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Guidelines Part 23
Guidelines Part 23 Contents
GENERAL REQUIREMENTS
G23.4 Coordination of multiple-employer workplaces
G23.5 Safe work procedures
G23.8 Control of ignition sources
G23.9 Flare pits and flare lines
G23.10 Fire extinguishers
G23.14(5) Pressure control measures at pumping wellheads
G23.22 Driver training
G23.26 Gauging
DRILLING AND SERVICING RIGS
G23.39 Auxiliary escape
G23.43 Ventilation openings
G23.60 Rotary tongs
G23.61 23.5, and 12.3 Safeguarding at the rotary table area of drilling and service rigs
DRILL STEM TESTING, SWABBING, CEMENTING, WELL SERVICING AND STIMULATION
G23.69 Flow piping
PRODUCTION AND PLANT OPERATIONS
G23.80 Venting of trucks
Guidelines Part 23 - General requirements
G23.4 Coordination of multiple-employer workplaces
Issued August 1999
Section 118 of the Workers Compensation Act defines "multiple-employer workplace" and "prime contractor". The section also details the responsibilities of the prime contractor. Section 119 of the Workers Compensation Act outlines the duties an owner. Other obligations are placed on the "owner" by sections 23.31, 23.63 and 23.72 of the OHS Regulation.
"Owner" is defined in section 106 of the Workers Compensation Act as including:
(a) a trustee, receiver, mortgagee in possession, tenant, lessee, licensee or occupier of any lands or premises used or to be used as a workplace and
(b) a person who acts for or on behalf of an owner as an agent or delegate.
The "owner" for the purpose of part 23 is commonly termed the "operator", meaning the owner of the plant and of the license under which the operation runs. The fact that this person subcontracts the operation of the facility and has no workers at the site does not affect the status as "owner".
G23.5 Safe work procedures
Issued August 1999
Section 23.5 of the OHS Regulation states:
(1) The employer must identify the work activities or circumstances, including releases of gases, that have caused or may cause significant risk of injury or occupational disease to workers.
(2) The employer must analyze the risks arising out of the work activities or circumstances identified under subsection (1) and implement safe work procedures if the activities or circumstances create a hazard.
(3) The procedures implemented under subsection (2) must state the number of workers involved, the steps to be followed and the safety equipment required.
The measures taken by the employer under this section must be consistent with the other sections of the OHS Regulation.
Industry recommended practices
Consideration should be given under section 23.5 to recommended practices for safe work developed by recognized industry associations. These include the Industry Recommended Practices (IRPs) of the Petroleum Safety Council and the Alberta Recommended Practices (ARPs).
G23.8 Control of ignition sources
Issued August 1999
Section 23.8(1)(b) of the OHS Regulation states "If regular monitoring and hotwork permits are not in use to control ignition sources...diesel engines required to operate within the zone defined by the BC Electrical Code and the Drilling and Production Regulation as a Class 1 Division 2 or higher classification must have a positive air shutoff or other effective method for engine shut down".
"Other effective methods for engine shut down" are:
- a system for injecting inert gas into the engine's cylinders, equipped with a readily accessible remote control, or
- a suitable duct so that air for the engine is obtained at least 25 metres from a well (this allows shutting off the fuel to effectively stop the engine.)
G23.9 Flare pits and flare lines
Issued August 1999
Section 23.9(5) of the OHS Regulation states "If feasible, there must be a continuous ignition source before flow to a flare pit or stack occurs".
During drill stem testing, it is acceptable to use a tiger torch, diesel soaked bag of sawdust or a burning pail of fuel, as a continuous ignition source, prior to flowing to the flare.
G23.10 Fire extinguishers
Issued August 1999
Section 23.10(1) of the OHS Regulation states "Non-freezing fire extinguishers, other firefighting equipment and firefighting personnel must be provided as required by subsections (2), (3) and (4) and Table 23-1"
.
The firefighting equipment specified in Table 23-1 for fracturing jobs is required when hydrocarbon fracturing is done. The Petroleum Services Association of Canada guidelines for pumping high flash hazard hydrocarbons should be used.
