Life-Saving Rules (IOGP Report 459)

REPORT AUGUST 459 2018

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Acknowledgements This report was authored by the Life-Saving Rules Task Force of the IOGP Safety Committee.

Photography used with permission courtesy of © Dutchy/iStockphoto and © Maersk Oil - Photographer Morten Larsen (Front cover) © botulinum21/iStock (Back cover)

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Copyright notice The contents of these pages are © International Association of Oil & Gas Producers. Permission is given to reproduce this report in whole or in part provided (i) that the copyright of IOGP and (ii) the sources are acknowledged. All other rights are reserved. Any other use requires the prior written permission of IOGP. These Terms and Conditions shall be governed by and construed in accordance with the laws of England and Wales. Disputes arising here from shall be exclusively subject to the jurisdiction of the courts of England and Wales.

Life-Saving Rules User Agreement The user accepts that any use of the IOGP Life-Saving Rules shall be on an ‘as is basis’ and that the responsibility for the interpretation and use of the IOGP Life- Saving Rules lies with the user. In no event will the IOGP or any contributor to the development of the IOGP Life-Saving Rules (or an affiliate of such contributor) be liable for (financial or other) damages or losses of any kind whatsoever sustained by any third party arising from the possession, use of, or reliance on, the IOGP Life- Saving Rules. The user further agrees to only use the IOGP Life-Saving Icons and specific accompanying wording un-amended in the form as provided by IOGP.

REPORT AUGUST 459 2018

Revision history

VERSION DATE AMENDMENTS

3.0 August 2018 Major revision

2.0 April 2013 Amendments to safety icon designs

1.0 February 2012 First issued

Contents

1. Foreword 6

2. The Life-Saving Rules 8

3. Implementing the Life-Saving Rules 9 3.1 Fundamental requirements 9 3.2 Lessons learned in rules implementation 10 3.3 The Life-Saving Rules as part of a system 12 3.4 Life-Saving Rules implementation resources 19

4. Data analysis in the revision of the Life-Saving Rules 20

Scope

With the revision of Report 459, IOGP launches a simplified set of Life-Saving Rules to provide workers in the industry with the actions they can take to protect themselves and their colleagues from fatalities. IOGP aims to improve the level of industry-wide adoption across the global oil and gas industry. The reduced number of rules (nine) still cover a similar scope to that of the original 18 Life-Saving Rules: since 2008, 376 lives could have been potentially saved by following the revised IOGP Life-Saving Rules.

IOGP Report 459 introduces the revised IOGP Life-Saving Rules, provides implementation guidance and the background data analysis. Additional implementation materials are available from https://www.iogp.org/life-savingrules.

1. Foreword

IOGP Member companies recognise the value of providing clear, simple, and consistent information regarding risks in the workplace and the proper use of barriers and safeguards to protect the workforce. In 2010 IOGP published a set of Life-Saving Rules to mitigate risk and reduce fatalities in the oil and gas industry. These were derived from analysis data reported to IOGP: 1484 fatal incidents (1991-2010) and 1173 high potential events (2000-2010). Following these simple rules could have prevented around 70% of these fatalities.

While member companies and others benefit from implementing their own programmes, there is greater clarity and effectiveness to be gained in standardising Life-Saving Rules across the industry. Over 80% of the workforce, and around 80% of fatalities, are contractor employees (Fig 1). Contractors are required to learn numerous process requirements for each client, even though the operating practices, activities, and risks are fundamentally the same.

5,000,000 120

100 4,000,000

workhours ('000) 80 3,000,000

Fatalities 60 2,000,000 40

1,000,000 20

0 0 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Hours company thousands Hours contractor thousands

Total company fatalities Total contractor fatalities

Figure 1: Fatalities reported to IOGP (2008-2017), and associated workhours

In 2018, IOGP re-examined the applicability of the 2010 Rules against the most recent fatality data. With the revision of this report, IOGP launches a simplified set of Life-Saving Rules (Figure 2) to provide workers in the industry with the actions they can take to protect themselves and their colleagues from fatalities. With a reduced number of rules (nine reduced from 18), but still covering a similar scope, IOGP aims to improve the level of industry-wide adoption across the global oil and

gas industry. Since 2008, 376 lives could have been potentially saved by following the revised IOGP Life-Saving Rules (See Appendix A for data analysis, Rule development, and applicability).

The IOGP Life-Saving Rules are not intended to address all risks and hazards in the oil and gas industry; they are meant to draw attention to the activities most likely to lead to a fatality, and the life-saving actions over which an individual has control. The Rules are intended to support existing company management systems. They are not intended to replace company management systems, policies, safety training programmes, operating procedures, or work instructions, and in fact rely on this framework being in place.

