rig hse case guideline (modu)...this guideline is structured in accordance with the iadc hse case...

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Wells HSE Rig HSE Case Guideline (MODU) WELLS/WHSE/MNL/RIG HSE GUIDELINE/2015/ Rev. 1 March 2015 © 2015 PETROLIAM NASIONAL BERHAD (PETRONAS) All rights reserved. No part of this document may be reproduced, stored in a retrieval system or transmitted in any form or by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright owner. PETRONAS makes no representation or warranty, whether expressed or implied, as to the accuracy or completeness of the facts presented. PETRONAS disclaims responsibility from any liability arising out of reliance on the contents of this presentation.

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Page 1: Rig HSE Case Guideline (MODU)...This Guideline is structured in accordance with the IADC HSE Case Guideline for MODU (Jan 2015) in that further guidance and required PETRONAS CARIGALI

Wells HSE

Rig HSE Case Guideline (MODU)

WELLS/WHSE/MNL/RIG HSE GUIDELINE/2015/ Rev. 1

March 2015

© 2015 PETROLIAM NASIONAL BERHAD (PETRONAS)

All rights reserved. No part of this document may be reproduced,

stored in a retrieval system or transmitted in any form or by any means (electronic, mechanical, photocopying, recording or

otherwise) without the permission of the copyright owner.

PETRONAS makes no representation or warranty, whether

expressed or implied, as to the accuracy or completeness of the

facts presented. PETRONAS disclaims responsibility from any liability arising out of reliance on the contents of this presentation.

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Document Holder

No. Title

1 Stephen Oliver

Note:

1. A Document Holder is responsible to communicate and ensure compliance with the

requirements of this document.

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Document Development Team Members

No. Name Designation Department

1 Stephen Oliver Technical Safety Specialist Wells HSE

2 Ad Theuns Senior Safety Specialist Wells HSE

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Amendment Summary

The table below must be completed in detail for each revision. To indicate amendments from the

previous version, vertical lines in the left hand margin shall be added at the amended section.

Rev Page Description Approved By Approval Date

1

All

Approved Final Document

Datuk George

Ling Kien Sing

03-04-15

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Table of Contents

1.0 INTRODUCTION .................................................................................................... 7

1.1 OBJECTIVE ........................................................................................................................................................... 7 1.2 SCOPE ................................................................................................................................................................... 7 1.3 STRUCTURE ......................................................................................................................................................... 7 1.4 ABBREVIATIONS ................................................................................................................................................ 7 1.5 GLOSSARY ........................................................................................................................................................... 8

2.0 Drilling Rig HSE Case ............................................................................................ 9

2.1 HSE CASE CONTENTS ....................................................................................................................................... 9

3.0 Section Content Guidance ................................................................................... 10

PART 1 INTRODUCTION .............................................................................................................................................. 10 PART 2 DRILLING CONTRACTORS MANAGEMENT SYSTEM ................................................................................. 11 PART 3 RIG DESCRIPTION AND SUPPORTING INFORMATION ........................................................................... 11 PART 4 RISK MANAGEMENT ...................................................................................................................................... 11 SAFETY CRITICAL ELEMENTS (BARRIERS) ............................................................................................................. 14 FIGURE 1 SCE ANALYSIS APPROACH ..................................................................................................................... 19 BOWTIE METHODOLOGY ............................................................................................................................................. 20 SAFETY (HSE) CRITICAL TASKS .............................................................................................................................. 21 PERFORMANCE STANDARDS ....................................................................................................................................... 22 DEVELOPING PERFORMANCE STANDARDS .............................................................................................................. 23 PERFORMANCE STANDARD PROCESS ....................................................................................................................... 25 PERFORMANCE STANDARD FORMAT ......................................................................................................................... 27 PERFORMANCE STANDARDS REVIEW ....................................................................................................................... 27 SWISS CHEESE MODEL ................................................................................................................................................ 28 PART 5 RIG EMERGENCY RESPONSE ........................................................................................................................ 29 PART 6 PERFORMANCE MONITORING...................................................................................................................... 29

4.0 Remedial Action Plan .......................................................................................... 31

5.0 Rig HSE Case Review ........................................................................................... 31

6.0 PETRONAS CARIGALI HSE Case Assessment Process .......................................... 31

7.0 Operationalization of the Rig HSE Case ............................................................... 33

EXAMPLE OF SAFETY CRITICAL LISTINGS .............................................................................................................. 34

8.0 Barrier Monitoring ............................................................................................... 35

9.0 Visual & Practicable Use...................................................................................... 36

10.0 Incident Investigation ..................................................................................... 36

11.0 Bridging Document .......................................................................................... 37

12.0 Simultaneous Operations ................................................................................. 37

13.0 Rig HSE Case Review Check List ....................................................................... 37

14.0 Appendix 1 - Typical SCE Barrier Diagram ........................................................ 40

15.0 References ....................................................................................................... 41

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1.0 INTRODUCTION

1.1 Objective

The objective of this guideline is to give guidance to all Drilling Contractors on the

development, content and operationalization of the Rig HSE Case and assist PETRONAS

CARIGALI personnel to effectively review, verify and formally accept the Case for the

intended Operation.

In line with PETRONAS CARIGALI Operations requirement UHSE Technical Standard for HSE

Case EP-HSE Case-02-12 (rev 1) all drilling units shall have in place an HSE Case developed

in accordance with the latest IADC Guideline for HSE Case for Mobile Offshore Drilling Units

(MODU)

This Rig HSE Case Guideline is intended to give further guidance on PETRONAS CARIGALI

requirements in addition to IADC and give direction on effective development and

implementation of the Rig HSE Case specifically in relation to Major Accident Hazard (MAH)

prevention through Safety Critical Element (SCE) identification & setting, monitoring and

verification of the associated performance standard.

It shall also give guidance to Drilling Contractors on the submittal, approval and verification

process for formal acceptance of the HSE Case by PETRONAS CARIGALI.

It is the responsibility of each Drilling Contractor to ensure that any further revisions issued

by IADC to the HSE Case Guidelines for MODU are reviewed and implemented as required.

1.2 Scope

This guideline shall be applicable throughout PETRONAS CARIGALI global operations. For

international operations if operating in a country subject to regulatory HSE Case

requirements then the drilling contractor shall also adhere to the regulatory requirements

of the country of operation.

1.3 Structure

This Guideline is structured in accordance with the IADC HSE Case Guideline for MODU

(Jan 2015) in that further guidance and required PETRONAS CARIGALI Rig HSE case

content is outlined through HSE Case parts 1-6 in Section 3 of this Guideline, with

additional guidance as required.

1.4 Abbreviations

(1) For the purpose of this guideline, the abbreviations and acronyms used in this

document shall have the following meanings

No. Abbreviations Description

1 ESD Emergency Shutdown Device

2 F&G Fire and Gas

3 HSE Health Safety Environment

4 IADC International Association of Drilling Contractors

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No. Abbreviations Description

5 MAH Major Accident Hazard

6 MOC Management Of Change

7 MODU Mobile Offshore Drilling Unit

8 OIM Offshore Installation Manager

9 PS Performance Standard

10 RAM Risk Assessment Matrix

11 SCE Safety Critical Element

12 TOR Terms of Reference

13 TR Temporary Refugee

1.5 Glossary

No. Term Description

1 Assurance Represents the activities performed to ensure SCE’s meet Performance Standards

2 Competence The ability to perform a particular job or task in compliance with the Performance Standard

3 Major Accident (MA)

An occurrence (including in particular, a major emission, fire or explosion) resulting from uncontrolled developments in the course of the operation of any establishment and leading to serious danger

to human health or the environment, immediate or delayed, inside or outside the establishment, and involving one or more dangerous substances.

