General Internal HSE Audit thAban VI, 17 -18th

General Internal HSE Audit – Aban VI, 17th -18th – February 2010

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56- A tripod and winch type SALA was found in one of the leg well areas. Crew need to use this

equipment. All crews to be educated in its assembly and use.

57- Currently the rig is using a diesel forklift close to a zone 1/ Hazardous area. This needs to be

reassessed and forklift operation area demarcated away from this area.

58- Crew to be trained in fork lift operation and list of approved certified users posted at the site.

Crew to review TRM 105.25, for fork lift operations.

Emergency generator room to be maintained and

equipment kept clean.

Generator to be run as per schedule and logged

and documentation maintained.

New „T‟ cards to be ordered by the rig as existing

ones are deformed.

A daily POB sheet is to be maintained at each

muster station to enable verification of head count

during drills/ actual eventuality.


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Emergency Systems

59- Alarm systems in various areas of the rig should have identification as to what type of alarm.

60- All hatches to be kept closed especiallyCo2 protected areas like pit rooms, engine room etc.

61- All hatches to be marked as to the space they open into i.e. PUMP ROOM, ENGINE ROOM, SACK

ROOM ETC. None of the existing doors / hatches are marked as such.

62- Home-made door closers with pulley and counterweight rig-up to be replaced with purpose built

door closers


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63- Openings in gratings which could lead to trips, falls, injuries etc. to be secured at all levels.

64- Paint locker fan switch was not marked and was switched off. When finally identified and switched

on, it made a tremendous noise and had to be switched off again.

Exhaust fan switch and fire extinguishing apparatus to be labeled for easy identification.

65- Mixing of paint should not be done inside the locker.

The paint locker is only for paint storage. Mixing of paint should be done in an open well ventilated

area.

Open paint cans and thinner cans should be removed and disposed accordingly. The thinner fumes and

open paint cans are a fire hazard. Only closed / sealed paint and thinner cans are to be stored.

Used Paint brushes, rollers and soak cans should be stored separately. Below is a recommended RTC unit

which can be used for storing used paints, soak brushes/rollers and as a paint mixing platform.

Crew to review TRM 105.09, for Paint storage.

PPE box is to be provided inside/ near the paint locker for crew to store PPE.


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As per SOLAS Chapter II-2

6.3.1 Paint lockers shall be protected by:

6.3.1.1 a carbon dioxide system, designed to give a minimum volume of free gas equal to 40%

of the gross volume of the protected space;

6.3.1.2 a dry powder system, designed for at least 0.5 kg powder/m³

6.3.1.3 a water spraying or sprinkler system, designed for 5 l/m² min. Water spraying systems

may be connected to the fire main of the ship; or

6.3.1.4 a system providing equivalent protection, as determined by the Administration.

In all cases, the system shall be operable from outside the protected space.

66- Rig needs to order a purpose built fiberglass storage box for the Billy Pugh basket. Rig also needs

to order the Billy Pugh X-904 rigid basket and a cover for the same, ordering info provided below.

this one for the X-904


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for collapsible billy Pugh

67- Drums should not be cut open to be used for any other purpose. Many plastic and metal containers

were seen cut and in use as bins, bucket‟s etc. Proper color coded purpose built bins/ containers

should be ordered for different uses and types of hazardous and non hazardous waste.

For the transportation of drums, a drum lifter is recommended as in safety catalogue, Pg 97.

68- The work basket in use needs to be replaced with a proper certified workbasket as recommended

in the safety catalogue. This also needs to be inspected and color coded bi-annually.

Information on approved work basket is available in the safety catalogue Pg 109.

Fork Lift operation..

69- Operation of forklift should be restricted only to certified operators and a list of certified crew should

be posted in the area. A designated parking / charging area should be demarcated for the forklift.

An expanded metal guard to be installed between the driver and the forks.


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Garbage management

70- A container was found on deck with all types of waste piled up in one heap. This included metals,

filters, waste paint cans and other general waste. This should be discouraged and waste

segregation should be followed and appropriate waste skips should be provided for the disposal.