G23.14(5) Pressure control measures at pumping wellheads
Issued January 1, 2007
Regulatory excerpt
Section 23.14(5) of the OHS Regulation states:
For a wellhead utilizing a down-hole positive displacement pump, the employer must implement measures to prevent the pump from causing pressures exceeding the pressure rating of the system.
Purpose of guideline
This guideline describes what is meant by the "measures" referenced in section 23.14(5) and outlines an example of an acceptable set of measures. The measures deal with the parts of the system that can be over-pressurized as a direct result of a down-hole positive displacement pump not being shut down when necessary, and with the associated pressure sensors.
Control measures
Appropriate control measures will ensure that a down-hole positive displacement pump does not cause pressure exceeding the design pressure of the system. They will typically include a combination of equipment, procedures and training.
The measures are to be effective. That is, they will provide at least the same level of safety and reliability as the applicable design codes for pressure safety valves if such valves were used to ensure that the design pressure was not exceeded.
An appropriate set of measures will address the following four matters:
- Keyed locks or seals to physically prevent tampering with the settings of the pressure sensor switch that is part of the well shut-in safety system and any valve that may interfere with the correct operation of the sensor.
- Procedures to ensure that locks or seals that restrict access to the pressure sensing and emergency shutdown system may only be removed with the prior permission of a supervisor.
- Procedures to ensure that access to the emergency shutdown overpressure system is only permitted for purposes of maintenance or testing of that system, while using accurate gauges to monitor pressures.
- Procedures and training to ensure the safety of field service workers and to prevent unauthorized changes to the pressure sensor and overpressure emergency shutdown system.
To be effective, the measures must be fully implemented and maintained, and workers must receive appropriate training on the control measures.
G23.22 Driver training
Issued August 1999
Section 23.22 of the OHS Regulation states:
A vehicle driver in the oil and gas industry must
(a) before operating a vehicle with a gross vehicle weight (GVW) rating greater than 5,500 kg (12,000 lbs) be certified in the Petroleum Industry Training Service (PITS), General Oilfield Driver Improvement Course (GODI) or other appropriate training, and
(b) before operating a vehicle with a GVW rating greater than 15,000 kg (33,000 lbs) be certified in the Petroleum Industry Training Service, Heavy Hauler Course or other appropriate training.
The course referred to in paragraph (b) targets oilfield bed trucks, tractor-trailer units, truck mounted cranes and gin pole trucks. These vehicles usually have their loads winched or hoisted, then chained down. This course does not extend to other vehicles over 15,000 kg, such as water haulers, oil/condensate haulers, cement/fracturing trucks (pumpers) and service rig carriers. Other appropriate training under clause (b) includes the Canadian Petroleum Products Institute (CPPI) training. This covers light oils, diesel and gasoline. For areas not covered by these courses, the GODI course referred to in clause (a) will be acceptable until an acceptable program covering each area has been developed.
G23.26 Gauging
Issued August 1999
Section 23.26 of the OHS Regulation states "A tank which contains or may contain a fluid with hydrogen sulfide as a component must have an external means of gauging its contents, or if manual gauging or sampling is required, the worker doing the gauging or sampling must use a supplied air respirator meeting the requirements of Part 8 (Personal Protective Clothing and Equipment) for use in an IDLH atmosphere, and must be visually monitored by another worker equipped with an equivalent respirator and capable of effecting a rescue of the worker doing the gauging or sampling".
Some external gauges do not provide the accuracy of manual gauging. However, when manual gauging is used, access to the top of the tank and stability of the worker may be a problem. In order to provide a safe means of gauging, an effective external gauge should be provided. If manual gauging is used, in addition to the requirements of section 23.26 the employer should either provide a stairway with a platform or a ladder safety device that provides work positioning and effective rescue capacity. Section 4.32 of the OHS Regulation states "There must be a safe way of entering and leaving each place where work is performed and a worker must not use another way, if the other way is hazardous."
Guidelines Part 23 - Drilling and servicing rigs
G23.39 Auxiliary escape
Effective August 1999
Section 23.39(1)(d) of the OHS Regulation states "Each drilling and servicing derrick must have a specially rigged and securely anchored line as an auxiliary means of escape which...is effectively anchored and able to withstand a load of 13.3 kN (3,000 lbs)..."
