Key Programme 2 Deck and Drilling Operations
Auditing the Management of Offshore Lifting Operations
1.1 HSE’s Energy Division (OSD) initiated Key Programme 2 (KP2) in 2003 in response to unacceptable accident statistics from deck and drilling operations offshore. A programme review in 2005 resulted in a closer focus on the management of lifting operations within these two areas of activity, lifting operations having been seen to contribute significantly to fatalities and major injuries. This revised programme, known as KP2 Phase 2, ran from December 2005 to March 2007.
1.2 The leading management failure identified during KP2 was that of a lack of effective auditing of the management of deck and drilling lifting operations. The leading failures subsequent to this lack of auditing were: Planning & Control and Training & Competence [Please insert hyperlink to file kp2deckdrillopsfinal.htm attached ]
1.3 At the completion of KP2, OSD will be writing to all offshore dutyholders to advise them of the programme findings and directing them to review their management of lifting operations, focussing on the key areas of audit. This guide has therefore been drawn up to assist dutyholders with this, by highlighting key areas of audit.
2.1 A fundamental element of any effective safety management system is one that ensures that company procedures and standards are adhered to, and remain fit for purpose. A key part of this element is audit.
2.2 The KP2 inspection programme found that the word audit was used in many contexts and with several, sometimes conflicting, meanings. For the purpose of this guidance, the following is proposed:
Auditing is a structured inspection by a competent independent body which has the required competence and knowledge in the subject or system being inspected, and is sufficiently independent from the subject or system to allow an unbiased judgement to be made.
2.3 In the majority of KP2 inspections, inspectors found that offshore installations were expected to “self-audit” their lifting operations. While such activities are an essential part of any safety management system, they are more properly monitoring/review exercises rather than audit. The programme findings support the view that installations are “closed organisations”, such that people working on them are never sufficiently independent of the organisation or system to be able take an unbiased view or to fully challenge its processes and procedures. They may certainly monitor or review the organisation, but not audit it. As has been demonstrated by the failures identified by the programme, installations left for long periods of self-regulation run the risk of falling in to company safety requirement deviations, with non compliance's or poor practices going unchallenged, unrecognised or accepted.
2.4 When company-specific KP2 inspection results were reviewed against each other no company was found to have a single comprehensive management oversight of lifting operations. Therefore almost all companies with more than two installations presented uneven results across the topics inspected. A consistent management approach to any industrial subject across several installations can only be achieved by effective management oversight of those installations. In respect of lifting operations this was not happening. This also meant that where good management was being applied, and there were many instances of this, the dutyholder was ignorant of the fact and the company and the industry lacked the benefit of such knowledge.
2.5 The leading root causes in deck and drilling lifting remain unchanged from the original HSE and industry reviews. This is likely to remain the case until effective management oversight and action is taken via routine company audits of these operations. Such audits will also allow companies to find and spread good working practices.
3 This Guide
3.1 This guide is provided in support of HSE’s ongoing inspection work in this topic and of the reports recommendation that companies review their management of lifting operations. It is therefore intended as a basis for an industry or company approach to the auditing of this subject.
3.2 In addition there is a separate but similar document in respect of the management of portable lifting equipment and lifting accessories [Please insert hyperlink to file kp2deckdrillopsriggingloft.htm attached]
3.3 Due to differing business sizes, processes etc., it is not possible to provide detailed guidance on how this subject may be audited. However, it is possible, drawing from the lessons of KP2, to provide an audit approach to the key elements of effective lifting management.
4 Auditing of Lifting Operations Planning
4.1 The Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) Regulation 8(1)(a) - of which the guidance [Safe use of lifting equipment Lifting Operations and Lifting Equipment Regulations 1998 Approved Code of Practice and guidance HSE Books 1998 ISBN 0 7176 1628 2] to the regulations goes on to say lies at the heart of LOLER - requires that:Every employer shall ensure that every lifting operation involving lifting equipment is properly planned by a competent person.
4.2 What this regulations means is that there need not be a single individual responsible for planning, but that every lifting operation should be competently planned. For example, on a MODU, drill floor lift planning will very likely be carried out by the driller, and on the deck, by the Barge Engineer, crane operator or others. However, in all cases the person doing the planning must be competent to do so.
Can the company demonstrate:
- That all persons carrying out lift planning have adequate practical and theoretical knowledge and experience of lifting operations? (Competency requirements of Reg. 8(1)(a) ACOP [Safe use of lifting equipment Lifting Operations and Lifting Equipment Regulations 1998 Approved Code of Practice and guidance HSE Books 1998 ISBN 0 7176 1628 2] and STEP Change “Lifting and Mechanical Handling Guidelines”).
- That there is a process or system in place by which this competency is routinely validated?
4.3 The approved code of practice (ACOP) for LOLER Reg. 8(1)(a) requires that:
The plan will need to address the risks identified by the risk assessment and identify the resources required, the procedures and the responsibilities so that any lifting operation is carried out safely.
The plan should ensure that the lifting equipment remains safe for the range of lifting operations for which the equipment might be used.
Where two or more items of lifting equipment are used simultaneously to lift a load, where appropriate a written plan should be drawn up and applied to ensure safety.
Given this, there are therefore several ways in which a dutyholder may approach planning. For example: generic plans; specific plans; plans drawn up on location ahead of an operation; generic or specific plans that are revisited at each operation, etc.
