HID Inspection Guide Offshore Inspection of Mechanical Handling & Crane Operations

Contents

 Summary  Introduction  Action  Background  Appendix 1 - The planning of mechanical handling operations and crane operations  Appendix 2 - The control of portable mechanical handling equipment  Appendix 3 - The thorough examination of lifting equipment and cranes  Appendix 4 - The maintenance and inspection of mechanical handling equipment  Appendix 5 - The maintenance and inspection of cranes  Appendix 6 - The training and competence, the providing of information, and the supervision of personnel involved in mechanical handling operations and crane operations  Appendix 7 - The undertaking of crane operations  Appendix 8 - The undertaking of mechanical handling operations using portable lifting equipment  Appendix 9 - The undertaking of mechanical handling operations on the drillfloor  Appendix 10 - The lifting of personnel by cranes or winches  Appendix 11 – Performance Assessment

Summary

This guidance outlines an approach to the inspection of dutyholder’s arrangements for the management of offshore mechanical handling operations, including crane operations and the management of offshore lifting equipment. It also sets out the criteria for satisfactory and unsatisfactory performance factors against which the dutyholder will be rated. Reference is made to technical standards and guidance that inspectors will use to form an opinion for legal compliance.

Introduction

Although in recent years there has been a reduction in the number of incidents occurring during both offshore mechanical handling operations and crane operations unfortunately they still continue to occur. Tragically some of these incidents have resulted in serious injuries and fatalities. In addition an incident during mechanical handling or crane operations can have the potential to be an initiating event for a

major accident, such as a dropped load or a failed crane boom falling onto and rupturing a vessel or pipeline containing hydrocarbons.

To ensure incidents do not occur they must be carried out in a safe manner and this can only be achieved if mechanical handling and crane operations are adequately planned, are undertaken by competent personnel, and utilise equipment that is both suitable for the task and in a safe condition.

Dutyholders must have an effective system in place for the management of mechanical handling operations and crane operations and these guidelines give inspectors guidance on how to inspect the suitability and effectiveness of a management system. This topic breaks down into ten core intervention sub topics.

An overview of how to undertake an inspection of each of these sub topics is included in the appendices. The use of this guidance will enable a consistent approach to be adopted for the inspection of these sub topics

Action

This guidance should be used by IMT Inspectors; however it may be necessary to have some input from the relevant specialist inspectors where there are technical issues on which the IMT Inspector requires guidance.

The ten core inspection sub topics are as follows:

 The planning of mechanical handling operations and crane operations  The management of mechanical handling operations and crane operations  The role of the Competent Person  Risk Assessments  Lifting Plans  Toolbox Talks  The control of portable mechanical handling equipment  The thorough examination of lifting equipment and cranes  The maintenance and inspection of mechanical handling equipment  The maintenance and inspection of cranes  The training and competence, the providing of information, and the supervision of personnel involved in mechanical handling operations and crane operations.  The undertaking of crane operations  The undertaking of mechanical handling operations using portable lifting equipment  The undertaking of mechanical handling operations on the drillfloor  The lifting of personnel by cranes or winches

The details of how to undertake an inspection of each of these sub topics is given in the attached appendices. The effective inspection of these sub topics will include establishing that the dutyholders documented procedures are sufficiently robust and that the dutyholder is actually following their procedures.

Background

The main legal requirements which are applicable to Mechanical Handling and Crane Operations come from the Lifting Operations and Lifting Equipment Regulations (LOLER). These Regulations implement the lifting provisions of the Amending Directive to the Use of Work Equipment Directive. The Provision and Use of Work Equipment Regulations (PUWER) apply to all work equipment including lifting equipment but LOLER deals with the specific risks associated with lifting equipment and lifting operations.

Mechanical Handling may involve moving a load horizontally (pulling), or the raising and lowering of a load (lifting). PUWER will apply to both activities however the requirements of LOLER only become applicable when there is the raising or the lowering of a load.

LOLER applies to all lifting equipment on offshore installations and all lifting operations undertaken on offshore installations. In addition certain sections of LOLER apply to some ‘specified operations’ undertaken from vessels in connection with offshore installations.

The Management of Health and Safety at Work Regulations (MHSWR) brings in the requirements for risk assessments to be carried out to identify the nature and level of risks associated with mechanical handling and crane operations.

LOLER defines ‘lifting equipment’ as work equipment for the lifting and lowering of loads and includes its attachments used for anchoring, fixing or supporting it. ‘Lifting accessories’ are specific items of lifting equipment which are used to connect the load to the lifting machine (slings, shackles etc.).

PUWER requires employers to ensure that work equipment is suitable for the purpose and additionally LOLER requires that lifting equipment is of adequate strength. The requirements for the strength of items of lifting equipment are specified in the Machinery Directive within the ‘essential health and safety requirements to offset the particular hazards due to a lifting operation’.