An anchor is effective if it will prevent the line from failing unless the load applied exceeds the anchor capacity. The employer must take measures to ensure the anchor is effective (see section 4.2). Measures to ensure the effectiveness of an anchor include:
- pull testing the anchor and documenting the test results,
- using an auger/screw anchor set to a given depth and torque, or
- using a manufactured or engineer designed anchor system.
In the case of the latter two items, standard drawings from the manufacturer or an engineer should be available.
G23.43 Ventilation openings
Issued August 1999; Revised February 11, 2004
Section 23.43(1) of the OHS Regulation states "Before commencing drill stem tests, swabbing, bailing, or displacement with gas or oil
(a) derrick enclosures must be altered to provide openings at least 1.8 m (6 ft) high and 2.4 m (8 ft) wide on opposite sides above, and on 2 sides below, the derrick floor, or
(b) adequate mechanical ventilation or monitoring must be provided."
For the purpose of this section, "displacement with gas or oil" includes underbalanced drilling when temperatures are within 10 degrees of the flash point.
Monitoring
Section 23.43(1)(b) of the OHS Regulation allows the option of "monitoring". If this option is used, safe work procedures (section 23.5) must be in place before commencing drill stem tests, swabbing, bailing, or displacement with gas or oil. The Board accepts the following procedures as complying with section 23.43(1)(b):
A. In addition to routine monitoring, instantaneous stationary detectors will normally be installed:
- at the flow nipple in the substructure for LEL detection,
- at floor level in the substructure for H2S detection, and
- at the designated entrance to the substructure for LEL and H2S detection.
All alarms are clearly audible exterior to the substructure.
B. Procedures for gas alarm response as follows:
- The employer, prime contractor or owner if there is no prime contractor, must ensure appropriate personnel are able to:
- install, inspect, maintain and operate personal protective equipment and air monitoring systems,
- provide safety orientation,
- conduct safety briefings,
- conduct emergency drills, and
- maintain rig location personnel count.
- Personal protective equipment and air monitoring systems are installed and function tested prior to doing drill stem tests, swabbing, bailing or displacement with oil or gas.
- Fire resistant clothing (coveralls, wet suits) are worn throughout the course of testing, from tool opening through initial circulation following testing, and during swabbing, bailing or displacement with oil or gas. Appropriate underclothing (for example, 100% tight weave cotton) is worn and hard hat liners are fire resistant.
- Continuous gas monitoring is in effect prior to commencing drill stem tests, swabbing, bailing or displacement with oil or gas. Alarms will activate when H2S exceeds 10 PPM and explosive gas exceeds 10% of LEL. Portable 3-way monitors, which measure oxygen, H2S and LEL, are acceptable. Alarms will be perceptible throughout the rig and clearly audible by personnel in the vicinity.
Workers will not enter or remain in areas of the rig where harmful substances exceed limits listed in the the Table of Exposure Limits for Chemical and Biological Substances (see OHS Guideline G5.48-1). In particular, sections 5.31 and 5.56 must be considered.
- Emergency procedures will be developed and followed in the event of an alarm situation (H2S gas concentration exceeds 10 ppm and LEL concentration exceeds 20%.) The following is an example of a minimum acceptable procedure:
- ALL PERSONNEL WILL DON BREATHING APPARATUS and evacuate immediately upwind to the designated safe briefing area. All personnel on location will be notified and accounted for. A head count will be completed and rescue teams dispatched as warranted.
- The site supervisor in consultation with the rig manager will determine to what extent rig power can safely be de-energized in the areas of the cellar, substructure, rig floor, derrick and doghouse.
- Trained personnel (equipped with a portable/personal three way gas detector complete with probe) will proceed to remotely de-energize and lockout electrical components for areas where prefabs are to be removed. Electrical cords or switches will not be de-energized at source; rather, main breakers and locks will be used.
- When non-essential rig power has been de-energized, trained personnel will remove prefabs in the affected areas if safe to do so.
- Trained personnel equipped with portable/personnel three-way gas detector, complete with hose and probe, will provide emergency/rescue support.
- Workers will not enter into or remain in an area containing 20% of LEL or greater except as permitted under section 5.31(d).