Whatever the dutyholder’s approach to planning, a minimum test would be whether the company can demonstrate:
- That its lifting plans comply with the requirements of LOLER Reg. 8(1)(a) and its ACOP?
- That where necessary, these plans are routinely reviewed?
- There are routine independent assessments of lifting plans?
4.4 To assist in planning, many companies have categorised lift operations e.g. routine, non routine, complex, simple, etc. Irrespective of any categorisation the key issue is still one of planning competence.
Does the person carrying out lifting planning know the limits of their knowledge/ experience/ competency/ responsibilities and where to seek help when these are reached?
4.5 As required by the LOLER ACOP, lifting plans need to identify resources required, this means people in the lifting team as well as equipment - and thereby the competencies, knowledge and skills they require. (Reference the STEP Change Guidelines “Lifting and Mechanical Handling).
Can the company demonstrate:
- That the lift planning process enables identification of the necessary competencies for the task?
- That all persons involved in lifting operations have the necessary knowledge skills and experience as identified by the lift planning process?
- Where lifting related training is in progress that it is a properly managed process where such training is delivered fully and in a timely manner?
5 Auditing of Risk Assessment
5.1 Risk assessment of lifting operations is required by regulation 3(1) of the Management of Health and Safety at Work Regulations 1999 (MHSW).
Can the company demonstrate:
- That the risk assessments carried out for lifting operations comply with the requirements of MHSW Regulation 3(1)?
- That there are routine independent checks that the company’s risk assessment requirements are being complied with?
- That where non-compliance's are identified, a manager has responsibility to ensure these are corrected in a timely manner?
- That there is a routine independent assessment that the companies risk assessment requirements remain fit for purpose and, where these are deemed not so, that there is a management structure in place to ensure improvements are identified and implemented in a timely manner?
5.2 When a lifting operation, for whatever reason, deviates or changes from the agreed plan, the task should be revisited. Many injuries, and some fatalities, have resulted from a failure to do so. The offshore industry continues to work hard to have a working culture where anyone may “stop-the-job” where they suspect that safety is, or may be, compromised. Even where this culture is embedded, its effectiveness is still dependant on individual hazard awareness, work experiences and task knowledge.
The auditor’s challenge is not only to ensure that plans and risk assessment will be revisited should they change but also to gauge the likely effectiveness of this and any interventions with regard to such influences as competencies and work experience within the task group.
6 Auditing of Supervision
6.1 LOLER Reg. 8(1)(b) requires that: Every employer shall ensure that every lifting operation involving lifting equipment is appropriately supervised. Part of any lifting operation supervision includes the important element of communications.
This is a difficult topic to audit in the field given that an inspector’s presence is likely to influence working practices. However, all companies need to have a process that ensures that they have adequate, competent supervisors and that supervision of lifting operations is appropriate. It is this system that the auditor should inspect for evidence of its use and effectiveness.
For example, one company requires supervisors to make a check report on their worksite visits, another employs cross team checks. Whatever approach is taken the auditors role is to ensure it is implemented as required and professionally challenged in its ability to meet its objectives.
7 Auditing of LOLER and the Drill Floor
7.1 LOLER is applicable to lifting operations irrespective of where they are taking place on an installation. The KP2 inspection programme has provided evidence to show that there is still a disparity in the application of these regulations where drilling occurs, a fact acknowledged by several drilling contractors. The LOLER regulations have been in force since December 1998 and therefore there can now be no reasonable excuse for their lack of application throughout an offshore installation.
The approach to auditing the drill floor in respect of the management of lifting operations is no different from any other part of an installation, save for the relevant standards and practices. LOLER provides the comprehensive legal framework for regulating safety during all offshore lifting operations, and company audit procedures should include activities to monitor compliance against its detailed provisions, irrespective of the location of the operations.
8.1 Although the offshore industry has made progress in reducing the number of manriding operations, the KP2 inspection programme results show that known industry good practices are not always followed (Step Change in Safety “Best Practices guide to manriding safety”) and the need to manride is not always challenged.
Can the company demonstrate:
- That, where reasonably practicable, all manriding operations have been identified and replaced with a safer system of work?
- That where manriding operations remain, these are conducted as a safe system of work employing industry best practices?
- That the company carries out routine audits to ensure that the two conditions above are being met?
9 Logistics and Deck Management
9.1 Inefficient logistics can, and often do, lead to poor deck management where worksites become restricted and unnecessary lifts are made. This is most often seen on MODUs.
When poor deck management is encountered the inspector/auditor should ensure they identify the root cause(s) as the rectification of such may well be in the hands of a party other than the installation owner or operator.
10 Learning from Incidents and Near Misses
10.1 The KP2 inspection programme discovered a variety of failures in this topic such that the following suggested audit approach is recommended.
Can the company demonstrate that:
- Each lifting related incident is effectively recorded and competently investigated?
- All root causes are identified?
- All necessary actions are identified and implemented in a timely manner?
- All relevant parties are provided with the necessary information?
- There is a single manager responsible for ensuring all of the above happens? and
- There is a process or system in place by which the management of the investigation of lifting related incidents is independently inspected on a routine basis to ensure that it is effective, compliant with company requirements and that these are fit for purpose?
11 Further Information
Any queries relating to this guidance should be addressed to:
Health and Safety Executive
Hazardous Installations Directorate
Lord Cullen House
Fax: 01225 252648