Standardisation of Life-Saving Rules across the oil and gas industry: • Enables better transfer of knowledge, experience and lessons learned • Increases individual awareness ownership of critical safeguards that prevent fatalities • Is a step towards an industry-wide common safety language • Improves clarity and allows consistent use by contractors and operators doing similar work across the world

To achieve the benefits of standardisation and prevent workforce fatalities, all 9 Rules should be adopted as written and not be modified or substituted; organisations should: • Adopt the IOGP Life-Saving Rules if they currently have no equivalent program • Transition to the revised IOGP Life-Saving Rules if using a different set of rules or if using the previous set of IOGP rules • Encourage joint ventures and partners to implement the revised IOGP Life- Saving Rules • Accept and encourage contractor use of the revised IOGP Life-Saving Rules

This document provides an introduction to the revised Rules, data analysis, and implementation guidance. Additional implementation resources are available from the IOGP website.

2. The Life-Saving Rules

The nine Life-Saving Rules are shown in Figure 2. These Rules focus on the activities which, through rigorous data analysis, have been shown to most likely result in fatalities. Each Rule consists of an icon and simple life-saving actions individuals can take to prevent a work related fatality.

Bypassing Safety Controls Confined Space Driving Obtain authorisation Obtain authorisation Follow safe driving before overriding before entering a rules or disabling safety confined space • I always wear a controls • I confirm energy seatbelt • I understand and use safety- sources are isolated • I do not exceed the speed limit, critical equipment and procedures • I confirm the atmosphere has been and reduce my speed for road which apply to my task tested and is monitored conditions • I obtain authorisation before: • I check and use my breathing • I do not use phones or operate – disabling or overriding safety apparatus when required devices while driving equipment • I confirm there is an attendant • I am fit, rested and fully alert while – deviating from procedures standing by driving – crossing a barrier • I confirm a rescue plan is in place • I follow journey management • I obtain authorisation to enter

Energy Isolation Hot Work Line of Fire Verify isolation and Control flammables Keep yourself and zero energy before and ignition sources others out of the work begins line of fire 0

• I identify and control • I have identified all ignition sources • I position myself to energy sources • Before starting any hot work: avoid: • I confirm that hazardous energy – I confirm flammable material – moving objects sources have been isolated, has been removed or isolated – vehicles locked, and tagged – I obtain authorisation – pressure releases • I have checked there is zero • Before starting hot work in a – dropped objects energy and tested for residual hazardous area I confirm: • I establish and obey barriers and or stored energy – a gas test has been completed exclusion zones – gas will be monitored continually • I take action to secure loose objects and report potential dropped objects

Safe Mechanical Lifting Work Authorisation Working at Height Plan lifting Work with a valid Protect yourself operations and permit when against a fall when control the area required working at height • I confirm that the • I have confirmed if • I inspect my fall equipment and load a permit is required protection equipment have been inspected and • I am authorised to perform before use are fit for purpose the work • I secure tools and work materials • I only operate equipment that I am • I understand the permit to prevent dropped objects qualified to use • I have confirmed that hazards are • I tie off 100% to approved anchor • I establish and obey barriers and controlled and it is safe to start points while outside a protected exclusion zones • I stop and reassess if conditions area • I never walk under a suspended change load

Figure 2: The 9 IOGP Life-Saving Rules

3. Implementing the Life-Saving Rules Standardisation of Life-Saving Rules simplifies training, aids compliance and understanding of critical safeguards, and helps transfer of experience and lessons learned. Effective industry wide implementation requires collaboration between operators, contractors, and subcontractors.

To achieve the benefits of standardisation, all 9 Rules should be adopted as written and not be modified or substituted.

It is accepted that operational risk profiles may differ, and the Rules may not address all an organisation’s fatality risks. In this case, companies are encouraged to manage these other risks through existing management systems or in other ways, e.g., campaigns, training, and workforce engagement, rather than creating additional Life-Saving Rules.

It is important that the Rules are understood by all individuals, their supervisors, and their leaders, and that management have created the conditions necessary to enable everyone to follow the Rules.

3.1 Fundamental requirements Successful implementation of the Rules requires the following, as a minimum: • Organisations have an existing safety management system, containing the following supporting policies, processes and systems: –– Worker Fitness for Duty including a drug and alcohol policy –– Contractor (and subcontractor) Management program including bridging arrangements, if applicable –– Journey Management program –– Safe systems of work including permit to work, and energy isolation –– Management of change –– Hazard identification and awareness, risk assessment and safeguard management –– Field (self) verification providing checking and verification of critical tasks • A commitment that work does not start until all individuals involved are aware of and can confirm they can follow the Life-Saving Rules that are relevant to that work. • A requirement that work is not conducted without a pre-job risk assessment and a safety discussion, such as a toolbox talk, appropriate for the level of risk. • Organisations define which procedures and equipment are safety critical and ensure impacted workers clearly understand what these are. • Personnel are trained and competent for the work they conduct. • Equipment is fit for purpose, properly maintained, and in working condition.

• Before work starts, there are emergency response plans in place that have been developed from a review of potential emergency scenarios, which have suitable and sufficient resources available, and which are periodically drilled/tested. • Everyone is authorised to intervene or stop work without adverse consequences if they are in any doubt about the safety of an activity. • Suitable personal protective equipment is provided and worn in accordance with the requirements identified by the risk assessment and worksite policies.