Refer Policy ENV 170.00 and ENV 180.00 on waste segregation and disposal.

71- Burn basket is being used for burning a mix of garbage over the side. Rig to review the

Garbage Management Policy and comply. Management to stress to the client the

requirement of sending in hazardous / non hazardous garbage to shore for disposal.

72- Water bottles were found in various areas of the rig filled with oil, diesel, thinner, soap etc. This

practice should be stopped immediately and only purpose built containers with proper labels as to

the contents must be used.

Spill Containment & segregation.

73- Crew should be discouraged from keeping any type of chemicals, oils, waste water etc directly over

the grating where it can enter the water and cause an environmental issue. Crews to be educated

towards a ZERO discharge policy where no waste is thrown over-board.


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74- Various oil and chemical drums are stored in various parts of the rig without any spill containment.

The rig needs to designate a oil/ chemical storage area that is bunded for spill containment and

designated as such. Storage of oil/ chemical drums in various areas poses a spill and a fire hazard.

Information on approved spill containment available in Safety catalogue on pg 98

Spill Kits

75- Spill kits should be designated in areas with potential spill hazards and these kits should be

numbered and listed for weekly inspection.

Spill kits were found almost empty and others were used as storage boxes for other equipment. A

list of items inside should be posted on the inside of the lid and the kit should be kept sealed. Crew

to be educated to used it only for spills.

Information for ordering spill containment equipment is available in the safety catalogue, Pg 96


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Environmentally Sensitive Valves and Drains (ESVD)

76- All ESVD‟s should be identified and kept locked and should be operated under a Permit To Work.

.

As an example the ESVD list has been attached here.

Padlock Isolation Cert No. Valve ID Valve Type Valve Function Valve Location Contents

1 I 000583(19-Jan-10) OF 001 3” Gate Fuel Oil Bunker Port Loading Station Fuel Oil

2 I 000583(19-Jan-10) OF 002 3” Gate Fuel Oil Bunker Starboard Loading

Station

Fuel Oil

3 I 000583(19-Jan-10) OB 004 4” Butterfly Base Oil Bunker Port Loading Station Base Oil

4 I 000583(19-Jan-10) OB 005 4” Butterfly Base Oil Bunker Starboard Loading

Station

Base Oil

5 I 000583(19-Jan-10) ML 097 6” Butterfly LP Mud Bunker /

Discharge

Port Loading Station Drilling Fluids

6 I 000583(19-Jan-10) ML 098 6” Butterfly LP Mud Bunker /

Discharge

Starboard Loading

Station

Drilling Fluids

7 I 000583(19-Jan-10) WL 105 4” Butterfly Bilge Port Loading Station Oily Water

8 I 000583(19-Jan-10) WL 106 4” Butterfly Bilge Starboard Loading

Station

Oily Water

9 I 000584(19-Jan-10) DQ 001 2” Gate Sanitary Water Port Loading Station Grey Water

10 I 000584(19-Jan-10) DQ 002 2” Gate Sanitary Water Starboard Loading

Station

Grey Water

11 I 000584(19-Jan-10) ML 157 6” Butterfly Brine Port Loading Station Drilling Fluids

12 I 000584(19-Jan-10) ML 158 6” Butterfly Brine Starboard Loading

Station

Drilling Fluids

13 I 000584(19-Jan-10) DQ 010 4” Gate Grey Water Overboard Starboard Auxiliary

Machine

Grey Water

14 I 000584(19-Jan-10) OF 027 1” Ball Fuel Oil Port Aft Pedestal

Crane

Fuel Oil

15 I 000584(19-Jan-10) OF 039 1” Ball Fuel Oil Port Forward

Pedestal Crane

Fuel Oil


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16 I 000584(19-Jan-10) OF 047 1” Ball Fuel Oil Starboard Pedestal