4 Performance Standard

A statement that can be expressed in qualitative or quantitative terms of the performance required of a system, item of equipment,

person or procedure of which is used as the basis for managing the hazard.

5 Risk Matrix A Tool for ranking and displaying risks by defining ranges for consequence and likelihood.

6 Risk

Management

Coordinated activities to direct and control an organization with

regard to risk.

7 SCE Such Parts of an Installation, including computer programs, or any part there of:

The failure of which could cause or contribute substantially to ; or

A purpose of which is to prevent or limit the effect of a major

accident.

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No. Term Description

8 Tolerability Tolerability refers to the willingness to operate with a risk to secure

certain benefits and in the confidence that it is being properly controlled.

9 Verification Represents the activities in addition to Assurance carried out by Independent Competent Person appointed by Duty Holder to confirm whether the SCE’s will be, are and remain suitable.

2.0 Drilling Rig HSE Case

As stated the drilling contractor shall have in place an HSE Case developed in accordance

with the latest revision of the IADC Guidelines.

The HSE Case shall:

Demonstrate that there is an effective HSE Management System in place to

manage major hazards, other work place hazards and environmental hazards.

Identify all potential hazards, including major accident events.

Identify, assess and manage the risks associated with the hazards and

demonstrate that all residual risks have been reduced to tolerable levels.

Identify those personnel with HSE Critical Tasks to maintain Safety Critical

Barriers.

2.1 HSE Case Contents

The rig HSE Case (as per IADC Guidelines) shall contain the following as minimum:

Introduction/Expectations

Drilling Contractors Management description, describes the drilling contractor’s

management system and presents HSE management objectives that must be met

to demonstrate assurance that HSE risks are reduced to tolerable levels.

MODU/Installation description and supporting information, describes the equipment

and systems necessary to meet the HSE management objectives and to fulfil the

requirements of the Drilling Contractors scope of operations.

Risk Management, describes the Risk Management Process for assuring that the

risks associated with a Drilling Contractor’s Scope of Operations are reduced to a

level of risk that is tolerable to the Drilling Contractor and PETRONAS. The Risk

Management Process must consider the HSE management objectives described in

Part 2 and the systems and equipment described in Part 3. Any gaps related to the

HSE Management Objectives in Parts 2 and 3 that are identified in Part 4 must be

addressed in the Drilling Contractor’s management system.

Emergency Response describes the HSE management objectives for

Emergency response of incidents - to mitigate the consequences (severity)

identified in Part 4 and the measures to recover.

Performance Monitoring, describes arrangements for monitoring to ensure that the

risk management measures identified in Part 4 are implemented, maintained and

effective at the workplace. (See section 6.0 on Performance Standards Framework)

Remedial Action Plan (PETRONAS CARIGALI requirement), is a compilation of

recommendations identified during HSE Case assessments. All recommendations

shall be reviewed and accepted by the HSE Case Custodian. The recommendations

shall be tracked to closure via a formal action tracking system (e.g. HSE Online,

iHSE etc.) to ensure it is properly monitored.

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All Drilling Contractors shall refer to the latest revision of the IADC HSE Guidelines for

detailed guidance on the structure and content of each section.

3.0 Section Content Guidance The following section is structured in accordance with the IADC HSE Case Guidelines, the

intention is to give further guidance as required to ensure the Rig HSE Case meets the

requirements of both IADC & PETRONAS CARIGALI.

Part 1 Introduction

All Drilling Contractors shall refer to IADC Guidelines for development of Part 1 of the HSE

Case. Part one shall include as minimum:

Purpose of the Rig HSE Case

Senior Management Demonstration against the expectations identified in the IADC

Guidelines

HSE Case Scope and arrangements

Drilling Contractor Overview

HSE Case responsibilities, It is critical to demonstrate in this section who is

identified as the responsible person/position to ensure the HSE case is

implemented effectively and complied with

HSE Case Review and Updates

Continuous Improvement to include statement of contractors commitment to

continuous improvement and how they demonstrate this

Action Plan/Recommendations to demonstrate how the Drilling Contractor

addresses Identified HSE performance gaps

In addition to the above IADC requirements PETRONAS CARIGALI require this section to

also include a statement/demonstration of how bridging requirements will be addressed

for campaign specific risks.

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Part 2 Drilling Contractors Management System

This section shall describe in detail the Drilling Contractors Management System and

layout the HSE Management objectives. The IADC Guidelines are quite prescriptive in

this section requirements thus PETRONAS CARIGALI shall review this section in line with

the IADC Guidelines and no further guidance is required.

Part 3 Rig Description and Supporting Information

The purpose of section 3 is to detail the rig layout and describe the equipment and

systems on the rig. It shall describe the equipment and systems onboard to meet HSE

Management objectives outlined in sections 2 & 5. This shall include but not limited to:

MODU Details

Certification, Classification and Registration

MODU Layout

Modifications or Upgrades

Selection of HSE Critical Equipment & Systems (See following Section for

Guidance)

Operating Limits

Structural Integrity

Stability Systems

Ballast & Bilge Systems (Semi, Drill ships)

Towing Arrangements

Mooring & Station Keeping (If required)

Drilling, Completion & Well Control Systems

Helideck Arrangements

Emergency Lighting

Fire & Explosion Protection

Detection Systems

ESD Systems

Passive Fire Protection

Temporary Refugee Arrangements

Evacuation & Escape Arrangements

Well Testing Arrangements

Other Third Party Equipment

Accommodation Arrangements

Within section 3 as per IADC HSE Case Guidelines for MODU Section 3.1.5 it shall describe

how the drilling contractor selects equipment/systems that are determined to be HSE

Critical (Safety Critical Elements SCE)

The IADC Guidelines do not outline a defined process for determining those equipment &

systems that are Safety Critical thus further guidance is described in Part 4 within this

Guideline.

Part 4 Risk Management

The objective of Part 4 of the Rig HSE Case is to demonstrate the effectiveness of the

Drilling Contractors risk management process and critically how it is applied by the rig

personnel at the worksite.

The IADC Guidelines calls for a consistent approach in identifying and managing risk thus

this section shall demonstrate the Risk Management Process for assuring that risks

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associated with the Rig operations are reduced to a level that is tolerable both for the

Drilling Contractor and PETRONAS CARIGALI

The HSE Case is the principal document that is used to identify the Major Accident Hazards

and consequently establish the barriers that are in place that prevent or mitigate the

consequences of the MAH.

