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CR FPS 110 HSE Bridging Document for Well Operations Rev 00

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TABLE OF CONTENTS

1. RECAP OF RULES... 5

2. FOREWORD- GENERAL DEFINITIONS... 6

2.1 Indicator...6

2.2 Glossary ...6

3. GENERAL... 7

4. RESPONSIBILITIES OF MANAGEMENT (MAESTRO - HSE 02) ... 9

4.1 HSE responsibilities ...9

4.2 Organisation chart ...10

4.3 Communication system ...10

5. MEETING AND PERSONNEL MOVEMENT (MAESTRO - HSE 02)... 10

5.1 Crew change/personnel movement (POB)...10

5.2 Induction sessions...11

5.3 Hand-over between personnel on shift or rotation ...11

5.4 On-site HSE meetings...11

6. OPERATING PROCEDURES (MAESTRO - HSE 03) ... 12

6.1 Work permits ...12

6.2 Simultaneous operations procedures...12

6.3 Well control policies and procedures...13

6.4 H2S policy ...13

6.5 Shallow gas policy...14

6.6 Lifting equipment and handling procedures ...14

6.7 Other relevant operating procedures and policies...15

7. RISK EVALUATION AND MANAGEMENT (MAESTRO - HSE 04) ... 15

8. WASTE AND CHEMICAL MANAGEMENT PLAN (MAESTRO - HSE 05) ... 16

9. SAFEGUARDING OF HEALTH (MAESTRO - HSE 06) ... 16

9.1 General occupational health...16

9.2 Personnel Protective Equipment (PPE) ...17

9.3 Hazardous substance, product or material...17

9.4 Prevention of asbestos hazards ...18

9.5 Driving policy (onshore Site) ...18

10. ...COMPETENCE AND TRAINING OF PERSONNEL (MAESTRO - HSE 08) ... 18

10.1

....

Well control certification...18

10.2

....

HSE training plan...19

11. ...SITE DRILL POLICY AND EMERGENCY PLANS (MAESTRO - HSE 09)... 20

12. ...INCIDENT ANALYSIS (MAESTRO - HSE 10) ... 21

12.1

....

Accident, incident and unsafe situation reporting system ...21

12.2

....

Analysis of reported incident and on site diffusion of information ...21

13. ...MAINTENANCE, INSPECTIONS AND AUDITS ON SITE (MAESTRO - HSE 11)22

APPENDIX 1 CHECK LIST... 23

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Reference documents

Unless otherwise stipulated, the applicable version of the reference documents listed below, including relevant appendices and supplements, is the latest revision published.

Standards Reference Title Professional Documents Reference Title Not applicable Regulations Reference Title Not applicable Codes Reference Title Not applicable Other documents Reference Title NSL 2002 North Sea Lifting International Rigging & Lifting Handbook

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Other Total documents Reference Title HSE Charter EP01 Directive CR HSE 001 CR HSE 102 CR HSE 023 CR HSE 035 CR HSE 061 CR HSE 062 CR HSE 063 CR HSE 081 CR HSE 101 CR HSE 103 CR LOG 100 CR FPS 510 CR FPP 120 CR FPP 130 CR FPP 132 CR FPP 135 CR FPP 140 CR FPP 160 CR FPP 165 CR FPP 170 CR FPP 215 CR FPP 230 CR FPP 255 CR FPP 265 CR FPP 710

Exploration & Production Health, Safety & Environmental Organisation Charter

Exploration & Production Health, Safety & Environment Policy Rules for Implementation of the DGEP HSE Policy "MAESTRO" Incidents, Anomalies and Illnesses Recording and Reporting – Definitions

HSE communication and information

Responsable Sécurité et Environement de site ( RSES ) Vehicle and driving

Personnel protective equipment Prevention of asbestos hazards HSE training for E&P personnel Investigation of major accidents Board of enquiry

Standard for air transport operations

HSE training for well operation personnel ( to be published ) Classification of Well Operations

Well barriers for drilling and workover operations Barriers for well servicing operations

Barriers on completed wells SIMOPS

Well Control Equipment

Pressure and functions tests of well control equipment H2S policy

Shallow gas policy Well shut in

Non aqueous based mud Well pressure integrity

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1. RECAP OF RULES

Rule 1:

Before starting work on any Rig contract, drilling & completion Managers are responsible for introducing an HSE Bridging Document for application on each Rig Site.

The HSE Bridging Document shall be signed by the local manager of the Rig Contractor, the drilling & completion Manager and the HSE Manager. In case of SIMOPS, the operation manager or the asset manager or the exploitation manager depending on the local organisation shall also sign the HSE Bridging Document.

It must be available on the Rig Site (Company man and tool pusher offices), and Rig safety induction must include an introduction to it.

Rule 2: The relevant SE and FP Company rules which are based on the Total E&P HSE policy are to be compared with the Rig Contractor’s HSE rules. When there are differences on key points, a common rule shall be agreed and documented in the HSE Bridging Document in force on the Site.

The HSE Bridging Document shall incorporate any specific requirements relevant to the Site or platform on which the Rig Contractor is to perform the services.

Rule 3: Whenever possible, and if compatible with the Operator HSE MS, the Rig Contractor’s HSE MS will form the basis for the management of HSE related issues on the Site.

