific equipment and its proper methods of retention. This may be created by a company, independent auditor, or requested of an OEM in a contractual agreement at time of initial purchase

Primary Fixing Principal method by which an item is installed, mounted, and secured to prevent the item from falling (e.g., bolted connections, screws, pins, buckles, clips, welds)

Qualified Person An individual who possesses the knowledge, experience, and training to fulfill the competencies of the defined role(s)

Reliable Securing The appropriate selection, application, and management of fastenings and fixings

Risk Management Process A procedure within a company’s safety management system that formally evaluates potential for Dropped Objects within given circumstances and/or areas

Risk Register A document created during the early stages of planning that is utilized as a tool for tracking known or found issues and eliminating or mitigating risks as they arise

Safety Management Systems (SMS) A systematic approach to managing safety, including the necessary organizational structures, accountabilities, policies, and procedures

Safety Securing An additional mechanism for securing the item to the main structure that restrains the item or its components from falling (e.g., rated steel, synthetic nets, lanyards, baskets, wires, slings)

Secondary Retention The engineered method for securing the primary fixing to prevent loss of clamping force or displacement of fastening components (e.g., locking washers, locking wire, safety pins)

Static Dropped Object Any Dropped Object whose failure may be attributed to gravitational or natural forces (i.e., without an applied force, unsecured items, or failure of fixings)

Subject Matter Expert A person who has proven through experience or training to be an authority in a particular area or topic

Third Party The individual, partnership, firm, or corporation, who provides a service outside of the scope of the contractual agreement between the Operator and Contractor

Training The process by which an individual gains the required level of skill and knowledge to perform a function or task

Tripping The physical act of running a drill string in or out of the wellbore

1.5 Abbreviations

CI Continuous Improvement

DROPS Dropped Object Prevention Scheme

HSE Health, Safety, and Environment

KPI

Key Performance Indicator

MoC Management of Change

PIC Person in Charge

PPE Personal Protective Equipment

2 DROPPED OBJECT PREVENTION SCHEME

2.1 DROPS SMS Minimum Requirements

No. Area Description

1 Management System Where dropped object hazards are present, a Dropped Object Prevention Scheme shall be in place

Companies shall create job specific roles, responsibilities, training, and competencies for dropped 2 Roles & Responsibilities object prevention

While work is being conducted between multiple companies, prevailing DROPS shall be clearly 3 SMS Interface communicated and understood by all present

Risk assessments shall be conducted prior to beginning work to identify job-specific dropped 4 Risk Assessment object hazards and put controls in place

Companies shall implement full inspection programs including Independent Inspections minimally 5 Inspection every 3 years, systematic inspections for specifically identified equipment, unplanned inspections, and train competent personnel to properly inspect

6 Equipment Design Manufactured equipment shall be designed to eliminate dropped object exposure where possible

All equipment at height shall be inspected and maintained per Original Equipment Manufacturer 7 Equipment at Height recommendations and Company policy

All equipment at height that is not an integral part of the primary structure shall be reliably 8 Reliable Securing secured

While working at height, all portable tools shall be transported in a secure manner and tethered 9 Working at Height while in use

Tubular handling mechanisms shall be measured, independently checked, and have functionality 10 Tubular Handling verified prior to use

11 Lifting & Hoisting A Lifting & Hoisting program shall be in place that minimally meets the requirements of IOGP 376

12 Shipping & Transport Pre-shipping inspections shall be completed prior to transporting equipment

Restricted Access & No-Entry Zones shall be established within the job plan based on job scope 13 Zone Management and dropped object risks present

14 Assurance Methods of assurance shall be implemented to show effectiveness of DROPS implementation

2.2 Risk Assessments

Recommended Practice Risk assessments are conducted prior to commencing work in both scope planning and pre-job meetings, as well as at intervals defined by each company’s SMS. Assessment of the risk potential of dropped objects are discussed as part of every risk assessment. Risk assessments are conducted by qualified person(s) and cover area-specific activities and conditions. The purpose of a risk assessment is to identify and prevent or mitigate the risk of Dropped Objects following the Hierarchy of Controls (see section 2.4).

Key components for risk management are as follows:

Identifying and assessing the risks

Maintaining or adding controls and/or barriers

Developing or improving risk management measures to further manage these risks.

Periodically monitoring effectiveness of risk management measures and status of actions

Compiling and reporting risk information

After Action Reviews to incorporate feedback into existing controls

The DROPS Calculator (see Annex A) is a tool for measuring the potential consequences of Dropped Objects and is utilized during job planning to identify hazards and implement both prevention controls and zone management.

Additional Guidance To maintain and track identified risks, a risk register is utilized. A Dropped Object risk register is created by a qualified person (e.g., the area owner) for at-risk equipment. Equipment of high complexity may require technical guidance from OEMs on how to position, fasten, secure, and inspect at height. The risk register categorizes the Dropped Object potential risk of the equipment (i.e., low, medium, or high) regarding likelihood of falling and consequential harm.

The register contains the following:

Relative risk of equipment aloft

Equipment identification

Equipment location

Methods of positioning, fastening, and securing

Visual guides

High and medium risk items are typically photographed to monitor potential deterioration. An example of visual guidance included in a risk register can be found in Annex F.

2.3 DROPS Calculator

Recommended Practice The DROPS Calculator provides a common benchmark in the classification of the potential consequences of a Dropped Object. It is endorsed by the DROPS workgroup and globally recognized by HSE organizations.

Additional Guidance The DROPS Calculator is a guide only and provides a general idea of the potential severity of a Dropped Object. A detailed risk assessment delivers a more accurate calculation of potential severity.

The DROPS Calculator is:

Designed to be employed during task planning and risk assessment to determine potential severity rating

Used in reporting processes to determine potential outcome of an actual dropped object incident

Considered during design and manufacture to address requirements for positioning, fixtures, and fittings for items to be secured at height

Considerations and tips for using the DROPS Calculator:

With light objects (i.e., with a weight <0.1 kg), a key influencing factor is the likelihood of an object piercing the skin and damaging tissue and organic functions

The calculator assumes a blunt object and does not take into consideration sharp objects (e.g., broken glass, metal shards)

The wearing of standard personal protective equipment (i.e., hard hat, safety boots, and eye protection) is assumed in the calculator

Do not subtract the height of an individual; measure fall distance to ground level

The DROPS Calculator and similar tools are guides, providing only cursory indication of possible outcome, not precise predictions

2.4 Hierarchy of Controls

Recommended Practice The Hierarchy of Controls is a system utilized to eliminate or minimize exposure to hazards. The methodology is applied as part of the risk assessment in order to make the operation as safe as possible. The order of effectiveness begins with elimination of the hazard present and ends with the use of personal protective equipment (PPE) if there is no alternate control.

The system is taught through training to personnel (see section 2.9) and is promoted as standard guidance for managing