The Risk Assessment Process Shall address the key 3 steps as outlined in the Structured

Hazard Identification and Control (SHIDAC) Process:

Step 1 Identify Hazards

Step 2 Evaluate Risk

Step 3 Identify Risk Reduction measures (control, defense, and recovery measures

and set performance requirements)

Detailed guidance on the content of each step is outlined in the IADC Guidelines. Although

it should be highlighted that workplace hazards that have been assessed as high risk the

following shall be applied:

For each cause (potential to release hazards) identify the barriers (SCE) expected to

prevent the release of the hazard

For every potential release of hazard identify the barriers to reduce the consequences

or assist in the recovery from the consequences

For each (barrier) SCE Identified

Identify the critical tasks/activities required to ensure barriers are in place,

working effectively and integrity maintained

Identify the resources & competencies required for the barrier to be implemented

and effective

Identify where the barrier is referenced in the Management System

Identify any factors that prevent such barriers from being defeated, removed

from service or any reduction or elimination of their effectiveness and;

Identify any compensatory barriers and the associated activities, resources,

competencies and management system references to address such factors.

As per IADC Guidelines In order to provide a consistent and systematic estimation of risk,

the recommended approach is to apply a Risk Assessment Matrix (RAM) in a qualitative

manner. A RAM provides a convenient structure to apply the Drilling Contractor’s

screening criteria (values, targets or performance standards) to evaluate or compare

the significance of an identified hazard, event or associated risk to determine the

tolerability.

The IADC HSE Case Guidelines do not prescribe which RAM should be adopted and each

Rig Contractor may have different matrices, but the RAM is fundamental in the risk

management process for determining MAH.

The following RAM is a typical Risk Assessment Matrix taken from the IADC Guidelines and

the Specific RAM utilized by PETRONAS CARIGALI for determining risk.

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PETRONAS CARIGALI RAM The classification of hazards as MAH is determined by risk

ranking, Major Accident Hazards are represented by risks ranked as Red – VERY HIGH

(E4, E5, D5), Orange – HIGH (B5, C5, D4, E3)

Whichever RAM has been applied when determing the classification of Hazards the

relevant Rig HSE Case shall reference:

A description of the process used to systematically evaluate and select the barriers

that will be applied to reduce the risk of each identified hazard and source

The completed Rig Contractors Hazard/Risk Register listing all the hazards and

sources, the estimates of the associated risks, the significance of these and the

references to the associated barriers selected to reduce the associated risks

Describe the critical activities, resources and competencies etc. needed to ensure

these are all established and maintained

References to the decisions made by the review team to document their

justifications for rejected or potential barriers

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Details of where relevant good practice and judgement based on sound engineering

and ergonomic principles have been taken into account in determining which risks

are tolerable

A list of all the barriers that have been selected to reduce the risks, also

highlighting which barriers are already in place and those to be put in place.

A prioritized Remedial Action Plan to fully establish the remaining selected barriers

including identifying the required/responsible personnel for implementation.

PETRONAS CARIGALI shall use TOLERABILITY as it’s reference for determing risk.

Tolerability means a willingness to operate with some risk in order secure certain

benefits and in the confidence that the risk is being correctly controlled. The risks are

considered Tolerable where:

The Drilling Contractor is willing to accept the risk in order to gain the benefits

from the activity (with the understanding that the risk is being properly managed

and with the belief that the risk is worth taking); And

The risk has been reduced to a level where the effort, cost and practicality of

further reduction measures become disappropriate to the additional amount of risk

reduction that could be gained this condition is sometimes reffered to As Low As

Reasonably Practiable (ALARP)

Tolerability is considered to be achieved when the risk is reduced to a level at which the

cost and effort of further risk reduction is largely disproptionate to the achieved reduction

of risk, as illustrated in diagram below, although to ‘Tolerate” risk does not necessarly

mean it is regarded as negligible or the risk can now be ignored but rather a risk that

must be kept under review and reduced further if and when it can be.

Safety Critical Elements (Barriers)

Safety Critical Elements are any structure, plant, equipment, system (including computer

software) or component part whose failure could cause or substantially contribute to a

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major accident, or are any which are intended to prevent or limit the effect of a major

accident.

The Safety Critical Element not only includes the specified equipment, but also any other

SCE required for the equipment to perform its specified safety function, including electric

and hydraulic power supplies and connections.

Each SCE shall be selected based on the following criteria:

Consequences of failure of the item

Elements that contribute substantially to preventing or reducing, risks from Major

Accident Hazards (MAH)

Elements that contribute substantially to controlling or mitigating the effects of a

MAH.

For PETRONAS CARIGALI requirements each SCE identified shall be grouped into the

relevant barrier which will prevent or limit the consequence of a Major Accident Hazard or

Event.

The Rig HSE Case (as minimum) should ensure that each SCE is identified/grouped using

the generic barrier groups: (See Section 3.0 Swiss Cheese Model)

1. Structural Integrity

2. Process Containment

3. Ignition Control

4. Detection Systems

5. Protection Systems

6. Shutdown Systems

7. Emergency Response

8. Life Saving

Each Major Accident Hazard (MAH) is established through Hazard Identification Study

(HAZID) each MAH shall be analyzed to identify the required means to manage the

associated risks. The HAZID process used by each Drilling Contractor to identify the MAH,

associated risks and SCE shall be demonstrated or referenced as part of the Rig HSE Case.

Typical Examples of SCEs and relevant associated equipment (sometimes referred to as

sub-elements) include but are not limited to:

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Structural Integrity (SI)

Critical structures whose failure could lead to a multiple fatality accident, e.g.

offshore jackets, accommodation unit topside support structures

Structures supporting equipment where loss of integrity could result in an escape

of hazardous material with the potential to cause fatality and/or damage the

environment

Structures designed to protect other structures or equipment from the full force of

an impact which otherwise has the potential to cause major accidents e.g. boat

fenders / riser guards

Lifting equipment and systems, jacking systems whose failure could lead to or

contribute to a major accident

Ballast System

Heavy Lift Cranes

Drilling System

Mooring System

Subsea Foundation Structures

Topsides &/ Surface

Bridge Connections to support vessel

Station Keeping / Propulsion / Dynamic Positioning / Thrusters

Process Containment (PC)

Equipment, piping and pipelines where loss of integrity could result in an escape of

fluid under pressure or hazardous material with the potential to cause harm to

people and /or the environment

Integrity protection systems such as relief valves, instrumented protective

systems, and bursting discs that protect the plant from loss of containment as a

result of exceeding design conditions.

Fired Heaters

Gas Tight Floor Wall

Heat Exchanger

Helicopter Refuel

Oil Produced Water Control

Pipeline System

Piping System

Pressure Vessel

Rotating Equipment

Tank

Tanker Loading

Well Containment

Wire Line Equipment

Relief System

Moveable and Temporary Equipment

Ignition Control (IC)

Area classification systems and procedures designed to prevent ignition in case of

an escape of flammable material. This also includes ventilation systems that may

be necessary to maintain the correct area classification.

Miscellaneous ignition control components such as flame arrestors, spark arrestors,

etc.

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Hazardous. Area Ventilation

Non- Hazardous. Area Ventilation

Certified Electrical Equipment

Earth Bonding

Cargo Tank Inert Gas System

Flare Tip Ignition

Fuel Gas Purge System

Miscellaneous Ignition Control

Chemical Tank Inert System

Detection Systems (DS)

Detection equipment and systems designed to alert the operators of an escape of

hazardous material and possibly to initiate various control actions.