Rule 4: The HSE Bridging Document in force on the Site shall be communicated to, and applied by all Service Companies working on the Site. Deviation from the bridging document, if needed by a service company, shall be documented in writing by this Service Company and approved in writing by the Operator and the Rig Contractor.

Rule 5: Any significant change made to the HSE MS of the Operator or of the Rig Contractor shall trigger a corresponding update of the HSE Bridging Document. The HSE Bridging Document shall be reviewed at least yearly and updated as necessary.

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2. FOREWORD- GENERAL DEFINITIONS

2.1 Indicator

Rule which needs derogation

2.2 Glossary

DGEP Total E & P Branch.

HSE Health, Safety and Environment.

HSE MS Heath, Safety and Environment Management System.

JRA Job Risk Assessment.

MAESTRO Management And Expectation Standards Towards Robust Operations.

MSDS Material Safety Data Sheet. OIM Offshore Installation Manager.

Operator the Total E&P entity, Company.

OSCP Oil Spill Contingency Plan.

OSL Operational Safety Leader.

PPE Personal Protective Equipment.

Rig means drilling/work over/well servicing unit.

Rig Contractor means the contractor operating the drilling/work over/well servicing unit.

RSES Responsible for Safety and Environment on Site.

Site means the zone of activity under the responsibility of the

RSES.

Well operations means drilling/work over/well servicing operations.

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3. GENERAL

An HSE MS is part of the overall management system of an organisation, dedicated to the management of the Heath, Safety and Environment risks associated with the business of that organisation. This includes the organisational structure, responsibilities, rules, procedures, practices and resources for implementing, achieving and maintaining the organisation’s HSE policy.

The Total E&P HSE policy, as defined in DGEP Directive EP01, covers the following twelve fundamental topics:

• HSE 01 - respect of laws and regulations • HSE 02 - responsibilities of management • HSE 03 - operational responsibility

• HSE 04 - risk evaluation and management • HSE 05 - respect for the environment • HSE 06 - safeguarding of health • HSE 07 - contractors and suppliers

• HSE 08 - competence and training of personnel • HSE 09 - emergency preparedness

• HSE 10 - incident analysis • HSE 11 - audits and inspections • HSE 12 - performance improvement.

The Total E&P HSE Policy applies to all activities which are under the control of an entity that is answerable to the Total E&P branch (DGEP).

At the time of issue of this Company Rule, the Total E&P HSE policy is essentially set out in the relevant SE and FP Company rules listed on page 4 above.

During Well Operations, two main HSE MS’s co-exist on the Site: • the HSE MS of the Total E&P entity which is the Operator,

• the HSE MS of the Rig Contractor which operates the Rig with its personnel.

There may be discrepancies between the two systems and this is not desirable on the same site. The purpose of the HSE Bridging Document is therefore to resolve such discrepancies and to lay down the rules and procedures that will apply on the Site.

Services Companies working on the Site have their own HSE MS’s but their personnel work under the Operator’s and Rig Contractor’s responsibilities. They too are therefore required to adhere to the HSE rules and procedures defined in the HSE Bridging document and in force on the Site.

The HSE Bridging Document should be no longer than 10 pages, easy to use and read. The backbone of the HSE Bridging Document is described in Appendix 1.

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Rule 1:

Before starting work on any Rig contract, drilling & completion Managers are responsible for introducing an HSE Bridging Document for application on each Rig Site.

The HSE Bridging Document shall be signed by the local manager of the Rig Contractor, the drilling & completion Manager and the HSE Manager. In case of SIMOPS, the operation manager or the asset manager or the exploitation manager depending on the local organisation shall also sign the HSE Bridging Document.

It must be available on the Rig Site (Company man and tool pusher offices), and Rig safety induction must include an introduction to it.

Rule 2: The relevant SE and FP Company rules which are based on the Total E&P HSE policy are to be compared with the Rig Contractor’s HSE rules. When there are differences on key points, a common rule shall be agreed and documented in the HSE Bridging Document in force on the Site.

The HSE Bridging Document shall incorporate any specific requirements relevant to the Site or platform on which the Rig Contractor is to perform the services.

Rule 3: Whenever possible, and if compatible with the Operator HSE MS, the Rig Contractor’s HSE MS will form the basis for the management of HSE related issues on the Site.

Rule 4: The HSE Bridging Document in force on the Site shall be communicated to, and applied by all Service Companies working on the Site. Deviation from the bridging document, if needed by a service company, shall be documented in writing by this Service Company and approved in writing by the Operator and the Rig Contractor.

Rule 5: Any significant change made to the HSE MS of the Operator or of the Rig Contractor shall trigger a corresponding update of the HSE Bridging Document. The HSE Bridging Document shall be reviewed at least yearly and updated as necessary.

The aim of this Company rule CR FPS 110 is to provide a checklist (structured in keeping with the MAESTRO document) identifying the points that are to be reviewed in the two different HSE MS’s in order to resolve the discrepancies. This CR also offers a number of reminders/clarifications to help in the preparation of the HSE Bridging Document.

The checklist will need to be adjusted and/or completed to factor in the specific local conditions (Rig, location, contracts, regulations, etc.) and the evolution of the HSE MS’s.