The Supply of Machinery (Safety) Regulations brings in the requirements for persons who supply lifting equipment to ensure the lifting equipment meets the Machinery Directive ‘essential health and safety requirements to offset the particular hazards due to a lifting operation’. Such equipment should be CE marked and accompanied by EC declaration of conformity.

It should be noted that The Supply of Machinery (Safety) Regulations and the Machinery Directive do not apply to lifting equipment supplied for use on Mobile Offshore Drilling Units, Floating Production Units, or Floating Storage Units. However in practise non CE marked lifting equipment which meets the requirements of the Machinery Directive will generally be found on such installations together with lifting equipment manufactured to the American API standards.

Organisation Targeting

Although the inspection may be carried out at any installation it is particularly important to carry this out for every dutyholder.

Timing

Inspections should be planned within the timescales set out by ED divisional management.

Resources

Resources for the undertaking of this inspection will come from the Inspection Management Team inspectors with support from discipline specialist inspectors

Recording & Reporting

The dutyholder performance ratings should be entered on the Inspection Rating Form (IRF) tab of the relevant Installation Intervention Plan Service Order. Findings from the inspection should be recorded in the normal post inspection report and letter

Further References

 LOLER Regulations and ACoP  Step Change in Safety ‘Lifting and Mechanical Handling Guidelines’  Step Change in Safety ‘Best Practise Guide to Manriding Safety’  Step Change in Safety ‘Safety of Wireline Operations’  Step Change in Safety ‘Marine Transfer of Personnel’  Offshore Safety Notice 2/2005 ‘Single line components in the hoisting and braking systems of offshore cranes’  HSG 221 ‘Technical guidance on the safe use of lifting equipment offshore’  SPC/ENF/152 The lifting operations and lifting equipment regulations 1998 – Offshore aspects

Appendix 1 - The Planning of Mechanical Handling Operations and Crane Operations

Mechanical Handling Operations and Crane Operations

Mechanical Handling Operations are those activities which involve the movement of a load using work equipment. This work equipment can be that which is either manually operated or power operated. When a Mechanical Handling Operation requires a load to be raised or lowered then the required work equipment becomes lifting equipment and the activity can be considered to be a lifting operation. Examples of mechanical handling equipment which is not lifting equipment would be a wheeled trolley used to move a load or a tirfor used to pull a load on level ground. However if such equipment is used to move a load up or down an incline then this would become a lifting operation.

Incidents have occurred with turntable types of wheeled trolleys (barrows) during the movement of loads on level ground. Wheeled trolleys in which the turntable carrying the front wheels can be turned at angles greater than 45 degrees can be prone to tipping as a result of the centre of gravity of the carried load changing as the turntable is turned.

Crane Operations are mechanical handing operations undertaken using pedestal cranes, gantry cranes, BOP cranes etc.

Legal Requirements

 The Health and Safety at Work etc Act 1974 requires a safe system of work to be in place for the mechanical handling operation.  LOLER Reg 8 (1)(a) requires that every lifting operation involving lifting equipment is properly planned by a competent person.  The Management Regulations Reg 3(1) requires that for every mechanical handling operation a risk assessment is undertaken to identify the hazards and the corresponding risks.  PUWER Reg 4 requires suitable work equipment to be provided for the mechanical handling operation

Inspection Procedure

Management System

To ensure the legal requirements are met duty holders must have within their management system details of how they will ensure mechanical handling operations will be carried out in a safe manner. This should be a specific section within their management system detailing how they manage mechanical handling operations and lifting equipment. The Safety Case will also make reference to this document as being the system that will be in place to prevent dropped objects, that is dropped objects that could be an initiating event for a major accident hazard.

Inspectors should check the dutyholders management system that this specific section exists and that it is readily available to the personnel who plan lifting operations.

The fundamental starting point for any mechanical handling operation is the identification that such an activity is to take place and then that it is planned by a competent person. Only by careful planning can these activities be carried out in a safe manner. The Step Change in Safety publication, ‘The Lifting and Mechanical Handling Guidelines’ defines the responsibilities, training, the competencies and the assessment of those personnel involved in the lifting and mechanical handling operations and it sets out a structured approach to ensure that such operations are systematically planned and carried out in a safe manner.

Inspectors should ask dutyholders whether they are following the Step Change Guidelines or if not have they compared their current management system and working methods with these guidelines to ensure the principals have been adopted.

All personnel involved in mechanical handling operations and crane operations must have been trained, have the required experience and have been assessed as competent. This also applies to the personnel who plan and supervise these operations. The Step Change Lifting and Mechanical Handling Guidelines give guidance on the key parts of a competency scheme and refers to industry standards for training and competency, such as the OPITO standards.

Inspectors should check that dutyholders have a competency scheme in operation and that it is being followed by looking at the competency / training matrix completion dates.