Portable gas monitoring and gas testing equipment, used either to supplement, or

to complement fixed equipment and systems, or for certifying safe conditions of

work, e.g. prior to undertaking hot work or confined space entry under Permit to

Work (PTW).

Fire and Gas Detection System

H2O in Condensate

Protection Systems (PS)

Fire and explosion suppression equipment and systems where people could

otherwise be at risk

Firefighting equipment and systems

Incident control equipment such as water sprays, foam systems

Equipment and systems designed to mitigate the consequences of fire and

explosion such as fire walls, blast walls and passive fire protection

Other equipment and systems, which play a significant role in preventing major

accidents, such as navigational aids.

Chemical Injection System

Collision Avoidance

Deluge System

Fire/Explosion Protection

Navigational Aids

Power Management System

Sand Filter

Firewater Pumps

Firewater Ring main

PFP

Gaseous PFP

FWS System

Sprinkler System

Fixed Foam Sys

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Shutdown Systems (SS)

Release control equipment and systems such as emergency shutdown, non-return

valves, and blowdown, which are designed to limit the quantity of hazardous

material involved in an incident.

Well isolation equipment such as the SCSSSV, SSV, etc.

Drilling well control equipment such as Blowout Preventer, Mud weight control, etc.

De-pressurization System

Drilling Well Control

ESD

HIPPS

SSIV

Well Isolation

Pipeline Isolation Valves

ESDVs

Emergency Response (ER)

Emergency power equipment and systems (emergency generators, switch gear,

Uninterruptable Power Supplies (UPS), etc.

Communications equipment and systems that alert people that an incident has

occurred and which can be used to provide instruction

Equipment and systems that allow communication between emergency response

teams and the emergency control centre

Equipment and systems that expedite the removal of people to a place of safety

such as emergency lighting, escape routes, offshore platform evacuation systems

and standby vessels.

Equipment and systems that allow communication with external agencies that can

provide assistance in dealing with the incident.

Secondary containment equipment and systems designed to restrict hazardous

materials spreading from a spillage location into other areas.

Weighing and measuring equipment and systems whose failure could lead to or

contribute to a major accident such as gas meters, pressure/ temperature/level

gauges, weighbridges.

Communication System

Emergency Power

Emergency/ Escape Lighting

Escape & Evacuation Routes

Helicopter Facilities

Temporary Refuge

UPS

Manual Fire Fighting Equipment

Open Hazardous Drain

Open Non Hazardous Drain

Oil Spill Contingency (Oil Booms and Dispersants)

Life Saving (LS)

Personnel protective equipment for general use in an emergency such as life

jackets, breathing apparatus, and search and rescue equipment, etc.

Evacuation facilities such as life boats, TEMPSC, life rafts, knotted ropes, scramble

nets, boat landing etc.

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PPE

Lifeboats/ TEMPSC

Rescue Facilities

Tertiary Means of Escape

Life Jackets and Life Buoys

The IADC MODU HSE Case Guidelines do not give prescriptive list or overview of what

predefines Technical SCE and on which detail level they shall be identified although they

can be divided into two main categories – those that do and those that do not alter shape

state or condition in order to perform a barrier function. The former is commonly referred

to as active or functional barrier elements, while the latter is often called passive or

structural barriers.

Active barriers can be characterized by being dependent on actions of an operator, a

control system and/or some energy sources to perform their functions. Passive barriers

refer to measures integrated into the design of the platform or vessel, and do not

require operator actions, energy sources or control systems to perform their functions.

Examples Include:

Active / functional: Fire and gas detectors, fire dampers, sprinklers, emergency

shutdown valves, PA, communication equipment, BOP, choke and kill system, etc.

Passive / structural: Fire and explosion walls, casing, cements, 500m safety zone,

passive fire protection, drains, escape routes, temporary refuge etc.

Figure 1 SCE Analysis Approach

The below diagram gives a basic structured approach to the identification of SCE, Setting

of the Performance Standards and the verification of the Performance.

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The main output objectives from the above process are to identify:

What is classed as Safety Critical? (SCE)

What does it have to do? (Functional Requirement)

What do we need to do to ensure its reliability? (Performance Standards)

Monitoring and Routine Inspection (Maintenance, inspection and Testing)

Auditing & Inspection (Assurance)

Bowtie Methodology

In order to better understand and be aware of the rigs Safety Critical Elements and their

functions a systematic approach shall be demonstrated. In order for the rig to manage

each SCE they must first know what they are and what they do.

Each SCE/Barrier for each identified MAH shall be presented in the “Bowtie” This picture

format links all the SCE/Barriers for a given MAH which in turn allows the rig to adopt a

systematic approach to the management of the SCE/Barriers.

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Safety (HSE) Critical Tasks

HSE Critical Tasks or activities are essential for maintaining the effectiveness of each

identified safety critical element.

Personnel contribute to major accident risk both in positive and negative ways. Positively,

they detect and correct failures in technical systems through e.g. testing and

maintenance, they diagnose and respond to system upsets and abnormalities in ways

which computers are incapable of, and they perform other tasks which cannot be replaced

by machinery and automation. Negatively, as with technical systems, personnel are prone

to error under certain circumstances, such as working under stress, lacking proper

training or operating with misleading procedures. This contribution happens through what

is called HSE critical tasks, which in many ways can be considered the operational, or

human, equivalent to SCEs.

Operational elements are considered safety critical because they represent operator tasks

which play a direct role in realizing preventive or mitigating barrier functions. For

example, tasks required to ensure correct mud density and volume can be identified as an

HSE Critical task part of the barrier function “prevent well kick”.

The Drilling Contractor shall identify the competent staff designated to maintain the

Safety Critical Element/Barrier. Each task maybe a combination of:

Inspection and Maintenance – To ensure the equipment/hardware maintains its

integrity and reliability

Operational- To ensure that the equipment is used within the defined limits of the

controls provided

Administrative – To provide the necessary training and awareness to ensure people

perform to the required competency level and provide the necessary equipment

and support for them to adequately perform the task.

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IADC does not define Competence but for PETRONAS CARIGALI requirements it shall

include having the necessary theoretical and practical knowledge and actual experience

of the type of rig or facility to conduct the necessary inspections and maintenance and

thus identify any defects or potential weaknesses.

The Drilling Contractor shall have a system of documented competence assurance with

a traceable means of assessment which clearly states the competence criteria and

method of assessing the designated person with the HSE Critical Task.

The Competence scheme shall contain the minimum following elements:

Competency criteria by engineering discipline or SCE Specific

Detailed criteria to define competence – a combination of technical knowledge

Frequency of review and assessment

Definition of which lifecycle phase the person is considered competent for

It may also be linked to the competence program to demonstrate how the level of

competence is increased.

The Rig HSE Case shall contain or make reference to:

List of the HSE Critical Activities/Tasks & Equipment/Systems

Details of the arrangements for verification of effectiveness for all HSE critical

activities/tasks and equipment/systems against the established performance

standards

Details for the arrangements for tracking actions arising from verification to

completion.

Further guidance on awareness and training into HSE Critical Tasks is outlined in

section 7.0 On Operationalization of The HSE Case.