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4. RESPONSIBILITIES OF MANAGEMENT (MAESTRO - HSE 02)

4.1 HSE responsibilities

Reminder:

The HSE responsibilities on the Site are defined in the frame drilling contract in the following articles:

• Sub-article 1.2.5: definition of “COMPANY REPRESENTATIVE”, • Sub-article 1.2.8: definition of “CONTRACTOR REPRESENTATIVE”, • Sub-article 3.3: Safety,

• Sub-article 3.7: CONTRACTOR’s PERSONNEL, • Sub-article 5.2: Liabilities between the Parties.

The Operator’s representative on the Site, usually the Company Man, is the RSES or a delegated RSES for the Site:

• He is the Operator authority on the Site for the Operator’s personnel and the Operator’s assets, especially the wells (the well which is currently being drilled and the other wells on the Site), the platform, etc.

• He has the authority to take whatever steps he may consider necessary to safeguard the well orOperator’s assets in case of emergency on the well.

• As RSES, he is, jointly with the Rig Contractor’s representative on the Site, responsible for application by all personnel on the Site of the HSE rules and procedures as per the bridging document. The role of the RSES is defined in Company rule CR HSE 035: “RSES”.

• He is consulted by the Rig Contractor’s representative on the Site if evacuation is necessary.

He liaises directly with the Operator emergency organisation in the event of emergency on the Site.

The Rig Contractor’s representative on the Site, usually the Tool Pusher or the rig Manager or the OIM:

• He is the Rig Contractor authority on the Site for the Rig Contractor’s personnel, the unit and the Rig Contractor’s equipment.

• He is, jointly with the RSES, responsible for application by all personnel on the Site of the HSE rules and procedures as per the bridging document.

• He has the authority to take whatever steps he may consider necessary to safeguard life in the event of emergency on the Site. He decides, after consultation with the Operator’s representative, on evacuation if necessary.

The Service Company representative on the Site:

• He is the Service Company authority on the Site for the Services Company’s personnel and equipment.

• He ensures that the personnel of the Service Company apply the HSE rules and procedures as per the bridging document on the Site.

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Action:

The HSE Bridging Document should state that RSES and Rig Contractor’s representative on the Site are co-responsible for its application.

The HSE responsibilities and accountabilities, for normal and emergency operations, of key Rig Site and office personnel for Operator and Rig Contractor (including deputies) should be defined in their job descriptions.

These job descriptions should be attached to the HSE Bridging Document.

4.2 Organisation chart

Organisation charts of all the parties involved in the Well Operations and in the event of emergency, (usually the drilling department, logistics, medical organisation, the Rig Contractor and the other Service Companies) in the offices and on the Rig Site should be included or referenced in the HSE Bridging Document. The communication channels to be used (when communicating, when giving orders or instructions) between the different organisations should be clearly identified and indicated in the HSE Bridging Document.

4.3 Communication system

All the communication networks (routine and emergency) between the Rig Site, Operator field installations and the offices of all the parties involved (Operator, Rig Contractor and Service Companies) should be described in the HSE Bridging Document.

The procedures to regularly assess the effectiveness and the reactivity of the identified communication networks should be defined or referenced in the HSE Bridging Document.

5. MEETING AND PERSONNEL MOVEMENT (MAESTRO - HSE 02)

5.1 Crew change/personnel movement (POB)

The Personnel On Board (POB)/Site headcount policy, which means the procedure for: • counting the people present on the Site

• updating the Site headcount

• communicating the updated list to the Operator (on site and to the office) • checking people present in the event of emergency or evacuation procedures,

should be defined or referenced in the HSE Bridging Document. As a normal rule, the POB/ Site headcount policy specified in the Rig Contractor’s HSE MS should be used on the Site but in case of SIMOPS, a special procedure should be implemented to factor in the complexity of the Site and the numerous companies present on it.

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5.2 Induction sessions

Reminder:

Rig safety induction should be provided to all personnel, including accompanied and unaccompanied visitors to the Rig Site.

Company Rule CR “HSE 023: HSE communication and information” defines the minimum requirements for induction sessions.

GM-FP-SAF-01 “Rig Site safety induction” helps in the preparation of Rig Site safety induction.

Action:

Indicate the reference of all the induction supports (video, booklets, layout, etc…) for visitors and for personnel working on the Rig.

Indicate the authorities in charge of the induction sessions.

Indicate the additional information (beyond that in the support material) given during the induction session.

Append an example of the documentation (available in the host country language and in English and/or French) to be given to a newcomer with the logos of each Operator and Rig Contractor.

5.3 Hand-over between personnel on shift or rotation

Reminder:

Each company working on the Rig Site should have a hand-over procedure to ensure that the hand-overs between its own personnel crews on shift or rotation are strictly controlled and documented.

Action:

The hand-over procedures should be defined or referenced in the HSE Bridging Document.

5.4 On-site HSE meetings

Reminder:

Each Site should have an "On Site HSE meetings" policy. The meetings to be organised on the Site should include, but are not limited to:

• tour meeting • tool box meeting, • pre-job meeting • pre-spud meeting • daily safety meeting, • weekly safety meeting,

• monthly Rig Site HSE committee meeting, • etc.

