Last month, we talked about personal fall arrest (PFA) systems as well as the heights at which different types of fall arrest equipment are most effective. This month, I talk about the use of fall arrest equipment during drilling operations.
Although this topic seems a little bland, one need look no further than social media to find drillers nonchalant about fall hazards. I saw one video from overseas where a driller, needing more down pressure on their bit, positions two helpers on top of the swivel assembly. One of the helpers acts as if he is on a bucking bronco. Gladly most of the comments fell into the “WTH” category — but not all.
As I stated in the first of these fall protection articles, I have climbed a tower or two. Even as a younger man, I understood and feared the hazard from the top of a tower. But that is not the only fall hazard we face in the drilling industry.
The vast majority of fall hazards faced by drill crews come from much lower elevations. Falls can result from a wrong step off unprotected sides or edges of platforms or decks, improper ladder use, poor housekeeping, or access to an area not designed for worker positioning. The first thing to understand is when to protect our workers, and we determine that by the type of work that they do. The act of drilling typically falls under the general industry standard unless our work meets the definition of construction. OSHA defines construction or “construction work” as “construction, alteration, and/or repair, including painting and decorating.” The agency further provides that construction industry standards apply “to every employment and place of employment of every employee engaged in construction work.”
During drilling operations, we don't typically meet the definition of construction. Thereby, we would follow the general industry fall-protection height of 4 feet called out in 1910.28 Subpart D Walking/Working Surfaces. This definition of work allows us to choose which standard applies. During pump maintenance or setting, the construction standard height of 6 feet called out in 1926 Subpart M Fall Protection would apply if our operations meet the definition of construction.
Now that we know what to apply when, we should look at where the fall hazards are on drilling jobs. Hazardous areas include, but are not limited to:
- Uneven/slick working surfaces
- Unprotected sides and edges of platforms
- Open pits
- Climbing and working from the derrick
- Working off the bed of trucks
- Holes in decks and floors
- Getting on and off mobile equipment
- Equipment, materials, lines, etc. on rig tender or the ground
As discussed in last month’s article, the use of fall protection (i.e., personal fall arrest systems or positioning systems) may not be the wise choice for lower-elevation fall risks. Many of these risks require fall prevention such as guardrails and platforms. If a worker must climb to an elevation higher than 4 feet above ground level during drill operations, we must provide them with some type of fall prevention. Typically, that fall prevention comes in the form of guardrails.
According to OSHA, what constitutes a guardrail? Guardrails must have a top rail with the top-edge height between 39 and 45 inches above the walking/working surface. When a test load of 200-pounds is applied in a downward direction, the top rail of a guardrail system must not deflect to a height of less than 39 inches above the walking/working surface. A mid rail must sit halfway between the walking/working surface and the upper edge of the top rail. This mid rail must be load tested to 150 pounds of downward and outward force. The gap between the mid rail and the top rail, as well as the gap between the mid rail and the walking/working service or tow board, cannot exceed 19 inches. If it does, additional mid rails are required. If there's a possibility of equipment or tools falling off of the platform and striking workers below, toe boards at least 3½-inches-high must also be included in the railing system.
This brings me to my main point: How many times during the course of operations does a worker have to climb up above 4 feet on some type of equipment to access the rod box, hoses, grease zerks, etc? Many rigs have no factory fall prevention for these tasks. My program owns a rig with a vertical fixed ladder mounted to the tower to access the carousel for servicing. What is not provided? An anchorage point for a fall protection system. Anchorage points, as discussed in a previous article, must be stamped by an engineer to withstand 5,000 pounds per employee connected. Adding an after-market anchorage is not quite a straightforward process. However this is not the case with guardrails. The parameters in the paragraph above need only be tested — and no engineer stamp is required. This means adding guardrails where needed falls well within the limits of most drilling companies. Guardrails could pin into steak pockets or be permanently affixed, as long as they meet the 200- and 150-pound test requirements set forth by OSHA.
The next thing drilling companies need to do is a thorough hazard assessment of the drilling operations, keeping an eye on fall prevention and protection. Not sure where to start? Well OSHA, in cooperation with the oil and gas industry, makes training material available through the U.S. Department of Labor’s Susan Harwood Training Grant, which covers hazard recognition for fall protection and prevention. I know some are saying, “Well, we’re not doing oil and gas drilling.” You’re right. Not everything will be applicable to your operations, but much of the material is and it’s available for free on the OSHA website.
Beyond contractors, I call on the manufacturers of drilling equipment to work more fall prevention into their designs. There’s no reason why, when I buy a new excavator, I have guard rails all the way around when I'm checking the oil, but when I change a hammer union or run rods into a rod box on a brand new, $750,000 to $1.5-million machine, I have no fall protection at all.
Falls are the most common cause of severe injury and death in industry, so shouldn't preventing falls be of the highest priority for both contractors and manufacturers?
Until next month, stay safe, stay grounded and keep turning to the right.