Performance Standards

Performance standards shall be prepared for all Safety Critical Elements. The performance

standards are the parameters that are measured or assessed so that the suitability and

effectiveness of each SCE can be assured and verified.

Through the development of Performance Standards the drilling contractor shall

demonstrate a competent understanding of the MAH controls in place based on

measureable evidence. In that through the development of the performance standards

within the HSE Case they can demonstrate:

They fully understand what the performance criteria is for each MAH Control and;

That the maintenance and testing is fully implemented to demonstrate that these

performance standards can be met.

So in basic principle “This is what the control is designed to do” and “This is how we

demonstrate through testing/maintenance etc. It actual does it”

The performance standard process and associated standard shall be developed for each

identified Safety Critical Element (SCE)

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Developing Performance Standards

When developing the performance standards the following criteria shall be met:

Functionality, what the control measure must do and the criteria it must achieve.

Reliability, assuring its functional capability.

Survivability, will it continue to function, if required after a hazardous event has

occurred.

Dependency, what other control measures are required to maintain/allow its

functional capability.

And then how the above criteria is or will be assured e.g. Design/Technical review,

QA/QC, maintenance, inspection & testing or audits etc.

The following shall be observed in the setting of Performance Standards:

Each criteria, including minimum acceptance criteria shall be justified

It should be encouraged to use and reference design standards and codes where this

is relevant. For example, the Code used to design the SCE, or that governs the

testing frequency e.g. API RP 520 for sizing of relief valves, EEMUA 188 for

establishing operating periods of relief valves. This may be relevant throughout the

asset lifecycle.

HSE Case supporting studies such as Fire and Explosion Risk Assessment (FERA) and

Quantitative Risk Assessment (QRA) should be reflected in the Performance

Standard criteria, e.g. FERA shall provide information for the required fire water

demand in respect to the largest potential scenario.

Clearly measurable criteria, which can be confirmed during routine operations,

maintenance, testing or inspection is needed. Where acceptance criteria are obscure

or ambiguous they cannot practicably be assured. This can lead to confusion and

loss of confidence in the SCE management process

Lifecycle phases shall be separately considered, but shall be combined into a single

Performance Standard document. This is to provide traceability across the entire

lifecycle of the SCE.

The specific performance standard shall ensure for all Safety Critical Elements that they:

Are suitable and fully effective for the type hazards identified,

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Have sufficient capacity for the duration of the hazard or the required time to provide

evacuation of the installation,

Have sufficient availability to match the frequency of the initiating event,

Have adequate response time to fulfil its role,

Are suitable for all operating conditions”.

The following demonstrates the performance requirement for active fire water System:

Performance Criteria shows what the system requirements are, Basis is what the

Performance Criteria is developed against i.e. Design, Regulations, rules etc. Performance

Verification is how each function is verified and how it is assured.

The performance verification should also contain the relevant links to the Procedure or

Maintenance Task or Schedule.

Function 2 To Supply the Fire water at the required pressures and flow rate:

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Performance Standard Process

Performance Standards need to be defined in a consistent and logical manner. It is likely

that more than one parameter will be needed to detail the required performance of the SCE

as a barrier. The codes, standards and specifications used in the original design of SCEs

should be identifiable from the Performance Standards so that suitability can be maintained

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throughout the asset’s life. Any other related key documents should also be referenced

in the Performance Standard.

Performance Standards Criteria:

Functionality

Functionality defines the key duties that the SCE is required to perform. The minimum level

at which that function is achieved must also be defined. Criteria is considered measurable

where it is possible for a person carrying out an assurance task or activity to clearly

understand what the critical requirement is and thus be able to measure or observe that

the criteria is being met.

Reliability

How likely is it to perform on demand? Those SCE’s for which it is required to measure

reliability during operations shall be identified at the design stage. Reliability targets are

set during the design phase based upon the safety studies carried out in support of the

Rig Safety Case. When in the operation phase the ability to meet this criteria is

demonstrated by functional testing at appropriate intervals, From these functional tests

Survivability

Will it continue to function, if required after a hazardous event has occurred.

The performance criteria for survivability must be defined if the SCE is required to operate

in the event of a Major Accident, it shall also state how long the system should continue to

operate for. Each SCE shall be considered against the defined MAH in the Rig HSE Case.

Dependency/Interactions

What other control measures are required to maintain/allow its functional capability.

It shall also be defined what other SCE’s are required to function in order for the one in

question to operate effectively.

Systems of SCE’s are often dependent upon each other in order that the MAH is mitigated.

As example:

• Structural elements rely on Passive Fire Protection Systems to ensure they meet

Survivability criteria

• Fire & Gas systems rely on Emergency Power (UPS) to ensure they provide

protection during power outage or ESD

• Electrical ignition prevention is a system relied upon by others to ensure that safe

operation is continued in potential flammable atmospheres.

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Performance Standard Format

When reviewing the performance standards as part of the HSE Case acceptance process

PETRONAS CARIGALI does not dictate which format the performance standards are to be

presented in but it shall be demonstrated that each of the above criteria have been

addressed through a systematic process.

The following example demonstrates a template for a performance standard for operations

phase, the template shows suggested layout not content.

Performance Standards Review

Review of performance standards shall be periodically carried out. The purpose to:

Incorporate new learnings from the Drilling Contractors organization and other

industry developments

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Consider if they are still suitable as required by operator or the regulations, if

bound by country of operations regulatory requirements.

To ensure the effectiveness of the reviews mixed teams of Offshore & Onshore personnel

should be used.

The Performance Standards shall also be reviewed when operating parameters on the

installation change, e.g. additional wells bringing more hydrocarbons or sour gas or

modifications as in additional POB through further accommodation etc. Further Guidance

on review is detailed in Section 6.

Swiss Cheese Model

As outlined in the Risk Management Section of this guideline PETRONAS CARIGALI refer

within their Risk Management Process to the Swiss Cheese Model the Swiss Cheese

Model is one of the most acknowledged barrier models. The model builds on the

principles of “defenses in depth” with a set of successive protection layers (barriers)

preventing hazards from being realized and causing accidents to happen.

The Swiss Cheese Model illustrates an event sequence in which barriers are presented in

cheese slices the holes in each slice represent weakened barriers either caused by active

or latent failures:

Active Failures are caused by people (unsafe actions) or technology and have a

direct influence on the accident causation, examples can be failure to operate a

BOP in case of a well kick or a fire damper that fails to close when activated

Latent Failures are defects or flaws in the system which indirectly allows an

accident scenario’s to develop. One example could be incorrect line-up of valves

e.g. a maintenance task which at a later stage may cause flow of hydrocarbons to

undesired locations.

Throughout the lifetime of a rig, holes in this model are expected to constantly move and

change sizes depending on the type operation, asset management, external

environments etc. For a major accident to happen, holes in the Swiss Cheese Model need

to align allowing for an “accident trajectory.” The strength of the Swiss Cheese Model is

how it exemplifies and promotes the following strategy for management;

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Each barrier should either prevent hazards from being realized or escalation of the

event

If one barrier fails, the subsequent barrier comes into play

Barriers should, as far as possible, be independent of each other

Barriers should be in place to reduce the risk to tolerable levels

No single failure should be able to cause a major accident

“Holes” i.e. degradation in barrier performance should be as small and few as

possible

For this strategy to be successful, barrier needs to be managed in a way which ensures

that they perform as intended at all times. This includes a comprehensive and common

understanding from design and throughout operations of what constitutes barriers to

hazards, and how barriers are verified, monitored and maintained.