Inspectors should check that the dutyholders planning process does not focus only on the lifting and lowering of a load but includes how the load will be transported to or from the point of lift. In particular when hand propelled wheeled trolleys/barrows are used how the suitability of this method of transport has been assessed and the risk assessment process relating to its use.

The Competent Person for Planning Lifting Operations

The Competent Person is someone who has the required level of competency to be able to produce written plans for the undertaking of lifting operations and be able to check and authorise plans that have been written by others. He must have the practical skills and theoretical knowledge to plan lifting operations, undertake risk assessments and conduct toolbox talks. The Competent Person may or may not supervise the lifting operation but he is the focal point for all the technical aspects associated with lifting operations and lifting equipment. He must know his own competency limitations and know when additional technical support is required and from where this can be obtained.

Inspectors should check that on the Offshore Installation being inspected that dutyholders have such a Competent Person in position. This may be a dedicated position or one in which the person undertakes both this and another role. The name

frequently given to this person is the ‘Loler Focal Point’, the ‘Loler Competent Person’ or ‘The Lifting Supervisor’.

Inspectors should talk with this Competent Person and determine whether his role meets the specification described above. Should the person also undertake another role that that he is happy that he can still perform his Competent Person duties fully? Also does he know where he can obtain additional technical support when this is required?

Inspectors should establish that the Competent Person is in the Dutyholders competency scheme and that the required training / assessments are up to date.

Risk Assessments

Every mechanical handling operation and crane lifting operation must be subjected to a risk assessment as part of the planning process. This risk assessment will identify the hazards and the corresponding risks. The assessment will detail how these risks will be eliminated or adequately controlled. The risk assessment will be either produced by the Competent Person or reviewed by the Competent Person. Unfortunately risk assessments are frequently viewed as a requirement of the regulations rather than being viewed as something which is both meaningful and useful to the lifting team. A common problem is the failure is to identify site specific hazards such as those due to the proximity to other equipment and those of prevailing environmental conditions. Emphasis is instead placed on recording hazards that are common to all lifting operations which will have control measures already in place. An example would be the failure of lifting equipment with the control measure in place of only using lifting equipment which has the current colour coding applied, that is ‘currently certified lifting equipment’.

Inspectors should consider the following by speaking to personnel and attending toolbox talks:

 Do the risk assessments address site specific hazards?  How are the results of the risk assessment communicated to the members of the lifting team?  How do the management ensure the risk assessment for repetitive (routine) tasks continue to be suitable?  Is there any evidence of risks being ‘assessed out’ rather than ‘engineered out’?  How is the management of change considered i.e. when conditions change or when a change occurs in the task?  Where applicable does the risk assessment include the use of mechanical handling aids such as wheeled trolleys and barrows?

Lifting plans

A lifting plan is the step by step instructions to be followed for carrying out the lifting operation together with details of the equipment to be used. It will either be produced by the Competent Person or it will be authorised by the Competent Person. The degree of planning can vary considerably and many dutyholders will

have systems in place to enable lifting operations to be classified as either ‘routine’ or ‘non routine’ For ‘routine’ lifting operations the lifting plan may be ‘generic’ in nature but will need to be reviewed prior to undertaking the lifting operation. For ‘non routine’ lifting operations they can be further classified in terms of ‘simple’, ‘complicated’ and ‘complex’. A ‘simple’ lifting operation may not require a written lifting plan whereas a lifting plan for a ‘complicated’ or ‘complex’ lifting operation may require additional authorisation from onshore technical specialists.

The lifting plan and the risk assessment are closely linked. Many hazards can be avoided or overcome by selecting the most appropriate work equipment and choosing movement paths which avoid hazard areas. It is the hazards which remain that need to be addressed in the risk assessment. In the case of a deck lifting operation using a crane the lifting plan will be for the complete task whereas for a lifting operation using portable lifting equipment it will be probably only be a part the overall task. The overall task will have a risk assessment, a permit, isolations etc.

Inspectors should consider the following by viewing lifting plans, by speaking to personnel and by attending toolbox talks:

 Has the lifting plan been authorised by the competent person?  Does the lifting plan clearly outline the step by step instructions for undertaking the lifting operation, the work equipment to be used and a sketch showing how it is to be installed?  Is there a system in place for the storing of lifting plans?  How is the lifting plan communicated to the members of the lifting team?  If using an existing lifting plan what steps have been taken to ensure it is still suitable?  Does the lifting plan include, where applicable, the movement of loads to and from the point of the lift?

Toolbox Talks

Before undertaking any mechanical handling operation or crane operation a toolbox talk should be held to discuss the task or tasks to be undertaken. This must include the method of undertaking the lifting operation as detailed in the lifting plan and any hazards together with the associated control measures detailed in the risk assessment. If at all possible the toolbox talk or the relevant portion of the talk should be held at the planned work site in order to facilitate easy and immediate recognition of the issues connected with the task. The toolbox talk should be managed in a manner which stimulates interest, allocates responsibilities and maximises participation. If during the discussions it is identified that