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Action:

The HSE Bridging Document for the Site should include: • the agreed list of meetings

• the standard agenda of each meeting

• the attendance list for each meeting (for Rig Site personnel but also for base personnel of Operator, Rig Contractor and Service Companies),

• the frequency of each meeting

6. OPERATING PROCEDURES (MAESTRO - HSE 03)

The operating procedures defined in the two main HSE MS’s should be reviewed to identify any discrepancies. They include, but are not limited, to the operating procedures listed below.

6.1 Work permits

Both the Rig Contractor and the Operator have a “work permit system”. A work permit system and a procedure identifying the works to be performed under a work permit should be selected and referenced in the HSE Bridging Document.

The normal and preferred solution is to work with only one Work Permit system.

However, if the complexity of the operations or the installations, or the size of the Site render it absolutely necessary, two different work permit systems may be selected. In this case, the areas of operation to which each work permit system applies should be clearly specified. For example, the Rig Contractor work permit system may be selected for the drilling area (essentially the Rig and the well it is working on) and the Operator work permit system for the production area (i. e. the well platform and the other wells).

Whenever 2 work permit systems are used, the HSE Bridging Document should define how the interface between the 2 systems is managed.

6.2 Simultaneous operations procedures

Reminder:

The CR FPP 140: SIMOPS represents Total E&P policy, and should form the basis of the procedures established by the Total E&P entities for conducting Simultaneous activities. It outlines general safety rules for conducting Rig activities simultaneously with any Production activities and/or well servicing activities.

Its aim is to decrease the level of risk associated with these operations by: • limiting the number of simultaneous activities,

• defining general preventive measures to be implemented before starting simultaneous activities,

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Action:

The Operator’s simultaneous operations procedures should be referenced in the HSE Bridging Document.

The simultaneous operations matrix should be included in the HSE Bridging Document.

6.3 Well control policies and procedures

Reminder:

Company rule CR FPP 160: “well control equipment” sets out the main Total E&P requirements for selection, inspection and maintenance of Well Control Equipment during drilling, testing and work-over operations with a drilling unit.

Well Control Equipment includes the BOP stack, high pressure riser, BOP control system, wellhead connector, drill string safety valves, the kill and choke lines, kill and choke manifold, mud gas separator and all associated connections, valves, fittings and piping.

Diverting systems are not covered in CR FPP 160 but in CR FPP 215: shallow gas.

Company rule CR FPP 165: “Pressure and function tests of well control equipment” defines the rating and frequency of pressure and function tests to be performed on well control equipment used in drilling, testing, well completion and work-over operations.

Company rule CR FPP 230: “well shut-in” defines the method in force in each Total E&P entity for shutting in a well when an influx occurs during drilling or completion operations. Action:

The well control policies and procedures including rating, configuration of the BOP, sizing of well control equipment, BOP testing program, well control drill policy and well shut-in method should be reviewed and agreed with the Rig Contractor.

The agreed policies and procedures should be defined or referenced in the HSE Bridging Document.

6.4 H

2

S policy

Reminder:

The purpose of Company rule CR FPP 170: “H2S policy” is to ensure that all personnel involved in operations on wells which may contain hydrogen sulphide (H2S) have an understanding of this gas and its effects. This CR sets out general guidelines and rules for making operations on such wells safe and successful.

Action:

Where relevant, the Operator’s H2S policy should be reviewed and agreed with the Rig Contractor and defined or referenced in the HSE Bridging Document.

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6.5 Shallow gas policy

Reminder:

Company rule CR FPP 215: “shallow gas” highlights the risks associated with Shallow Gas. It details the operating procedures which should be used in each Total E&P entity when Shallow Gas may be present and provides guidance on equipment selection to ensure safe top hole drilling

Action:

Where relevant, the Operator’s shallow gas policy should be reviewed and agreed with the Rig Contractor and defined or referenced in the HSE Bridging Document.

6.6 Lifting equipment and handling procedures

Reminder:

The NSL International Rigging & Lifting Handbook is one of the referenced standards in the future Company Rule “Handling and Lifting” and is recommended as one of the best when no other standard exists in the Operator’s organisation.

The Rig Contractor should have its own standard for lifting and handling procedures in his HSE MS.

Action:

Whenever possible, and if compatible with the lifting equipment and handling procedures of the Operator and the other Service Companies, priority will be given to the lifting equipment and handling procedures specified in the Rig Contractor’s HSE MS .

The specific procedures for the following, non-exhaustive list of points should be checked: • use of man riding (dedicated man riding winch, Work Permit…)

• use of man riding basket, • use of fork lift,

• use of cranes,

• use of tag lines on loads, • handling of tubulars, • handling of drums, • handling of pallets, • handling of wooden boxes, • handling of loose equipment

• bulk transfer (bleed off procedure, health aspect…) • liquid transfer (environment aspect…)

• HP line securing

• periodic inspection and certification of lifting or handling devices. Identification system (colour coding and tagging)

• etc.

The agreed common lifting equipment and handling procedures to be applied on the Rig Site should be referenced, and any amendments should be clearly explained in the HSE Bridging Document.

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6.7 Other relevant operating procedures and policies

Other operating procedures should be reviewed as appropriate, and the agreed rules or procedures should be referenced in the HSE Bridging Document. For example:

• use of Non Aqueous Based Mud, • use of explosives

• use of radioactive sources • NORM control procedure, • well testing procedure, • moving procedures,

• DP vessel: station-keeping and disconnection procedure, • etc.