Part 5 Rig Emergency Response

The objective of Section 5 is to demonstrate that emergency response arrangements for

the rig have been systematically assessed and suitable arrangements in place to respond

to all credible emergency situations to cover the following criteria:

Emergency Response Management

Command & Communication

Training/Drills for emergencies

Muster Station/Temporary Refuge (TR) arrangements

Details of evacuation and escape equipment, including details of Escape Routes and

Escape Times

Means of Recovery to Place of Safety.

PETRONAS CARIGALI shall review this section against the IADC Guidelines although the

Drilling Contractor shall ensure that this section is further developed into a rig specific

Emergency Response Plan to ensure alignment with current operations.

The Training, Exercise & Drills Plan shall be reviewed and further developed to ensure all

current credible emergency scenarios are covered and addressed in the plan.

PETRONAS CARIGALI shall ensure that Client and Third Party roles, responsibilities and

expectations are clearly defined in the Bridging Document. (See section 11.0 Bridging

Requirements)

Part 6 Performance Monitoring

Section 6 of the Rig HSE Case shall describe the systems and procedures in place to

ensure that all the Safety Critical Elements identified in section 4 are effectively

implemented and the effectiveness and integrity of those elements are maintained for the

life span of the rig.

AS per the IADC Guideline monitoring shall address the following:

Periodic Monitoring

Audit & Compliance

Verification of HSE Critical Activities/Tasks and Equipment/Systems

Periodic Monitoring:

The Rig HSE Case shall demonstrate that arrangements are in place for monitoring the

HSE management of major and other workplace hazards on a daily basis.

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It shall clearly detail:

Roles and Responsibilities for monitoring compliance with daily procedures and

standards

References to the program of daily work place inspections including the Behavioral

Based Safety Observation Program in use on the rig.

Further development and document the performance standards related to HSE

Critical Activities/Tasks and Equipment/Systems

Proactive performance measures related to other workplace hazards i.e. Hazard

Hunts, Stop Work Drills etc.

Reactive performance measures, incident investigation and management reviews

(See section 10.0 Incident Investigation)

How performance monitoring is measured to ensure trends are captured and

improvements made,

When reviewing this section against the IADC Guidelines PETRONAS CARIGALI shall

ensure that the following is clearly addressed and documented:

Each line manager and supervisor responsibility for monitoring the compliance with

HSE Procedures & Standards

Details of all workplace inspection schemes

Details of the Leading HSE Performance indicators

Details of how the analysis of HSE Performance is documented

Details on the arrangements for discussing, communicating and reviewing the HSE

Performance at each level of the contractor’s organization.

Audit & Compliance

It shall be demonstrated that arrangements are in place for auditing of the HSE

Management Systems Policies and Procedures that address major hazards and other

workplace hazards.

PETRONAS CARIGALI requires the following to be detailed within this section:

A documented audit program covering all areas of the rig and operation

Details of the responsible persons identified for auditing the HSE Management

Systems, Policies and Procedures

Details of the arrangements in place for follow up of findings and the close out of

actions.

Details of how audit findings are communicated to senior management and to

those audited.

Verification of HSE Critical Activities/Tasks and Equipment/Systems

It shall be demonstrated the arrangements in place for verifying HSE Critical

Activities/Tasks and Equipment/Systems developed as per Section 4

It shall ensure that:

All HSE Critical Activities/Tasks and Equipment/Systems have been identified

That suitable arrangements are in place for verifying the effectiveness HSE Critical

Activities/Tasks and Equipment/Systems against the established Performance

Standards (See Section 4 Risk Management)

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That Details of the verification process for assessment of the effectiveness of all

HSE Critical Activities/Tasks and Equipment/Systems against the established

Performance Standards (Third Party)

PETRONAS CARIGALI shall review this section against the IADC Guidelines, depending on

the scope of the rig contract an HSE Critical Activities/Tasks and Equipment/Systems

verification audit against the documented Bowtie diagrams shall be performed either prior

to commencement of operations or as soon as possible following commencement. This

may be performed internally with PETRONAS CARIGALI HSE Technical personnel or

through the use of Third Party Consultants.

4.0 Remedial Action Plan

As detailed in section 4.7 of the IADC HSE Case Guidelines it may be necessary to develop

a Remedial Action Plan to document and track actions arising from Risk Management

process, allocation of resources and nominated persons to ensure all barriers are

established prior to the potential of the MAH Risk at the rig.

PETRONAS CARIGALI requires the Remedial Action Plan to be documented as an additional

section 7 or additional appendix to the Rig HSE Case to allow a complete assessment

of the Rig HSE Case to be performed.

Once the Rig HSE Case has been accepted as suitable by PETRONAS CARIGALI the

Remedial Action Plan shall remain a live document to ensure all actions are tracked to

closure and any additional issues arising through operational requirements, major

design change or through result of incident investigation are included for tracking and

closure.

5.0 Rig HSE Case Review

Once the Rig HSE Case has been accepted by PETRONAS CARIGALI it shall be subject to

the criteria and arrangements for review and update.

PETRONAS CARIGALI require the HSE Case review to be performed for:

Changes in operation that significantly change the overall risk

Significant changes to manning levels or organizational structure

Significant Changes to the Drilling Contractors management System referenced in

the case

Significant lessons learned from incidents

If operating in a country subject to HSE Case regulatory requirements, any

changes in legislation/regulatory requirements

Expiry of specified Drilling Contractor specified review intervals

5 years has passed without formal review of the HSE case.

6.0 PETRONAS CARIGALI HSE Case Assessment Process

The following section outlines the review and acceptance process performed by

PETRONAS CARIGALI in order to accept the Rig HSE Case as suitable for the intended

operations.

As per the PETRONAS CARIGALI Rig Acceptance Procedure (If not submitted as part of

Tendering Process) the Rig HSE Case shall be submitted to PETRONAS CARIGALI a

minimum of 3 weeks prior to commencing operations to allow the HSE Case to go

through the 4 stages of review and acceptance.

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Stage 1:

Submittal by the Drilling Contractor of the Rig HSE Case and official notification of

receipt by PETRONAS CARIGALI.

Stage 2:

Initial screening of the Rig HSE Case by PETRONAS CARIGALI Upstream HSE Operations,

this screening is an initial reading of the case not an assessment, to ascertain if the HSE

Case is generally fit for purpose and meets the IADC & PETRONAS CARIGALI

requirements and contains sufficient information to allow a full assessment to be

performed.

Where there is obvious insufficient information the Rig HSE Case will be returned to the

Drilling Contractor with the opportunity to make required improvements and resubmit.

Stage 2 will normally be completed within 5 days of receipt.

A Rig HSE Case that does not meet the basic requirements of IADC requirements shall

not progress to stage 3.

Stage 3:

A detailed technical assessment of the Rig HSE Case is undertaken by a designated

assessment team or individual. This assessment will involve a number of discussions and

areas for clarification with the Rig Contractor and requests for information until such time

that the assessment team or person are confident the HSE Case is acceptable.