3.2 Lessons learned in rules implementation Senior Management commitment is essential to successfully roll-out the Life- Saving Rules. The following steps for effective implementation are based on the experience of IOGP member companies that have successfully implemented Life- Saving Rules equivalent programmes: • Conduct a risk assessment of your organisation’s activities and review historical data related to fatalities and high potential events within your own organisation (both company employee and contractors) and determine how these align with the Life-Saving Rules. • Develop a business case/change management programme and discuss with leadership of both your organisation and your contractors and subcontractors to ensure commitment to implement the Life-Saving Rules. • Ensure implementation, use and compliance are owned by line-management (e.g. maintenance, facilities, operations, etc.) and supported by HSE professionals. • Develop a communications and roll-out plan for the implementation of the Life-Saving Rules (stakeholder mapping, communications plan, accountability and compliance strategy in consultation with legal, supply chain and human resources departments). • Develop performance monitoring methods to determine the effective implementation and ongoing use of the Life-Saving Rules. • Use the IOGP Life-Saving Rules roll-out and engagement materials.

Helping people follow the Rules Experience from member companies shows that the Life-Saving Rules, when consistently applied, prevent fatalities. Simply communicating the Rules and then holding people accountable for following them is not enough for effective implementation.

To enable individuals to follow the Life-Saving Rules, organisations need first to provide the right conditions:

• Everyone needs to know the Rules, understand their value, and what following the Rules means for their role. • The physical workplace conditions required to be able to follow the Rules need to present (e.g., certified anchor points provided for all work at height, vehicles equipped with seatbelts) • There need to be clear expectations set and supported from the top of the organisation that work must not start unless the Rules can be followed, and these must be visible to the workforce, by, for example, ensuring physical workplace conditions are present. • Everyone must be given the authority and be encouraged to stop work and intervene if they observe a Life-Saving Rule (or indeed any other unsafe activity) actually, or potentially, not being followed. Proactive intervention may be the last opportunity to prevent injury or fatality.

The focus on personal accountability for following the Rules is about care and concern for the individual and the well-being of everyone who works in our industry.

If a Life-Saving Rule is not followed, organisations need to determine the reason to learn and improve workplace conditions, whether it resulted in undesirable consequences or not. Organisations have a role in positively reinforcing an open reporting culture, i.e. for self-reported errors and peer-to-peer interventions and responding appropriately where cases of ‘non-reporting’ are found. The intent is to understand what conditions and environment meant that a Rule was not followed, and drove people to do what they did, so that lessons can be identified, applied and learned.

If a Life-Saving Rule is not followed, despite organisations providing all the necessary enabling conditions, then consequence management may have a place. This might be relevant for the individual, or for those responsible for providing the enabling conditions. However, companies should also consider that such occasions are rare and should always follow their internal processes for dealing with such matters.

An IOGP Member recently looked at 353 of their incidents that had been tagged as a potential human violation (not necessarily related to a Life-Saving Rule). Of these, system-level issues were identified as causal in 90% of cases; these issues include unclear procedures (23%), capability and resources (30%) and mistakes due to labelling, alarms or tool issues (21%). That means that only a very small proportion of all incidents were actual violations1. This experience matches that of other IOGP Members, and that of other industrial sectors (in the construction industry, for example, human violations account for only 5% of incidents2). IOGP strongly encourages all organisations considering applying

1 F.K. Bitar et al. ‘From individual behaviour to system weaknesses: The re-design of the Just Culture process in an international energy company. A case study’. Journal of Loss Prevention in the Process Industries 55, 2018, pp. 267-282. United Kingdom Health and Safety Executive. Causal Factors in construction accidents. HSE Books, Norwich, 2003.

consequence management for not following a Life-Saving Rule to be sure that the person deliberately intended not to follow a Rule despite being given all enabling conditions and the leadership and supervisory support to do so.

Continued engagement and integration The introduction of the Life-Saving Rules to a workforce is not by itself sufficient to produce the tangible benefits of standardisation. An ongoing effort is required to drive integration and conformance with a dynamic global workforce. Organisations should use the tools available within their existing management systems to continuously improve conformance to the Life-Saving Rules. Examples may include: • Awareness campaigns • Refresher training • Leadership site visits • Positive recognition of conformance and interventions • Internal and external feedback for improvement of compliance • Integration into contractual agreements • Use of IOGP engagement resources

Further reading Please refer to the following published technical papers for case studies on implementing the Life-Saving Rules, refreshing the programme, and a comparative study of various companies’ programs and implementation approaches: • SPE-157465-MS: A Major Oil Company’s Approach to Significantly Reduce Fatal Incidents • SPE-179289-MS: Re-Energising the Life-Saving Rules • The APPEA Journal 2017, 57, 41–48: Golden safety rules: are they keeping us safe?

3.3 The