US GoM Diving Safety Work Group

Transcription

1 US GM Diving Safety Wrk Grup COMMITTEE WORK GROUP JULY 2016 DISCLAIMER This US GOM DSWG dcument is nt meant t be all inclusive, and nt every rule and regulatin is cntained herein. The US GOM DSWG des nt issue plicy r create regulatins. The reader shuld cnsult additinal resurces and subject matter experts fr mre detailed infrmatin as required. Revisin 0 Page 1 f 11 7/14/16

2 The GOM Diving Safety Wrkgrup is a US GOM fcused, nn-cmpetitive and nn-cmmercial grup f il and gas peratrs, transmissin cmpanies, cmmercial diving cmpanies, supprting sub- Cntractrs, rganizatins and industry stake hlders. The grup will prvide a unified vice t prmte and imprve diving safety, thrugh the fllwing: Identificatin and sharing f best practices Identify and seek slutins t industry challenges and issues Review and cmment f existing and prpsed standards and guidelines Prvide input t the regulatrs and industry assciatins Purpse f Cmmittee This dcument has been prepared by the US GOM DSWG as guidance fr: The has been frmed t identify recmmended qualificatins, rles and respnsibilities fr Client Cmpany Diving Representatives. While this cmmittee is fcused n the US Oil and Gas Operatrs; this is nt a ne size fits all and des nt necessarily apply t all Operatrs. Each Cmpany shuld cnduct an assessment as t what qualificatins, rles and respnsibilities shuld apply t their Diving Representatives. Revisin 0 Page 2 f 11 7/14/16

3 Please Nte: The cmmittee has mdified the standard template int the sectins listed belw: Part 1: Executive Summary / Intrductin Part 2: Definitins Defines the activity being evaluated and prvides definitins frm regulatry r industry grups that are assciated with the activity. Part 3: Regulatry / Industry Cnsideratins Identifies regulatry and industry assciatins and guidelines in which the Diving Client Representative shuld have knwledge. Part 4: Purpse f the Diving Client Representative (DCR) Outlines why a Diving Client Representative is necessary fr the prject. Part 5: Qualificatins f a Diving Client Representative (DCR) Outlines the experience and the knwledge base a Diving Client Representative shuld pssess. Part 6: Rles and Respnsibilities f the Diving Client Representative (DCR) Defines the rles and respnsibilities f the Diving Client Representative. Part 7: Interfacing with the Cntractr Outlines hw a Diving Client Representative shuld interface with the Diving Cntractr and what the Diving Cntractrs expect frm a representative. Revisin 0 Page 3 f 11 7/14/16

4 Part 1: Executive Summary / Intrductin Diving Client Representatives are the eyes, ears, and vice f a Client Cmpany n diving prjects. They are respnsible fr the versight f the peratin s safety and regulatry and Client cmpliance. The DCR prvides cmmunicatin links and quality cntrl between the Client and the Cntractr(s) ding the wrk. DCRs may functin alne r in sme cases prvide a single fcal pint when ther representatives are required t cver the scpe f wrk. The DCR may represent the varius disciplines fund n the jbsite, such as welding inspectrs, dynamic psitining (DP) cnsultants, specialty tl r equipment cnsultants, r diving representatives. Part 2: Definitins ADCI: Assciatin f Diving Cntractrs Internatinal ASOG: Area Activity Specific Operatinal Guideline; A set f peratinal, envirnmental and equipment perfrmance limits fr dynamically psitined (DP) vessels t perate within preestablished parameters fr a specific lcatin and activity.. BSEE: Bureau f Safety Envirnmental Enfrcement Client Representative : A persn, chsen by virtue f training and experience, t be the appinted representative f a Client r cntract hlder with the duties f versight and authrity f the Client n the wrk site. This culd include numerus ther disciplines besides diving. Cmmercial Diving Operatr (CDO): Defined in NPR 46CFR 197-subpart B (aka; Operatr, Client r Cmpany). Diving Client Representative (DCR): An appinted representative f a Client r cntract hlder with the duties f versight and authrity f the Client n the dive wrk site. Fr this dcument we will use Diving Client Representative r the acrnym DCR. IMCA: Internatinal Marine Cntractrs Assciatin NCR: Nn-Cnfrmance Reprt IOGP: Internatinal Oil and Gas Prducers Assciatin OVID: Oil Cmpanies Internatinal Marine Frum-Offshre Vessel Inspectin Database PMS: Planned Maintenance System - A recrd f maintenance and repair t specifically identified equipment thrugh its life. SIMOPs: Simultaneus Operatins SUMS/BUMS: Surface Umbilical Management System; Bell Umbilical Management System Revisin 0 Page 4 f 11 7/14/16

