Change is something most of us view with a little apprehension.
After the usual questions have flashed through our minds - what will it mean for us, how will we be involved - we usually move on to think about the next thing.
But in April 1999 an event took place that is going to change our industry.
The previous year the Government revised the Provision and Use of Work Equipment Regulations 1998 (PUWER'98).The regulations, first published in 1992, cover the use of engineering lathes, mills and other machine tools.
The 'other machine tools'include drilling rigs and their rotating drill string, but everybody in the industry quietly ignored this point.Nobody was talking about it, nobody was doing anything about it, no one wanted to be the first to rock the boat.
That was the view we all had until April 1999, when the Health & Safety Executive drew the regulations to our attention.Meetings were held in quick succession around the country, as the British Drilling Association (BDA) and the HSE explained the correct meaning of the rules in PUWER'98.
Attendance was staggering.Hotel conference rooms were full.Why did we attend? To see how we would be affected, to find out what changes would have to be done to the rigs? Could we quash the matter? Could somebody's life be saved? Whatever our noble cause, we were there.In the wake of these meetings a BDA guidance committee was formed, which involved a good cross section of the industry.
HSE representatives explained how the law worked.The case histories they cited were terrifying.One involved a car manufacturer and a factory worker.The employee had disabled the safety devices on the press he worked on.Later, he had an accident in the press and lost his arm.The car manufacturer was prosecuted.
This and other case histories caused a few present to feel that if an accident took place, rig owners were going to be prosecuted no matter what safety devices or actions they put in place.Then we learned that the car manufacturer had not checked the operation of the safety equipment which they had installed on that press for a long time - that is why they were liable.
Things were starting to make sense.
The BDA and the Federation of Piling Specialists (FPS) chaired parallel meetings and information was passed between the two working parties.HSE representatives were present at several of the meetings, and gave encouragement and correction where necessary.However, as the HSE was viewed with extreme caution by other participants, the meetings were a little less adversarial when they were not present.
As things progressed it became clear that a hierarchical structure of safety devices was needed, starting at the top with fixed guarding, then removable or opening guarding, safety stop trip wires, safety fences, safety training and so on.The owner, manager, operator, or whoever was responsible for safety would record why a level of safety equipment could not be used on a rig, and what safety measures had been used instead.A record of this should be available for inspection at the rig at any time.The documentation had to be up to date and, of course, accurate.
A rig may be equipped with several safety devices, but in certain working conditions a device may increase the risks to the operator.For example, fixed guarding may block an escape route when the rig is working close to a wall.In this instance the relevant documentation has to be amended for those conditions.Once the rig is working back in the open, the guards have to be refitted, and the documentation re-amended.It can all be worked out before drilling starts.If a drawing of the hole patterns has been supplied, it can be stated which safety equipment will be in place for which holes.
As long as the instructions are followed by the owner, manager, or operator, the HSE will have no problems when an inspection is made.But if safety equipment is not fitted, or not working, and is deemed to be needed by the HSE inspector, a prohibition order will be issued and the rig will be forced to stop working.
These regulations are already in effect.Have your rigs been modified to comply? If not, there is an important document that you need to read.It is Guidance notes for the protection of persons from rotating parts and ejected or falling material involved in the drilling process, published by the BDA.With this information you can formulate a system of safety that will protect you from overstepping the law and the operators from danger.There are many types of rig, so it is not possible to dictate the exact specification for each one.
The guidance translates the complex BS EN standards into something we can relate to.
We all hate change to greater or lesser extent.This new practice for safety will stop the worst type of change: damage to a person or even death.We will probably never know when or who was saved by following these safety notes.So why implement them? To protect your own.Now that is a noble cause.