The objectives of stage 3 are to:

Identify, clarify and prioritize issues which need to be clarified or resolved

Discuss and resolve the above issues with Rig Contractor

Reach formal agreement on required improvements

Reach a decision on whether to accept the HSE case or not

Where an HSE Case is rejected provide reasons of justification.

The assessment of the Rig HSE Case shall be done in accordance with the latest

revision of the IADC HSE Case Guideline and additional PETRONAS CARIGALI

requirements as outlined in this guide. Stage 3 assessment shall normally be completed

within 10 – 15 days.

Stage 4:

Formal acceptance of the Rig HSE Case as acceptable for the continued operation. This

may also include any gaps or outstanding items required for tracking and closure.

Any actions required to be closed will be included in the Remedial Action Plan (See Section

4) of the HSE Case with assigned targets and action parties for closure.

It is essential that the Rig HSE Case is maintained as a live document and kept

up to date to ensure that the information and risks of exposure are current.

The HSE case should form part of any consultation before any major

modifications are undertaken and form part of any incident review process to

ensure barriers referenced remain effective.

Management of Change (MOC) is one of the most important elements supporting

major accident prevention throughout the lifecycle of the rigs activities. Poor

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identification of the hazards and risks exposed by change leads to improper

management of change and leads to the potential for major incidents.

7.0 Operationalization of the Rig HSE Case

Once the Rig HSE Case has been accepted as suitable by PETRONAS CARIGALI the Drilling

Contractor (If not already demonstrated) shall produce a documented implementation

plan to effectively roll out and communicate the HSE Case at the rig site.

The operationalization of the Rig HSE Case should be focused on operation requirements

as in what is required to be done now to manage all MAH rather than what has been done

previously.

The implementation plan shall as minimum cover the following areas:

Roll out and communication of the Rig HSE Case to all personnel at site.

Two levels of training on the HSE case, basic familiarization for all personnel and

technical training for management, supervisors and those with HSE Critical tasks.

Visibility and use of the Rig HSE Case.

Verification of the controls/barriers documented in the Bowtie’s

Sustainability on how the implementation and use will be sustained for the duration

of the rigs operation.

PETRONAS CARIGALI shall ensure that all PETRONAS CARIGALI Rig Management and

Supervisors, as well as relevant Third Party Rig Contractors attend the appropriate level of

training and familiarization into the Rig HSE case.

The Rig Drilling Supervisor in consultation with the Rig OIM shall track the progress of

the implementation plan and highlight any areas of concern to the Drilling

Superintendent for follow up with the Drilling Contractor.

Each Drilling Contactor shall ensure a systematic process is implemented to assess and

verify all documented barriers and SCE within each MAH Bowtie the purpose being to

ensure each barrier is actually in place, each SCE has the detailed performance

standard and HSE Critical Tasks/Activities have been assigned to maintain each barrier.

All personnel shall be made aware of their HSE critical tasks and activities. This should be

in the form of training and works shops as well as publication of associated safety critical

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tasks lists and booklets for ease of use covering all levels of the rig organization including

third party the following stages should be addressed:

To ensure all personnel fully understand their HSE Critical Tasks, Frequency of task and

the performance standard it should be put in a simplified tabled format and distributed to

each relevant personnel in documented or booklet format.

Example of Safety Critical Listings

Rig Superintendent

Safety Critical Task Threat / Consequence Control Process Sirius

Reference H-01.02.01 Shallow Gas / Hydrocarbon gas release

Bridging document – Maersk involved in planning

T: Failure by well planners to act on survey information

WCM 12.02.09

Competency & training of personnel C: Cratering below spud cans

Competency & training of personnel C: Ignited release without conductor

Competency & training of personnel in diverting procedures

C: Ignited release with conductor

Consultation with Client Well Construction team

T: Failure by well planners to act on survey information

WCM 3.01

Drilling location moved T: Lack of precaution for identified shallow gas

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Pre spud meeting will ensure the problem is communicated

T: Failure to communicate the information WCM 3.01

Required by Well Control Manual Procedures

T: Failure to carry out seismic survey / Failure to identify presence of shallow gas

WCM 7.02.1

Well program is approved and distributed

T: Failure to communicate the information WCM 3.01

H-01.02.02 Hydrocarbons in Formation during Drilling / Blowout at drill floor

Full redundancy in accordance with API RP53 requirements

T: BOP failure / Well control system failure WCM

Originals parts manufacturer or approved vendors

T: BOP failure / Well control system failure Models: Maintenance and repair

Trained & competent personnel T: Well control procedure failed whilst drilling with BOP

Training matrix: Trained & competent personnel + OJT

T: BOP failure / Well control system failure

H-01.02.03 Hydrocarbons in Formation during Coiled Tubing Work / Hydrocarbon release / blowout

Effective well planning process T: Well control procedure failure

Trained & competent personnel T: Well control procedure failure

Well program is accepted as per the bridging document

T: Inappropriate well plan WCM 12

Mud Logger

Safety Critical Task Threat / Consequence Control Process Sirius

Reference H-01.02.02 Hydrocarbons in Formation during Drilling / Blowout at drill floor

Kick identification procedures T: Well control procedure failure whilst drilling with BOP

WCM 5

Mud monitored – calibrated balance T: Incorrect hydrostatic pressure / Well control procedure failure whilst drilling with BOP

WCM 9

Monitoring of flow and pit volumes and drilling parameters

T: Unforeseen abnormal formation pressures / Well control procedure failure whilst drilling with BOP

WCM 9

H-01.02.03 Hydrocarbons in Formation during Coiled Tubing Work / Hydrocarbon release / blowout

Kick identification procedures T: Well control procedure failure with BOP WCM 5

Mud monitored – calibrated balance T: Incorrect hydrostatic pressure / Well control procedure failure

WCM 9

Monitoring of flow and pit volumes and drilling parameters

T: Unforeseen abnormal formation pressures / Well control procedure failure

WCM 9

Mud loggers sampling means T: Unexpected H2S encountered – not identified as present in drilling program / Release of H2S gas during drilling operations

Maintenance & calibration of logging equipment records maintained on rig

T: Mud loggers equipment failure or error/ Release of H2S gas during drilling operations

(Example Courtesy of Maersk Convincer)

8.0 Barrier Monitoring

It is crucial in managing major accident risk to capture early warnings of deterioration of

the barriers and the effectiveness of other systems in place. These warning signs can be

used to implement measures to improve the barriers or to adjust the activity level and

operations in accordance with the deteriorated barrier performance.

With reference to section 3.0 (Swiss Cheese Model) this early warning means to identify

the condition or the status of the barrier; where the holes are and how big they are. When

identified the holes can be fixed or the activity level can be adjusted so the hazard does

not penetrate a hole.

To ensure that barrier effectiveness is monitored the Drilling Contactor shall ensure that:

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Information relevant for assessing the status of a barrier is identified

A process to evaluate and communicate the status is in place

Purpose and use of information about barrier status is identified related to

planning, operating and maintaining the MODU.

When establishing a monitoring system, a recommended approach is to map already

available information in existing reporting monitoring system(s) and evaluate how this can

be utilized directly or be made available with a minimum of modifications.

