KP2 Phase 2 Inspection Templates

INSTALLATION and DUTY DATE(S) IMT and INSPECTOR(S) HOLDER

Key Persons interviewed Position

(Not all persons need to be named e.g. an entry of ‘both drill floor teams’, would be sufficient for group interviews)

No 1 Management of Lifting Operations

The safety management system should establish a safe system of work for all lifting operations, both on the deck and the drill floor. The majority of accidents occur during routine lifts due to their increased frequency and the assumed familiarity with the risks. The essential elements required for a safe system of work include: • Planning the lifting operation with the development and implementation of a documented lift plan • Assessing the risks associated with the lifting operation • Selecting appropriate equipment • Using the selected equipment correctly • Providing equipment that is maintained in good condition • Communicating the lifting plan to those involved. • Clarifying everyone’s role and responsibilities, identifying who is in control of the lifting operation • Involving suitably trained and experienced personnel who have been assessed as competent. Preventing unauthorized use. Providing adequate supervision

By interview and inspection onshore and offshore establish the effectiveness of a duty holder’s overall management of lifting operations.

Evidence/responses are required on the following two questions:

• Have the company’s current working methods been assessed against the above principles as put forward in either British Standard BS 7121 (ISO 12480) “Safe use of cranes” or the STEP Change Lifting and Mechanical Handling Guidelines. If they have, what did they find and what actions if any were taken. If not, do they plan to do this?

• How does the duty holder monitor and audit its safety management system with respect to lifting operations? Review related documentation.

Guidance Questions Actions

• Does monitoring/audit include the following information sources? Injuries and dangerous occurrence investigations: Near miss reporting: Safety observation programme outputs Weakness or omissions in agreed performance standards.

• Observe a lifting operation (preferably a routine one) being carried out offshore to assess the quality and effectiveness of the management of that operation.

Main Relevant Legislation HSWA Sec 2 & 3 LOLER Reg. 8 MHSWR Reg. 3,4,5. PUWER

Inspection Notes No1 Management of Lifting Operations

Onshore Management

Offshore Management

Workforce

HSE Comments:

Action Taken:

NON COMPLIANCE / ISOLATED FAILURE / IN COMPLIANCE / NOT INSPECETD MAJOR FAILING INCOMPLETE OK SYSTEM

No 2 Risk Assessment The STEP Change Fatality report identified that: “The credibility and use of risk assessment is not at the required level. The character of risk assessment must be challenged – in particular the written form. The starting point must be the question - What is usable, meaningful and useful to the workforce? Risk assessment should be live, should stimulate thinking, be an integral part of planning and should be useful and useable i.e. well laid out - rather than driven by regulatory concern.”

The recently published STEP Change ‘Personal Responsibility for Safety Guidance” notes at section four that an organisation should “Provide relevant risk assessment and observation skills training skills for all personnel”

Previous KP2 inspections and incident investigations point to poor hazard awareness. Note also that it is during routine tasks the greater number of incidents are occurring.

By interview and inspection onshore and offshore establish to what degree and effectiveness is the duty holder addressing hazard awareness and risk assessment.

Evidence required for the following question: • Has any effort been made to ensure that the risk assessments and procedures covering routine tasks have been re-reviewed and are fit for purpose? N.B. It was a recommendation of the STEP Change Fatality report that routine task risk assessments be reviewed.

Possible further Questions/Actions How are supervisors attempting to make workers aware of the hazards associated with lifting Who undertakes the risk assessment – do they actually go offshore and witness proximity hazards and available space – do they consult with the employees who actually undertake the lifting operation(s). Assess the quality of the processes first hand by attending tool-box talks or job specific risk assessment meetings How does management ensure that Task Risk Assessment, and the Lifting Plan or Procedures continue to be appropriate for the specific task? Are the existing precautions for routine tasks adequate or does more need to be done When undertaking risk assessments, there can be many personnel who are only involved in discrete parts of the operation, has the company considered the inclusion of these people and their activities Are the findings from asked risk assessments recorded and how are they modified, revised or updated? If generic risk assessments are used, how is it confirmed that these reflect the specific conditions on the particular installation? How are risk assessments modified, revised or updates? How are the risk assessments and knowledge from 3rd party contractors used? Are issues that are raised during crew meetings ever rejected for incorporation? Is there evidence of risks being ‘assessed out’ rather than ‘engineered out’? Do risk assessment take into account the experience and competence of the crews? Are inherently safer options considered, e.g. doing the job a different way?