5 Part 3: Regulatry Cnsideratins There are n direct laws that mandate the DCR s respnsibilities and each DCR shuld wrk per the guidance and requirements f their Client Cmpany; hwever, the representative shuld be aware f the fllwing: The US Cast Guard details Persn-in-Charge and Master f Vessel respnsibilities The DCR is nt specifically addressed. Hwever, he/she must knw the chain f cmmand. NPR 46 CFR 197 Subpart B identifies respnsibilities fr the Cmmercial Diving Operatr and by default the Diving Client Representative. BSEE requires individuals be selected wh act as the persn in charge and thse wh are named t have Ultimate Stp Wrk Authrity DCR is nt specifically addressed. Hwever, he/she must knw the chain f cmmand. Industry References Internatinal Oil and Gas Prducer s Assciatin (IOGP) Reprt 431; Diving Wrksite Representative Rles, Respnsibilities and Training, Nv 2009 Internatinal Marine Cntractrs Assciatin (IMCA): IMCA TCPC 12/04; Cmpetence f Client Representatives Part 4: Purpse f the Diving Client Representative (DCR) Cmpetent versight during a diving prject is paramunt t the safe and successful cnclusin f the wrk scpe. Diving is a service that may require utilizatin f many wrk disciplines r types f wrk besides diving interventin. Welding, underwater demlitin, rigging and lifting, dealing with pllutants, vessel lgistics, regulatry issues, permitting, and crdinatin f large segments f a prject are t name but a few f the cnsideratins that can take place n a dive peratin. The DCR prvides n-site representatin fr the Client; prviding a single fcal pint fr n-site cmmunicatin and acts as a direct liaisn between the cmpany and nsite Cntractrs. A DCR will als cnfirm cmpliance t cmpany requirements, cmpetency verificatin f the wrkfrce and adherence t safety and regulatry cnsideratins as well as a quality cntrl mnitr t verify cmpleted wrk is as required. Revisin 0 Page 5 f 11 7/14/16

6 Part 5: Qualificatins f a Diving Client Representative (DCR) Operatr cmpanies may decide the DCR qualificatins apprpriate t their Cmpany. Cnsideratin shuld be taken when selecting a DCR. The DCR will be expected t represent the Client cmpany in all things related t the wrk scpe and shuld be selected based n the requirements f the wrk assignment. It is the respnsibility f the DCR s cntracting cmpany t ensure that the selected DCR has the cmpetency, knwledge, training, and experience based n the prject s requirements. Leadership qualities and persnnel management skills shuld be cnsidered when making the DCR selectin. These qualities greatly cntribute t the success f a prject. A representative that is engaged in the jb is a valuable asset t the prject. The experience level f a Diving Client Rep may vary with the cmplexity f the prject and the expected mde f diving. Experience as a diver r diving supervisr prvides great insight fr the DCR as they represent the Client and interface with the dive Cntractr. The number f prjects and the cmplexity f the prjects that a DCR has participated n as a DCR, a diver r dive supervisr are all just as imprtant as the number f years spent ffshre. The DCR s ffshre experience shuld be in diving, subsea interventin, ffshre cnstructin, and/r marine peratins. It is imprtant that the DCR s diving experience is in the mde f diving prpsed. Fr prjects requiring special disciplines the DCR shuld be able t demnstrate a wrking knwledge in the specific discipline. The DCR shuld prvide a résumé r a Curriculum Vitae (CV) listing all f their qualificatins, ask fr references and refer t these peple fr verificatin f recrds. Jb Specific Skills and Knwledge Verificatin Assessment: All DCR s shuld have adequate skills and knwledge t perfrm their assigned jb duties in a safe and cmpetent manner. This shuld be reviewed annually r as jb duties change. Supprting dcumentatin shuld be maintained n file fr each individual. Qualificatins fr the DCR Knwledge f USCG Diving Regulatins CFR s relative t diving. The candidate shuld understand lcal laws and regulatins. BSEE /BOEM Regulatins Individuals shuld understand where the infrmatin can be fund. They are nt expected t knw the regulatins and best practices frm memry. Safety and Envirnmental Management Systems (SEMS) and SEMS 2. State r Lcal Regulatry Regulatins When Applicable t the Operatr s Lcatin E.g. - Alabama Oil and Gas (AOGB) r Califrnia State Lands Cmmissin (CSLC). Revisin 0 Page 6 f 11 7/14/16