9.0 Visual & Practicable Use

It is critical that all levels of Company & Rig personnel understand the purpose and use of

the Rig HSE Case this is achieved by visibility of use at inductions, meetings and daily

planning.

If implemented effectively the Rig HSE Case is an indispensable tool for communicating

hazards and making all personnel aware of their interactions with the critical equipment

that manages them.

A basic introduction into the purpose and use of the Rig HSE Case shall be included in

the rig induction process for all personnel arriving at rig site this shall ensure that all

personnel arriving on the rig are aware of:

What are the MAH on the rig

Where the MAH may occur

The key management provisions/barriers they should be aware of

Each relevant Bowtie and associated HSE Critical Tasks shall be adapted for ease of use

and understanding by the rig crew. This should include visual display of the Bowtie’s at

the relevant work areas or listing of the critical barriers for verification and documented

listing of HSE Critical Tasks to be performed on a daily, weekly or monthly basis

depending on the phase of operation.

The Rig HSE Case shall be utilized when performing any High Level Risk Assessment

process to ensure no barriers are being compromised or if so then sufficient mitigation has

been implemented to ensure the risk remains at tolerable levels.

Any modifications or deviations from the Rig HSE Case shall be managed through the

Management of Change process with the appropriate level of management approvals.

To ensure the HSE Case remains a live document any required changes through

verification or actual use of the HSE Case shall be managed through the Remedial

Action Plan (See Section 4) and all required changes or modifications shall have an

assigned action party, closure date and justification for the change.

10.0 Incident Investigation

Following any High Potential Incident or Major Event the HSE Case shall form part of the

Terms of Reference for the resulting incident investigation the aim being to:

Review the barriers and controls in place

Ascertain if the barriers and controls where actually in place

Ascertain if the barriers and controls where maintained and in good state of repair

Ascertain if any barriers or controls where compromised

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Ascertain if additional barriers or controls are required.

Following the incident investigation any recommended actions or revisions to the Rig HSE

Case shall be communicated to the appropriate level of management for change and

tracked to closure through the remedial action plan. Although any required immediate

preventative actions out with the HSE case requirements shall be implemented

immediately through the MOC Process.

11.0 Bridging Document

It is understood that not all specific aspects and associated risks of a project or operation

envelope can be effectively controlled and managed through the Rig HSE Case. Thus it is

imperative that the Bridging document is prepared and accepted by all Parties to align and

coordinate the response of both PETRONAS CARIGALI and the Drilling Contractor with

particular attention to alignment of emergency response procedures and responsibilities.

The Bridging Document is similarly a live document as is the Rig HSE Case and shall be

effectively put into operation and use as per section 9.0 of this document to ensure all

personnel are fully aware of their accountability and responsibilities.

Any identified additional MAH and Barriers due to further operations not already

assessed as part of the Rig HSE Case shall be subject to assessment using the RAM as

prescribed in section 4.0

12.0 Simultaneous Operations

When introducing further hazards not already assessed as part of the Rig HSE Case,

through required Simultaneous Operations PETRONAS CARIGALI shall ensure a hazard

assessment/risk assessment is performed to address any additional hazards not already

addressed as part of the rig HSE Case. This shall be further developed into the specific

Simultaneous Operations Procedure (SISO) this procedure shall:

Identify Management System Interfaces including responsibilities

Clarify the procedures to be followed and interface arrangements

Define the Boundaries of responsibility

The Drilling Contractor should be included in the risk assessment process and consultation

on development of the SISO Procedure/Document.

13.0 Rig HSE Case Review Check List

The following is a brief self-checklist to review the Rig HSE Case against to ensure it

meets the basic IADC Rig HSE Case requirements prior to submitting to PETRONAS

CARIGALI for acceptance or for use during periodic reviews.

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Full Rig HSE Case with constituent and cross referenced sections:

Section Description Interrelationship

Part 1: Introduction

Provision of overview of both rig and Company along with agreed ownership for the HSE Case. Further summarizes the management inputs and requirements for the HSE Case along with continuous improvement. Provides statement for of justification for continued operations.

Provides introduction for all HSE Case Sections and sets out main purpose, goals and objectives.

Part 2:

HSE Management Systems

Describes the Company HSE management

system and sets out the expectations and its delivery through structure, responsibilities, training, competence, plans, systems, standards, procedures and safe work systems. Provides detail on assurance and verification

through measures, audit and compliance.

This section interacts with

parts 4, 5 and 6. Information is shared with regard to competencies, responsibilities, procedures, standards, SCA/SCE barriers

and overall hazard and contingency management aspects.

Part 3:

Rig Description

Describes the layout, equipment, and control systems of the rig, in particular those systems

that are critical to safety and the prevention, identification, control or mitigation of major hazards and risks.

Interacts with sections 4 and 5 with regard to layouts,

SCE’s and rig functions and section 2 with lifesaving and firefighting layouts.

Part 4:

Risk

Management

Describes the overall risk management arrangements in place that have been

identified, assessed through the relevant RAM

process demonstrating a high level or hazard management and TOLERABLE Risk standing for the rig.

Provides input to sections 2 and 5 with regard to the

hazard profile, its

management and emergency response function requirements. Provides input to section 3 with regard to SCE functionality, layout

considerations and design / change hazard management

Part 5: Emergency Response

Describes the arrangements for emergency response management, including plans, training, and arrangements for communication, and how these are tested during drills and

exercises.

Provides input to sections 2 and 4 on emergency functions during possible MAH events and recovery to

ALARP status. Provides input into section 3

with regard to EER functions, layout and equipment

Part 6:

Performance Monitoring

Describes the arrangements for monitoring key

risk management measures to ensure they are implemented, maintained, and remain effective. Key performance monitoring activities include active and reactive monitoring.

Provides input to all sections

with regard to continuous improvement and assurance processes in place to maintain justification for continued operation maintain all risks to TOLERABLE

levels.

Part 7 or Appendix: Remedial

Action Plan (PETRONAS

CARIGALI requirement)

Provides detail on any actions arising from the development of the HSE Case process for remedial work or aimed towards future

continuous improvement.

Provides an active process of closure and improvement for the HSE Case as a whole

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The Completed Cycle of the Rig HSE Case:

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14.0 Appendix 1 - Typical SCE Barrier Diagram

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15.0 References

No. Reference

1 Health Safety & Environmental Case Guidelines for Mobile Offshore Drilling Units, IADC January 2015

2 Assurance & Verification Practitioners Guide, Step Change in Safety

3 UK HSE Guide To The Offshore Installations (Safety Case) Regulations 2005

4 IADC Appendix 1 to Health, Safety and Environment Case Guidelines for

Offshore Drilling Contractors

5 IADC Drilling Manual

6 Aqua Marine Driller HSE Case Manual 2013 (Vantage Drilling Company)

7 Maersk Convincer Rig HSE Case 2013 (Maersk Drilling Company)

8 Effective Management Of Safety Critical Elements, Stena Drilling Practical Lessons

9 UK HSE Assessment Principles for Offshore Safety Cases (APOSC) 2006

10 Technical Standards for HSE Case EP-HSE-02-12 (Rev 1)