Have company standards concerning the handling (or not handling) loads during a lift been explained? How is management of change handled e.g. when conditions change, when change occurs in the task?

Wherever possible inspectors should seek to assess the quality of the processes first hand by, for example, attending shift change tool-box talks or comparing written risk assessments against actual activity and thereby the adequacy and comprehensiveness of the assessment.

Main Relevant Legislation

HSWA Sec 2 & 3 MHSWA Reg. 3 PUWER Reg. 7

Inspection Notes No2 Risk Assessment Onshore Management

Offshore Management

Workforce

HSE Comments:

Action Taken:

NON COMPLIANCE / ISOLATED FAILURE / IN COMPLIANCE / NOT INSPECTED MAJOR FAILING INCOMPLETE OK SYSTEM

3 Training and Competence All persons involved in lifting and mechanical handling operations must be trained, have the required experience for the type of lift to be undertaken, and be formally assessed as competent.

The STEP Change Lifting and Mechanical Handling guidelines identify on page nine the four key stages that an individual has to pass through to reach full competency. It is important to ensure that following completion of stage 1 (initial training and assessment, normally undertaken onshore) that persons progressing on to stage 2 do not undertake lifting operations on their own. They should be considered as ‘apprentices’ and be supervised by a colleague.

The chart on page ten of the guidelines identifies the categories of personnel who undertake lifting and mechanical handling operations and sets out details of the training and competence assessment required.

Evidence required on the following question:

How is the duty holder is meeting these guidelines?

Possible Further Questions /Actions - Training

• How is on-the-job training identified and organised? • Is there a preference between on-the-job and off-the-job training? • How is training for leadership and supervision handled? • How is it ensured that persons receive the relevant training for the procedures that they are using • How is the training of green hats handled? • Check that those in a deck or drill floor crew have actually had the required training

Main Relevant Legislation

HSWA Sec 2&3 MHSWA Reg. 13 PUWER Reg. 8&9

Competence

Lifting operations must be managed effectively. • Someone must have overall responsibility for the ensuring that the lifting operation is managed in line with the bullet points listed in Template 1. • Someone must be responsible for planning the lifting operation, undertaking the risk assessment, and preparing a method statement. • Someone must supervise the lifting operation and ensure compliance with the lifting plan, risk assessment and method statement.

The STEP Change Guidelines – Lifting and Mechanical Handling - sets out on page eleven the requirements of competency for the Competent Person, as defined by the guidelines on page 3, 3.2.

Possible Questions/Actions – Competency

• What responsibilities does the lifting Competent Person have allocated? • What competencies are you looking for when appointing these Competent Persons? • Who are they? • Are they competent for non-routine lifting operations? • Review the systems which are in place to measure and record competence. • Who is accountable for maintenance of system / records? • Is the required competency and training profile for the crane operator, deck foreman and deck crew clearly set out? • Are checks on competence made for some specific non-routine lifts / tasks. If yes, what do these entail? • Is a person’s competency taken into account for promotion? • How do they assess and manage the competency of a whole team (as opposed to the individual)? • Is their any means of monitoring/auditing the use and effectiveness of the competency and training system? • Check that those in the deck and drill floor crew possess the required competencies.