7. RISK EVALUATION AND MANAGEMENT (MAESTRO - HSE 04)

Reminder:

A) Basic hazards are already identified for any drilling operation (blow out, oil spill, fire, etc…) B) There are other hazards related to the Rig (dual handling system, DP / anchor mode,

automatic equipment…). C) Other hazards are specific to:

y

the drilling area / location (tropical storms, ice, iceberg...)

y

the interface between the Rig and the Operator assets (pipeline, platform…)

y

the local context (community…)

y

the well (HP/HT, shallow gas, transition zones…)

D) A number of other hazards are related to day-to-day jobs that may cause personal injury and/or risks that may result in asset losses (running casing, testing the BOP, working at height, tubular handling, etc…)

Consequently:

y

the above hazards should be identified and risk assessed before the start of operations by the Operator and/or the Rig Contractor with their own system (refer to the HSE requirements in the standard drilling contract, appendix 4- PART 5 and to the safety manual GM-SAF-006: “HAZARD IDENTIFICATION (HAZID) STUDY”).

y

emergency plans should be prepared for specific and main hazards,

y

for day-to-day jobs not yet evaluated, a job risk assessment method should be operational on the Site. This JRA method should:

- identify all potential causes of personal injury and/or risks that may result in asset losses

- determine suitable and sufficient risk control measures

- and develop an action plan to implement the control measures in order to reduce the residual risk.

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Action:

The following information should be referenced in the HSE Bridging Document:

y

all the risk identifications and risk control measures in force on the Site

y

all relevant emergency plans in force on the Site

y

all the risk assessments and the job risk analysis method in force on the Site.

It will usually be the Rig Contractor’s Job Risk Assessment method that is adopted for application on the Site.

8. WASTE AND CHEMICAL MANAGEMENT PLAN (MAESTRO - HSE 05)

Reminder:

All waste resulting from the Rig’s activities should be covered by a Waste Management Plan (WMP). This defines the systems that ensure that all hazardous waste is properly segregated, processed and disposed of such as to minimise any environmental impact.

Action:

Whenever possible, and if compatible with the Operator’s WMP, priority will be given to the WMP specified in the Rig Contractor’s HSE MS.

The WMP in force on the Site should be referenced, and any amendments should be clearly explained in the HSE Bridging Document.

9. SAFEGUARDING OF HEALTH (MAESTRO - HSE 06)

9.1 General occupational health

Reminder:

It is the responsibility of the RSES and the Rig Contractor authority to ensure that: • occupational health hazards relating to the drilling activities have been identified • relevant medical audits are organised on the Site

appropriate medical resources are provided on Site

• a system of regular medical check-ups is established, with criteria for medical fitness, dependent on age, job and working environment .

Action:

Whenever possible and compatible with the occupational health policy of the Operator, priority will be given to the occupational health policy specified in the Rig Contractor’s HSE MS.

The agreed common occupational health policy in force on the Site should be referenced and any amendments should be clearly explained in the HSE Bridging Document.

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9.2 Personnel Protective Equipment (PPE)

Reminder:

Each company working on the Site should have a PPE policy.

The PPE policy of each Total E&P entity is based on Company rule CR HSE 062 “personnel protective equipment”.

Action:

Whenever possible and compatible with the PPE policy of the Operator and the Service Companies, priority will be given to the PPE policy specified in the Rig Contractor’s HSE MS.

The agreed common PPE policy in force on the Site must be referenced and any amendments clearly explained in the HSE Bridging Document.

9.3 Hazardous substance, product or material

Reminder:

Procedures should be in place to ensure that every substance, product or material considered as hazardous under local regulations or international standards is clearly identified and quantified, and that storage and handling requirements are clearly described. For each hazardous product, a material safety data sheet (MSDS) should be available on Site to all personnel.

The products in the non-exhaustive list below should be covered by a use, storage and handling procedure: • mud products, • explosives, • radioactive sources, • paints, • diesel,

• oil base fluid, if applicable, • etc.

Action:

Whenever possible, and if compatible with the Operator’s storage and handling of hazardous substances, products or materials policy, priority will be given to the storage and handling of hazardous substance, product or material policy of the:

• Rig Contractor for diesel, paints…

• mud services company for mud products, oil base fluid…

• specifically, the service companies involved (i.e. for explosives and radioactive sources)…

The agreed common policy(ies) for storage and handling of hazardous substances, products or materials in force on the Site should be referenced, and any amendments clearly

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9.4 Prevention of asbestos hazards

Reminder:

The HSE Company Rule CR HSE 063 “Prevention of asbestos hazards” defines the prevention principles and the rules to be applied in any situation or operation during which materials containing asbestos are present.

The issue will have been reviewed and checked during the call for tender process and laid down in the drilling contract. In addition to this, an inventory and statement of asbestos hazards and related action plan will have been drawn up after the inspection of the drilling unit at the acceptance step before the spudding date.

The personnel exposed to the risk of inhaling asbestos should be informed of the dangers of such exposure, trained in how to use protective equipment and provided with appropriate medical surveillance.