- Following drill stem testing, the pipe contents will be reverse circulated to flare in accordance with CAPP Drill Stem Testing Safety Guidelines (1984). Continuous monitoring will be in place until the drill string is circulated bottoms up at least twice.
- If tests indicate that the substructure or derrick enclosures have to be removed for adequate ventilation all crewmembers will wear:
- fire resistant clothing,
- pressure demand SCBA, and
- portable monitors to ensure the LEL remains below 20%.
- Workers will be trained in:
- use of air monitoring equipment and testing procedures,
- use of personal protective equipment, and
- safe removal of the substructure or derrick enclosure for adequate ventilation.
G23.60 Rotary tongs
Effective August 1999
Section 23.60 of the OHS Regulation states "Rotary tongs must have
(a) a primary safety device to prevent uncontrolled movement of the tongs, and
(b) a secondary safety device that will activate if the primary device fails."
Safety devices are normally two wire rope safety lines. Single stand rigs should use two wire rope safety lines, not less than 1/2 inch (13 mm) in diameter. Larger rigs should use two wire rope safety lines, not less than 5/8 inch (16 mm) in diameter.
G23.61 23.5, and 12.3 Safeguarding at the rotary table area of drilling and service rigs
Issued October 26, 2005
Regulatory excerpt
Section 23.61 (Rotary table) of the OHS Regulation states:
- If visibility on the rig floor is obscured, workers must not work there while the rotary table is in motion.
- Hoses, lines or chains must not be operated or handled near a rotary table while it is in motion.
- The rotary table must not be engaged until all workers are clear of the rotary table.
Section 23.5 (Safe work procedures) of the OHS Regulation outlines the employer's obligations to identify and analyze risks at operations in the oil and gas sector, and to develop appropriate safe work procedures to address hazards.
Section 12.3 (Standards) of the OHS Regulation states:
The application, design, construction and use of safeguards, including an opening in a guard and the reach distance to a hazardous part, must meet the requirements of CSA Standard Z432-94, Safeguarding of Machinery.
Purpose of guideline
The provisions of section 23.61 are straightforward. However, there are difficulties with installing physical guards in the rotary table area of drilling and service rigs under some of the guarding provisions of the CSA Standard referenced in section 12.3. This guideline provides information on other measures to consider for safeguarding in the rotary table area, pursuant to the CSA Standard and
the employer's obligation to conduct a risk analysis and adopt safe work procedures as required under section 23.5 of the OHS Regulation.
The CSA Standard and safeguards at the rotary table area
Machines, including drilling rigs, are required to comply with the safeguarding requirements of section 12.3 of the OHS Regulation. Generally, the first choice for safeguarding a hazard is a physical barrier, but it is recognized that it is not usually possible to completely guard rotary tables in that manner.
The definition of a safeguard in the OHS Regulation includes awareness barriers, warning signs and other appropriate means. In addition, the CSA Standard recognizes that physical barriers are not practicable in all situations. For example, section 4.2.2.7 of CSA Standard Z432-94 states:
It is necessary to inform and warn the users about residual hazards against which risk reduction by design and safeguarding techniques are not, or not totally, effective. The instructions and warnings shall describe the procedures and operating modes intended to overcome those hazards; indicate if a particular type of training is required; and, if it is necessary, specify personal protective equipment.
The following measures are provided as procedures and methods to overcome and safeguard against hazards in the area of the rotary table. They are in addition to the requirements of section 23.61 and other applicable provisions of the OHS Regulation. For convenience, the mandatory requirements of section 23.61 are noted at locations where related issues are addressed in the list of measures for safeguarding.
Measures for safeguarding in the rotary table area
- All drilling and service rigs will clearly establish the rotary table area as a Danger Zone, which will include as much of the area around the rotary table as is practicable, according to the style and layout of each individual rig.
- The Danger Zone will be clearly identified to personnel by signs, visible markings or other similar means in a manner that reinforces the location of the Danger Zone.
- Personnel are permitted in the Danger Zone only during non-drilling operations and only after a hazard assessment has been conducted and communicated to all personnel.
- Entry into the Danger Zone will be limited only to workers and other personnel essential to the operations.