Main Relevant Legislation

HSWA Sec 2&3 MHSWA Reg. 13 PUWER Reg. 8&9

Inspection Notes No3 Training and Competence Onshore Management

Offshore Management

Workforce

HSE Comments:

Action Taken:

NON COMPLIANCE / ISOLATED FAILURE / IN COMPLIANCE / NOT INSPECTED MAJOR FAILING INCOMPLETE OK SYSTEM

No 4 Planning, Selection and Control of Equipment The STEP Change Guidelines – Lifting and Mechanical Handling, sets out in section four (also outlined inside the front cover) the approach and requirements for the planning of a lifting operation.

By interview onshore, and interview and inspection offshore establish the effectiveness of the duty holder's approach to the planning, selection and control of lifting equipment.

Issues to Consider

Has job design been addressed and findings implemented? Are inherently safer options considered, e.g. doing the job a different way

Are there work instructions for the activities? Do they clearly identify each individual’s responsibilities, work activities, and identify which equipment is required for the activity

Are normal operations, possible upset conditions and work interruptions addressed?

How are the outcomes of the risk assessment fed into the lifting plan? How often are lifting plans reviewed? Is there a feedback system to inject the findings from previous lifting operations?

Do they adopt any system to identify routine lifts from non-routine lifts? Do they classify non-routine lifts (simple, complicated, complex)? With non-routine lifts how do they identify when to seek assistance? Who do they seek assistance from?

Possible questions:

• Who is the LOLER responsible person for lifting plans or rigging operations? • What competency does this responsible person have? • Who actually does lifting plans and what is their competence? • Who has the responsibility of authorising lifting plans? • How often plans are changed or modified, who approves the changes? • Does the work program identify logistics and other matters that may effect safe operation, for example insufficient deck space for lay down, weather? • Are the competencies for the various tasks defined? • How is the work carried out if not all staff is fully trained? • At what level of detail are job procedures written? Is there evidence of excess detail being required? • Is there a feedback system to inject the findings from previous lifting operations? • Does DH adopt any system to identify routine lifts from non-routine lifts? • Does DH classify non-routine lifts (simple, complicated, complex)? • Have inherently safer options been considered, e.g. doing the job a different way? • Are there work instructions for the activities? Do they clearly identify each individual’s responsibilities, work activities, and identify which equipment is required for the activity? • Are corrective actions from incidents and past lessons learnt, included in procedures?

• Is best practice circulated around other installations?

Where possible inspectors should seek to assess the quality of the processes first hand by, for example, attending toolbox talks or comparing written lifting plans against actual activity, checking their authority. Have a look at the procedure – is it clear and are responsibilities well established? Possibly work through a hypothetical example of a complex lifting operation.

Selection of lifting equipment

Inspectors could ‘invent’ a non-routine lift, say moving a 10 tonne winch from the deck to the drill floor and ask them to plan it. What equipment would they select, would they take account of the crane load rating & load radius. How would they lift / pull the winch inside the derrick – (checks rigging skills & knowledge). Do they walk the route and identify proximity / overhead hazards? When would they seek assistance?

Pre-Use Checks

Analysis of accident statistics reveals that adequate maintenance of cranes and other lifting equipment is a pre-requisite for safe lifting. Specialist contractors often provide maintenance, and inspection thereof falls under the scope of KP3. Pre-use checks are designed to identify obvious defects and to quarantine suspect equipment until examined by competent person. Advice is given in LOLER ACoP paras 285 to 293 and BS 7121-1 clause 11.2.3

Ask the crane operator to demonstrate how he undertakes the pre-use checks. What areas does he cover – confirm that the following safety devices are working:

• rated capacity indicator / limiter • upper hoist limiter • slew limiter • boom raise limiter • Enquire what pre-use checks are given to slings and lifting tackle. How are defects reported?

Control of Equipment

Planning is closely coupled with an understanding of whether the intended lifting equipment is suitable for the job in hand. Advice is given in LOLER ACoP paras 210 to 226 and section 4 of BS 7121-1. More detailed advice is given in the “General considerations” chapter of HSG 221 Technical guidance on the safe use of lifting equipment offshore

Possible questions / actions

• Enquire how defects reported on the LOLER Schedule 1 Report of Examination are remedied and progress checked. • Inspect the platform and drilling rigging lofts • Is a register of equipment in place and used? • How is access to the loft and its equipment controlled? • Are proper provisions made to segregate and store equipment that is quarantined (not to be used until re-inspected) or to be destroyed? • How are transit slings isolated?