Actions:

Check if the Rig Contractor has a policy regarding the prevention of asbestos hazards: • If they have one, check whether their policy is compatible with the Operator’s policy • If not, use the Operator’s policy or the one defined in CR HSE 063.

The agreed common asbestos policy in force on the Site should be referenced, and any amendments clearly explained, in the HSE Bridging Document.

9.5 Driving policy (onshore Site)

Reminder:

Each company working on the Site (Operator, Rig Contractor, service companies) should have a driving policy.

The driving policy of each Total E&Pentity is based on Company rule CR HSE 061 “vehicles and driving”.

Action:

The agreed common driving policy in force on the Site should be referenced, and any amendments clearly explained, in the HSE Bridging Document.

10. COMPETENCE AND TRAINING OF PERSONNEL (MAESTRO -

HSE 08)

10.1 Well control certification

Reminder:

The Company rule CR FPS 510 “HSE training for well operation personnel” defined the requirement for well control certification for Operator, Rig Contractor and services company personnel.

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Actions:

These requirements should be checked for compatibility with the well control certification policy of Rig Contractor and service companies.

The agreed well control certification policy applicable to the Site should be defined or referenced in the HSE Bridging Document.

10.2 HSE training plan

Reminder:

The Company rule CR FPS 510, “HSE training for well operation personnel”, defines the minimum HSE training requirements for Operator personnel, in particular, for RSES, drilling supervisor, junior drilling supervisor, etc.

It also defines a number of HSE training requirements for Rig Contractor and service company personnel.

The Rig Contractor’s HSE MS should identify and require specific training with valid certificates for the following jobs:

• tool pusher • barge master • mechanic • electrician

• driller, assistant driller • derrick man

• crane operator • medic

• fire team leader • fire team member

• Helicopter Landing Officer (HLO) • man riding winch operators • fork lift driver, etc.

Action:

The HSE Bridging Document should state that each company will adhere to its own training plan.

However, the training plan of the Rig Contractor and services companies should be checked for compatibility with CR FPS 510 “HSE training for well operation personnel” and, if necessary, additional training for the Rig Contractor and service company personnel must be specified in the HSE Bridging Document.

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11. SITE DRILL POLICY AND EMERGENCY PLANS (MAESTRO -

HSE 09)

Reminder:

For each of the identified critical situations, specific emergency procedures or plans are established, regularly updated, and communicated to all relevant personnel.

For some critical situations, notably uncontrolled blow-out or accidental pollution, the respective emergency plans are complemented by specific contingency procedures, which define the organisation, means and methods required to control and mitigate the situation. The efficiency of each of the emergency procedures or plans is systematically tested and improved through periodic Drills. For example:

• Evacuation Drills • Fire Drills

• Man overboard Drills • Medevac Drills • Kick Drills • Oil spill Drills • Blow out Drills Action:

Whenever possible and compatible with the Operator’s drills policy, priority will be given to the policy specified in the Rig Contractor’s HSE MS for standard drills.

The agreed common standard drills policy in force on the Site should be referenced and any amendments clearly explained in the HSE Bridging Document.

The HSE Bridging Document should stipulate: • the agreed list of drills to be performed on Site • the scenario of each drill

• the emergency procedure or plan for each of the critical situations. • the people involved for each drill,

• the frequency, of each drill

Whenever possible, and if compatible with the Rig Contractor’s specific emergency procedures or plans, priority will be given to the specific exercises specified in the Operator’s HSE MS for the following cases:

• Medevac

• emergency situation covered by the Emergency Response Plan • blowout covered by the Blowout Contingency Plan

• oil spill or any accidental pollution covered by the Oil Spill Contingency Plan (OSCP). For these critical situations, the plans and procedures in force on the Site should be referenced and any amendments clearly explained in the HSE Bridging Document.

If any other relevant emergency situation has been identified (SIMOPS…), the drills to be applied on the Rig Site should be described in the HSE Bridging Document.

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12. INCIDENT ANALYSIS (MAESTRO - HSE 10)

12.1 Accident, incident and unsafe situation reporting system

Reminder:

The Company rule CR HSE 102, “Incidents, Anomalies and Illnesses Recording and Reporting – Definitions”, defines the system and terminology for the reporting of occupational accidents and incidents (including Environmental Damage, Material Loss and Production Loss), worked hours and other information applicable in each Total E&P entity.

The Company rule CR HSE 121, “HSE Recording, Reporting and Feedback”, defines the system of recording, reporting and feedback of HSE information between each Total E&P entities and .the Safety and Environment Division of the Total E&P branch (DGEP/SE). A system should be set up on Site to ensure that any accident, incident or unsafe situation related to drilling and completion activities is immediately reported and analysed, and that remedial and preventive actions are defined and implemented.

Action:

Whenever possible, and if compatible with the incident reporting policy of the Operator and the other Service Companies, priority will be given to the incident reporting policy specified in the Rig Contractor’s HSE MS, amended if necessary.

The agreed common incident reporting policy in force on the Site should be referenced and any amendments clearly explained in the HSE Bridging Document.

12.2 Analysis of reported incident and on site diffusion of information

Reminder:

HSE statistics and HSE performances objectives should be posted on the Site.