7 Wrking knwledge f Industry Best Practices and Guidelines as applicable t the Operatr ADCI, IMCA, IOGP, DSWG, etc. Leadership Skills Safety Management, Risk Analysis - Training and Experience Individuals shuld be cmpetent in the use f Hazard Identificatin (HazID) studies and Jb Safety Analysis (JSAs). Technical Knwledge f Tls and Equipment Surface Diving r Saturatin System - Equipment Assurance. Assurance Audits/NCR/PMS. Mred and DP vessels (if applicable). Basic knwledge and/r awareness, f a DP vessels peratin and capabilities. Anchring prcedures and guidance s. Vessel Assurance Prcesses OVID, DP Trials, FMEAs. DP diving guidance s, SUMs/BUMs, ASOG, USCG Variance. Special tling fr prjects dredges, winches, pipeline repair clamps, etc. Pssess a current fitness t wrk medical exam - as per Client/Operatr requirements. Understanding f drawings and schematics. Basic cmputer skills. Verbal cmmunicatin skills. Written and dcumentatin skills. The recrds and dcumentatin that are prduced during a prject culd be subpenaed int a curt case. A DCR s lgs are recrds f the prject. They shuld accurately describe the events that tk place n a prject. Details surrunding wrk r incidents shuld be clearly presented with all relevant infrmatin. These specific training areas are required befre wrking fr sme peratrs. Operatr Specific Training Requirements Knwledgeable f Operatr Safety Expectatins r Safety Manual. Operatr specific Dive Standard r Guidance. Operatr guidelines/restrictins fr specific diving tasks. Operatr Permit- t-wrk system. Field Knwledge f the Wrk Site Field maps, pipeline surveys and field lgistics. Platfrm r facility familiarizatin fr SIMOPs and hazards. Revisin 0 Page 7 f 11 7/14/16

8 Part 6: Rles and Respnsibilities f the Diving Client Representative (DCR) Operatr cmpanies may decide the DCR rles and respnsibilities apprpriate t their cmpany. The DCR shall versee the Cntractrs activities t ensure that Client requirements are adhered t and the wrk is perfrmed in accrdance with all drawings, specificatins, prcedures and the scpe f wrk in a safe manner. When pssible, include the DCR in the planning phases f the wrk scpe. Sme f the pre-prject planning activities may include the fllwing: Technical review f prject design/diver install-ability. Wrk scpe definitin, prject required drawings /dcumentatin and prcedure develpment. Cnstructin planning and lgistical supprt. Hazard r Risk Analysis/Hazard Identificatin participatin. Dive Equipment and Vessel - Testing and audit/assurance prcess. Review the Cntractr s emergency respnse/evacuatin plans. During Mbilizatin the DCR shuld assist the Client Prject Manager with the fllwing: Lgistical supprt including equipment/material tracking. Cnducting a Prject Kick-ff meeting with the entire crew prir t ging ffshre. This meeting shuld cver safety and prject expectatins as well as a prject verview. The DCR shuld versee the safe executin f all wrk perfrmed by the Cntractr's persnnel and keep the Client infrmed f all wrk planned and in prgress. Safety shuld be at the frefrnt f all activities and cmmunicatins. The DCR shall wrk with the dive Cntractr t: Verify all equipment cmplies with Client r industry requirements. If applicable, issue r participate in the writing f the Permit t Wrk (PTW) and re-issue as required. Jintly discuss the daily wrk plans with the Offshre Manager r Dive Superintendent and include the Client s Operatins persnnel as needed. Adherence t the Client s SIMOPs plan and prcedures is a critical functin. Cnfirm that the Safe Wrk Plan and its appendices are understd and fllwed by everyne invlved with executing the wrk. Participate in the daily safety meetings with Cntractr persnnel. Participate with the dive crew fr the planning and executin f emergency drills, the DCR shuld encurage and supprt these drills. Observe the drills and afterwards ffer cnstructive criticism f what was bserved and can be learned during the drill. Participate in the Jb Safety Analysis (JSA) with the Cntractr s persnnel. Stp any peratin where the DCR feels an unsafe cnditin exists. Revisin 0 Page 8 f 11 7/14/16