Main Relevant legislation

HSWA Sec 2 & 3 MHSWA Reg. 3, 4, 5, 8. LOLER PUWER Reg. 4, 5,8, 9.

Inspection Notes No 4 Planning, Selection and Control of Equipment Onshore Management

Offshore Management

Workforce

HSE Comments:

Action Taken:

NON COMPLIANCE / ISOLATED FAILURE / IN COMPLIANCE / NOT INSPECETD MAJOR FAILING INCOMPLETE OK SYSTEM

No 5 Supervision By interview and inspection offshore establish the effectiveness of the duty holder’s procedures covering supervision and job monitoring

Inspectors should identify any factors inhibiting effective supervision, including time constraints and supervisor training. Note that insufficient supervisory time at the worksite was a finding of the STEP Change Fatality report.

Do supervisors, for example, feel diverted from an effective supervisory role of correcting mistakes, teaching and training, identifying hazards and taking effective remedial action by the burden of paper driven risk and competence assessments?

Planned monitoring activities should be incorporated into line managers’ job descriptions. The purpose of active monitoring is to minimise the likelihood of incidents by ensuring an effective safety management system is being applied. What training in supervision and monitoring have these individuals been given? Has it been subject to any follow up checking/auditing/monitoring?

With new crews or crew members, “green hats”, consider competence and training problems including on-site monitoring and methods of working round deficiencies.

Do supervisors: Ensure the crew are only asked to undertake work activities that they have been deemed competent to undertake.

Ensure crew fully understand work activities at the start of each shift and have clear work instructions based on current procedures for all anticipated activities including: normal operations, abnormal operations, breaks.

Ensure crew members are fully conversant with limits of their responsibilities and of the risks and consequences associated with anticipated work activities.

Monitor work activities to ensure crew are following work procedures etc.

Evidence required on the following question: • Does the company have policy with regard to supervision of “green hats” when they are involved in lifting and/or mechanical handling operations? How has the “green hat” policy been communicated and implemented and has its effectiveness been measures/monitored/audited. Check by asking representative individuals.

Possible further questions:-

• What parts of the work do they supervise, and how do they supervise? • How does the company ensure that supervisors with responsibilities for lifting and mechanical handling operations have sufficient time at the workplace? • How do they supervise these? • How much time do they spend on general oversight of the worksite (managing by walking around) • Is there a system in operation to determine when the Competent Person must supervise the lifting operation? N.B. The STEP Change Lifting and Mechanical Handling Guidelines identify that it is the Responsible Person (the

Supervisor) who identifies that a lifting operation is to take place and then informs or appoints the Competent Person to plan, and if required, supervise the operation. • Do they attend some/all shift handovers? • How do supervisors manage deficiencies in the crew numbers? • How do supervisors ensure that the necessary levels of competency are available for each task? • How do supervisors ensure that crews/individuals only undertake work activities they have deemed competent for? • If inexperienced staff are used are crew numbers increased to allow for better supervision? • Do supervisors change their supervision method if inexperienced staff is involved? (Inexperienced are those who have made fewer that 3 trips offshore in their role or have not been assessed as competent under any system in place whichever is the higher standard) N.B. Refer to LOLER Approved Code of Practise and Guidance paragraph 229 with respect to comment on ‘appropriate’ supervision. • How often do the crew think they see the supervisors? • How do they hear of improvements and lessons from other operations? • How do they implement these lessons? • Do they input lessons learned into the risk control process? • Do they ever reject recommendations from risk assessments? • Observe a crew to get a feel about the level, style, frequency and appropriateness of supervision.

MAIN RELEVANT LEGISLATION

HSWA Sec 2 & 3 LOLER Reg. 8 MHSW Reg. 5