A systematic analysis is made of each reported incident. The depth of the analysis will depend upon the complexity and severity of the incident. A cause tree analysis and subsequent action plan should be prepared for any incident with a real severity equal to or greater than 3 and/or a potential severity equal to or greater than 4.

For a major accident, Company rule CR HSE 101, “investigation of major accident”, apples. Company rule CR HSE 103 “Board of Enquiry” defines the system and terminology applicable for setting up and running a Board of Enquiry in the event of a fatal accident or any other incident that the local Operator management deems sufficiently severe to merit the same procedure.

Action:

The system selected for the communication of HSE statistics on the Site and for the analysis (cause tree analysis, root causes identification system or other) and subsequent action plans should be defined or referenced in the HSE Bridging Document.

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13. MAINTENANCE, INSPECTIONS AND AUDITS ON SITE

(MAESTRO - HSE 11)

Reminder:

The Rig Contractor and other Service Companies should ensure that planned inspections and maintenance are carried out. Implementation of identified corrective actions must be systematically followed up. The HSE MS of the Rig Contractor and of each of the other Services Companies defines:

• the Maintenance plan for its own equipment

• the Inspection of its own equipment and the audit plan • periodical health, medical and safety audits on Site.

The drilling and completion department and/or the Operator OSL check(s), by means of periodical HSE audits, the adequacy of the Rig Contractor and the service company’s HSE MS.

External audits such as MODUSPEC may be included in the HSE audit plan defined by the Operator.

Action:

The maintenance, inspections and audit systems in force on the Site and performed either by the Rig Contractor and all the Service Companies or by the Operator should be defined or referenced in the HSE Bridging Document.

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APPENDIX 1 CHECK LIST

NOTE: when a document is referenced in the bridging document, its main points, which should be known by all personnel working on the Site, may be summarised in the bridging document. HSE RESPONSIBILITIES

The HSE MS Bridging document should state that RSES and The Rig Contractor representative on the Site are co-responsible for its application.

The HSE responsibilities and accountabilities, for normal and emergency operations, of key Rig Site and office personnel for Operator and Rig Contractor (including deputies) should be defined in their job descriptions?

YES NO

These job descriptions should be attached to the HSE Bridging Document YES NO ORGANISATION CHART

Organisation charts of all the parties involved in the Well Operations and in the event of emergency, in the offices and on the Site are included or referenced in the HSE Bridging Document?

YES NO

If not included, indicate the references COMMUNICATION SYSTEM

Identification and description of all the communication networks? YES NO Procedures to regularly assess the effectiveness and the reactivity? YES NO Indicate the reference (s) of the procedures

CREW CHANGE/PERSONNEL MOVEMENT (POB)

Rig Contractor’s Personnel On Board (POB)/Site headcount policy in force on the Rig Site?

YES NO Indicate the reference of the Rig Contractor’s procedure

Indicate the reference of the amendments if any (in case of SIMOPS) If the Rig Contractor’s procedure is not in force on the Site, the POB procedure and relevant amendments in force on the Site should be referenced or defined

INDUCTION SESSIONS

Indicate the reference of all the induction supports (video, booklets, layout, etc…)

Indicate the authorities in charge of the induction sessions for visitors and for personnel working on Rig Site

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Indicate the additional information (beyond that in the support material) given during the induction session

Append an example of the documentation (available in the host country language and in English and/or French) to be given to a newcomer with the logos of each company ( Operator and Rig Contractor )

HAND-OVER BETWEEN PERSONNEL ON SHIFT OR ROTATION Indicate the reference of the hand-over procedures of the Operator and of the Rig Contractor for their own personnel

If the standard Operator’s and Rig Contractor’s procedures are not in force on the Site, the hand-over procedures and amendments in force on the Site should be defined

ON SITE HSE MEETINGS

The HSE Bridging Document for the Site should include: • the agreed list of meetings

• the standard agenda of each meeting

• the attendance list for each meeting (for Site personnel but also for base personnel of Operator, Rig Contractor and Services Companies),

• the frequency of each meeting WORK PERMITS

Indicate the reference of the Work Permit procedure in force on the Site Indicate the reference of the amendments if any

If there are 2 work permit systems, define how the interface between the 2 systems is managed.

List of works requiring a WP

y

(describe the tasks)

SIMULTANEOUS OPERATIONS PROCEDURES

Indicate the reference of the Operator simultaneous operations procedures

Matrix to be included in the HSE Bridging Document. WELL CONTROL POLICIES AND PROCEDURES

Indicate the configuration of the BOP (assy, K & C lines, choke manifold,..) Indicate the reference of the BOP testing program

Indicate the reference of the well control drill policy

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H2S POLICY

Operator’s H2S policy in force on the Site? YES NO

Indicate the reference of the Operator’s procedure

If the Operator’s H2S policy is not in force on the Site, the H2S policy and the amendments to it in force on the Site should be referenced or defined SHALLOW GAS POLICY

Operator Shallow gas policy in force on the Site? YES NO

Indicate the reference of the Operator’s procedure

If the Operator’s shallow gas policy is not in force on the Site, the shallow gas policy and the amendments to it in force on the Site should be

referenced or defined

LIFTING EQUIPMENT AND HANDLING PROCEDURES

Rig Contractor’s lifting equipment and handling procedures in force on the Rig Site?