- All personnel will be clear of the Danger Zone while the rotary table is engaged and the driller's controls are unattended. In addition, during drilling operations, personnel will not enter the elevated section of the rotary table Danger Zone (area covered by safety matting) while the table is in motion.
Also note that sections 23.61 (1) & (3) of the OHS Regulation state:
(1) If visibility on the rig floor is obscured, workers must not work there while the rotary table is in motion. (3) The rotary table must not be engaged until all workers are clear of the rotary table.
- When there are personnel within the Danger Zone, the rotary table will be restricted to a slow rate of speed and will be under the continuous direction of a designated driller positioned at the control console.
- There will be no equipment, hoses, tools, cables or other items that could potentially become entangled within the Danger Zone while the rotary table is engaged and the driller's controls are unattended. This may include steam hoses, water hoses, wash guns, air hoses and other such equipment.
Also note that section 23.61(2) of the OHS Regulation states:
Hoses, lines or chains must not be operated or handled near a rotary table while it is in motion.
- Proper procedures will be followed for the donning, wearing, removing and storing of fall protection and related equipment. Procedures will include:
- All harnesses and fall protection/arrest equipment will be donned and removed in a safe area away from the drilling floor. The Doghouse is recommended as such an area.
- All lanyards, slings, carabineers and any other fall protection/arrest equipment used for work in the derrick will be stored in the Doghouse or another safe location. This equipment will not be carried or worn around the rig when no longer required for work operations.
- No personnel may enter any designated Danger Zone while wearing a derrick harness or any additional fall protection or fall arrest equipment.
- Workers' clothing or personal protective equipment (PPE) will be maintained in good working condition and worn so that it does not increase the risk of entanglement on or around any rotating equipment. Any loose, torn, damaged or otherwise hazardous PPE is prohibited in the Danger Zone and will be replaced.
- Prior to working in the area of the rotary table, personnel will be instructed in and understand the Danger Zone hazards and safe work procedures at the particular site.
Guidelines Part 23 - Drill stem testing, swabbing, cementing, well servicing and stimulation
G23.69 Flow piping
Anchoring
Section 23.69(1) of the OHS Regulation states "Flow piping systems must be anchored during well testing or stimulation unless there is an effective quality assurance program to ensure integrity of the piping system."
Section 23.69(4) states "Flowback lines must be anchored and restrained."
Anchoring can include weights adequately installed to prevent movement of piping. Generally, there should be one weight for each pipe joint.
An alternative method of anchoring is to drill anchors near to the pipe ends with a restraining cable running the length of the piping. The cable system should be continuous and secured at both ends, and all individual pressure components should be secured. Restraining cables should not be less than 7/16 inch (11 mm) in diameter or chains of equal or greater strength.
Inspections
Section 23.69(2) states "The quality assurance program"
referred to in subsection (1) must include "routine inspections, non-destructive testing, pressure testing, identification of piping components, and piping specifications that meet the service application."
Well testing and simulation work can subject equipment to exceptional short term corrosion and erosion. The frequency of inspections required by a quality assurance program will depend on the nature of the work. However, they should be at least annual and after severe service. Severe service includes flow backs of acids, solvents, a substance with a large amount of chloride, C02, or H2S, and fracturing sand or other well debris.
Guidelines Part 23 - Production and plant operations
G23.80 Venting of trucks
Section 23.80 of the OHS Regulation states "Tank trucks or loading facilities must have a system for protecting workers from hydrogen sulfide if it is present."
The following systems may be used:
- pressurized tank trucks,
- atmospheric tanks with a suitable vapour gathering system,
- scrubber system, truck mounted or fixed, or
- an enclosed system.
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Disclaimer: The Worker and Employer Services Division issues Guidelines to help with the application and interpretation of sections of the Occupational Health and Safety Regulation and with divisions of the Workers Compensation Act that relate to health and safety. Guidelines are not intended to provide exclusive interpretations but to assist with compliance. WorkSafeBC ("Workers' Compensation Board of B.C.") does not warrant the accuracy or the completeness of the online version of the Guidelines and neither WorkSafeBC nor its board of directors, employees or agents shall be liable to any persons for any loss or damage of any nature, whether arising out of negligence or otherwise, which may be occasioned as a result of the use of the online version of the Guidelines.