BSEE Safety Alert - 496 - Misidentification of Corrosion Hazard Results in High Potential Event

SAFETY ALERT

Safety Alert No. 496 Contact: bseepublicaffairs@bsee.gov March 6, 2025 Phone: (800) 200-4853

BSEE Investigation: Failure to Properly Identify and Restrict Access to Faulty Grating Poses Serious Risk of Worker Injury or Fatality

Figure 1: Faulty grating covered in scaffold Figure 2: Operator’s body position at time of boards (right). incident.

The Bureau of Safety and Environmental Enforcement (BSEE) recently investigated an incident at a Gulf production facility that could potentially have resulted in a worker injury or fatality. During a facility walkthrough, operator personnel had identified grating near a skid as a hazard due to corrosion and installed hard barricades to prevent access. However, shortly thereafter, operator personnel installed two scaffolding boards on top of the previously identified grating hazard and removed the hard barricades so work could proceed (Figure 1). A worker tasked with installing a pump in the skid above the unsafe grating was kneeling on the scaffolding boards with the tip of his boots resting on the grating when the corroded section of grating suddenly gave way (Figure 2). The worker was able to quickly react, grabbing hold of a nearby section of piping to support himself. Upon further inspection, the worker later realized the 36 by 36-inch piece of grating beneath the scaffolding boards he was kneeling on had collapsed and fallen into the water.

Following the incident, operator personnel placed additional boards over the resulting open hole in the grating but did not install hard barricades or identify the area as a hazard.

Hard barricades were later reinstalled, and the grating was subsequently replaced.

BSEE recommends that operators and their contractors, where appropriate, do the following:

• Review BSEE Notice to Lessees No. 2024-N03 Restricting Access to Unsafe Areas Due to Corrosion NOTE: Lessees and Operators are required to comply with 30 CFR 250.107, What must I do to protect health, safety, property, and the environment by “maintaining all equipment and work areas in a safe condition.” 30 CFR 250.107(a)(2).

• Review in conjunction with this Safety Alert, BSEE Safety Alert 416 - Investigation into Grating Failure Fatality Reveals Deficiencies, and BSEE Safety Alert 365 - BSEE Identified Grating and Open Hole Hazards During Risk Based Inspections.

• Conduct a thorough walkthrough of the facility to identify open holes and check that potentially unsafe surfaces can safely support the weight of individuals working on or around them. If such an area or open hole is identified, ensure it has been properly barricaded and/or covered.

• Review internal and contractor Safe Work Practices to ensure that operations personnel clearly understand the requirements and expectations for the use of barricades. Effective hard barricades should be rigid, immovable structures that create a barrier to restrict access to hazardous or unsafe areas.

• Review and adhere to 30 CFR 250.1909 (h): Ensure that management of safety hazards and environmental impacts is an integral part of the design, construction, maintenance, operation, and monitoring of each facility.

• Review and adhere to 30 CFR 250.1914 (f): You must inform your contractors of any known hazards at the facility they are working on, including but not limited to fires, explosions, slips, trips, falls, other injuries, and hazards associated with lifting operations.

– BSEE –

A Safety Alert is a tool used by BSEE to inform the offshore oil and gas industry of the circumstances surrounding a potential safety issue. It also contains recommendations that could assist avoiding potential incidents on the Outer Continental Shelf.

Category: General; Grating/Open Holes