YES NO Indicate the reference of the Rig Contractor’s procedure

If the Rig Contractor’s lifting equipment and handling procedures is not in force on the Site, the main lifting equipment and handling procedures and the amendments to it in force on the Site should be referenced or defined Indicate the reference of the periodic inspection and certification of lifting or handling device policy

Indicate the reference of the identification system (colour coding and tagging)

OTHER RELEVANT OPERATING PROCEDURES AND POLICIES, IF ANY Indicate the reference of the procedure for use of Non Aqueous Based Mud

Indicate the reference of the procedure for use of explosive

Indicate the reference of the procedure for use of radioactive sources Indicate the reference of the procedure for NORM control

Indicate the reference of the procedure for Well testing

Indicate the reference of the procedures for Moving operations

Indicate the reference of the procedures for DP vessel: station keeping and disconnection procedure,

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RISK EVALUATION AND MANAGEMENT

Indicate the reference of all the risk identifications and risk control measures in force on the Site

Indicate the reference of all the emergency plans in force on the Site

Rig Contractor’s job risk analysis method in force on the Site? YES NO

Indicate the reference of the Rig Contractor’s policy

If the Rig Contractor’s job risk analysis method is not in force on the Site, the job risk analysis method and any amendment to it in force on the Site should be referenced or defined

WASTE AND CHEMICAL MANAGEMENT PLAN

Rig Contractor’s WMP in force on the Site? YES NO

Indicate the reference of the Rig Contractor’s policy

If the Rig Contractor’s WMP is not in force on the Site, the WMP and any amendment to it in force on the Site should be referenced or defined GENERAL OCCUPATIONAL HEALTH

Rig Contractor’s occupational health policy in force on the Site? YES NO Indicate the reference of the Rig Contractor’s policy

If the Rig Contractor’s occupational health policy is not in force on the Site, the occupational health policy and any amendment to it in force on the Site should be referenced or defined.

PERSONNEL PROTECTIVE EQUIPMENT (PPE)

Rig Contractor’s PPE policy in force on the Site? YES NO

Indicate the reference of the Rig Contractor’s policy

If the Rig Contractor’s PPE policy is not in force on the Site, the PPE policy and any amendment to it in force on the Site should be referenced or defined

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HAZARDOUS SUBSTANCE, PRODUCT OR MATERIAL

Rig Contractor’s storage and handling policy for diesel oil, paints in force on the Site?

YES NO Indicate the reference of the Rig Contractor’s policy for diesel, paints

Mud services company’s storage and handling policy for mud products, oil base fluid, in force on the Site?

YES NO Indicate the reference of the Mud services company’s policy for mud

products, oil base fluid, …

Other services company storage and handling policy for explosives and radioactive sources in force on the Site?

YES NO Indicate the reference of the other various services company’s policies in

force on the Site

If the hazardous substance, product or material policies are not as above, the different hazardous substance, product or material policies and any amendment to it in force on the Site should be referenced or defined PREVENTION OF ASBESTOS HAZARDS

Rig Contractor’s prevention of asbestos hazards policy in force on the Site?

YES NO

Indicate the reference of the Rig Contractor’s policy

If the Rig Contractor’s prevention of asbestos hazards policy is not in force on the Site, the prevention of asbestos hazards policy and any amendment to it in force on the Site should be referenced or defined. DRIVING POLICY (ONLY ON ONSHORE SITE)

Indicate the reference of the driving policy in force on the Site WELL CONTROL CERTIFICATION

Indicate the reference of the agreed well control certification policy applicable to the Site

TRAINING PLAN

Each company will adhere to its own training plan? YES NO If not, indicate the reference of the training plan that applies

Additional HSE training plan to be compatible with CR FPS 510 requirement

y

(describe the HSE training sessions)

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SITE DRILL POLICY AND EMERGENCY PLANS

Rig Contractor’s drills policy for standard drills? YES NO

Indicate the reference of the Rig Contractor’s policy

If the Rig Contractor drills policy is not in force on the Site, the drills policy and any amendment to it in force on the Site should be referenced or defined.

Nota: The HSE Bridging Document should stipulate: • the agreed list of the drills to be performed on Site • the scenario of each drill

• the emergency procedure or plan for each of the critical situations. • the people involved for each drill,

• the frequency of each drill

Operator specific emergency procedures or plans in force on the Site? YES NO Indicate the reference of the Operator’s procedure or plans for specific

emergency situation (SIMOPS, …) or other drills

ANALYSIS OF REPORTED INCIDENT AND ON SITE DIFFUSION OF INFORMATION

Rig Contractor’s incident reporting policy? YES NO

Indicate the reference of the Rig Contractor’s incident reporting policy If the Rig Contractor incident reporting policy is not in force on the Site, the incident reporting policy and any amendment to it in force on the Site should be referenced or defined.

ANALYSIS OF REPORTED INCIDENT AND ON SITE DIFFUSION OF INFORMATION The system selected for the communication of HSE statistics on the Site

and for the analysis (cause tree analysis, root causes identification system or other) and subsequent action plans should be defined or referenced MAINTENANCE, INSPECTIONS AND AUDITS ON SITE

Reference to the maintenance, inspections and audit systems in force on the Site and performed either by the Rig Contractor and all the Service Companies and or the Operator should be defined or referenced

References

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