9 Mnitr, inspect, and accept/reject the wrk bth in prgress and as cmpleted by the Cntractr. Mnitr the wrk area t ensure persnnel safety. The DCR shuld be present where the wrk activity is being cmmenced. The DCR shuld maintain a presence n deck t bserve wrk habits and cach if necessary. Practively bserve equipment cnditins and intervene if cnditins warrant t prevent the release f hydrcarbn. Observe Cntractr's wrk habits t verify they are wrking in a safety cnscius manner. Intervene in a psitive manner Offering cnstructive criticism r praise when due. Maintain all prject dcumentatin including cpies f checklists and permits thrughut the duratin f the cnstructin until jb cmpletin. Reprt and dcument near misses and incidents t the Client and assist in initial investigatin as per Client requirements Review and verify the Cntractr s persnnel are trained and certified as required. Prvide daily prgress reprting, cst tracking and prvide infrmatin n wrk activities/plans, safety aspects and schedule. Prvide marine lgistical supprt when necessary including material and equipment tracking. Critical Task Respnsibility A critical task is when the risk level is elevated. During these times the Client representative shuld be at a lcatin that permits interactin with the persnnel supervising the wrk. Examples f this wuld be: During the cutting r discnnectin f a pipeline, tasks invlving differential pressure, underwater burning, lift bag use, deep ditch jetting, heavy lifts etc. Be present in dive cntrl r n deck. Remtely mnitr with audi and visual. Cnfirm that a hld pint is written in the prcedure befre a critical task is perfrmed. Establish a clear cmmunicatin plan with a backup prtcl. Observe the testing f critical equipment prir t it ging in the water. Cnfirm that rigging certificatins and ther required dcumentatin has been checked. Cnsult industry best practice guidelines. Dive Vessel Mred t r alngside Offshre Structures Review the prcedures and equipment t mr vessel alngside r attach t the structure. Understand wrkable weather cnditins and vessel stability limitatins during inclement weather. Respnsible fr SIMOPS and interactin with platfrm. Understand and make the crew aware f all platfrm emergency alarms. Revisin 0 Page 9 f 11 7/14/16

10 Dive Vessel Wrking Remtely Multiple Vessels Review the emergency prcedures and establish cmmunicatin with the clsest manned structure and r helicpter landing site. Establish the prtcl fr Permit t Wrk system prir t mbilizatin. Review mring prcedures and weather limitatins fr mring integrity. Establish a cmmunicatin prtcl between all vessels. Ensure the crdinatin f all vessels in emergency drills. Wrking frm Deepwater TLP / Flater Barge Diving Establish and maintain the SIMOPS prtcl. Interface with platfrm persnnel n equipment placement when required. Equipment may need t meet additinal intrinsically safe / explsive / fire cnditins. Review the mring plan. Understand weather cnditin limitatins fr barge peratins. Participate with the barge peratins persnnel n SIMOPS issues. Additinal site representatin may be needed because f the high activity level n barges. Revisin 0 Page 10 f 11 7/14/16

11 Part 7: Interfacing with the Cntractr Prviding the prject specific infrmatin and dcumentatin t the diving Cntractr is essential t the success f the prject. The DCR is the liaisn/interface between the Cntractr and the Client and shuld be able t present the jb scpe t the crews in a manner that is understd by everyne. The DCR shuld have a gd understanding f and be able t cmmunicate the hazards and ptential SIMOPs at the specific dive lcatin, fr example, the lcatin f firewater intakes r the daily crew-bat schedule. The DCR shuld cmmunicate the Client s 100% cmmitment t SAFETY. A DCR shws this cmmitment by participating in the safety prcess. Attending and participating in daily safety meetings, JSA meetings and pre-dive briefings are paramunt. Leading by example with an integrity and authrity fr all things safety is the key t cmpleting a safe and efficient prject. Cmmunicatin f the specific Client s expectatins t the Diving Cntractr is imprtant due t the vast differences between the Clients. An example f a specific difference wuld be a Clients Wrk Management system; sme Clients use an electrnic system, sme use paper permits, while sme may nt use any at all. Other different systems may include JSA frmats r equipment auditing requirements. Different Clients als may have different paperwrk requirement; daily time sheets, JSAs and dive sheets may be required by sme and nt by thers. The Client Representative shuld be familiar with these differences and be able t clearly cmmunicate them t the Cntractr. Dive Cntractrs appreciate having a knwledgeable DCR invlved with the diving prject. This allws them t cnduct their wrk in a prfessinal manner withut spending time explaining why things are dne a certain way. The DCR shuld be an asset t the Cntractr and wrk tgether fr the verall success f the prject. It is imperative fr the DCR t have diving knwledge and a strng understanding f hw t cmplete the tasks assciated with the prject, but at the same time allws the Cntractr t cnduct their jb safely. A DCR shuld always remember their rle is fr versight, and the dive supervisr has the ultimate respnsibility fr the safety f their crews. Managing a wrksite and prject is imprtant, but a gd dive rep knws nt t verstep his rle and try t micrmanage the diver in the water. Revisin 0 Page 11 f 11 7/14/16