Crane

Fuel Oil

17 I 000585(19-Jan-10) OF 032 1” Ball Fuel Oil Cement Unit Fuel Oil

18 I 000585(19-Jan-10) OF 036 1” Ball Fuel Oil Well Logging Unit Fuel Oil

19 I 000585(19-Jan-10) DD 008 6” Three Way

Ball

Helideck Drain Under Heli Fuel

Platform

Heli Fuel

20 I 000585(19-Jan-10) WB 023 12” Butterfly Bilge Holding Tank #18-C Drilling Fluids

21 I 000585(19-Jan-10) WL 087 2” Ball Oily Water Separator Engine Room Oily Water

22 I 000585(19-Jan-10) WL 086 2” Ball Oily Water Separator Engine Room Oily Water

23 I 000585(19-Jan-10) MP 037 3” Butterfly Trip Tank Dump #1 Starboard Cantilever

Beam

Drilling Fluids

24 I 000585(19-Jan-10) MP 038 3” Butterfly Trip Tank Dump #2 Starboard Cantilever

Beam

Drilling Fluids

25 I 000586(19-Jan-10) DD 012 3” Butterfly Skimmer Tank #1 Starboard Cantilever

Beam

Drilling Fluids

26 I 000586(19-Jan-10) DD 013 3” Butterfly Skimmer Tank #2 Starboard Cantilever

Beam

Drilling Fluids

27 I 000586(19-Jan-10) OL 006 1 ½ “ Ditto Dirty Oil Discharge Port Main Deck Waste Oil

28 I 000586(19-Jan-10) MP 046 12” Gate Shale Shaker Overboard Under Shaker House Drilling Fluids

29 I 000586(19-Jan-10) MP 048 6” Butterfly Cutting Sand Trap

Dump

Under Shaker House Drilling Fluids

30 I 000586(19-Jan-10) ML 183 6” Butterfly Mud To Centrifuge Under Shaker House Drilling Fluids

31 I 000586(19-Jan-10) ML 182 6” Butterfly Mud Dump To Trough Under Shaker House Drilling Fluids

32 I 000586(19-Jan-10) DD 003 12” Butterfly Discharge Overboard Starboard Aft Main

Deck

Deck Discharge

33 I 000587(19-Jan-10) Nil 3’ Butterfly From Sand Trap #5

Below D-Desilter


34 I 000587(19-Jan-10) Nil 3” Butterfly From Sand Trap #5

Below Desilter


Ordering Information for Mechanical lock out devices


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Nitrogen Gas cylinders

77- Nitrogen cylinders should be inspected for Oxygen content as any amount of oxygen in these

cylinders could be disastrous. This testing should be recorded and logged for each cylinder and

before each use. This test can be done by the BW Gas-Alert Max detector and a special regulator

fitting is required for this test which is shown above. The rig should order at least TWO of these

regulators.

Refer Policy SAF 361.00

78- Compressed gas cylinders are to have a purpose built rack. The rig will need at least two portable

racks for Oxy- acetylene cylinders. Rope is not to be used as a securing means for these cylinders.

Store cylinders upright and secured in position with a chain, cable or bar. They have to have an

assigned space for storage.

Oxygen cylinders shall be placed a minimum of twenty feet (6.1 meters) apart from flammable gas

cylinders (acetylene, carbides, etc.) as well as highly combustible materials (oil, grease, etc.). If

stored less than 20 feet (6.1 meters) apart, they must be separated by a non-combustible barrier at

least five feet (1.5 meters) high with a fire resistance of at least one half hour when subjected to an

open flame.

Flash back arrestors and back flow check valves must always be used

This regulator is the SP2112

with CGA 580 Nitrogen fitting.

This regulator should be used

along with the BW Gas alert max

detector for this testing. Any other

regulators should be approved by

the manufacturer for the testing of

Nitrogen bottles.


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79- Freon/ R-22 bottles should be controlled and they should be stored in a designated area. A record

of their use and recovery should be logged.

80- Gloves are seen disposed all over the rig areas. Crew should be educated to ensure proper

disposal of these gloves.

81- Fire plan is present on each level of the accommodation. Updated plans to be provided to replace

the old plans showing previous company ownership logo.


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82- The rig has at present very poor quality of life saving equipment like ropes and flotation lights for

ring buoy. These have to be replaced with standard equipment provided in the safety catalogue.

Information for both these items is available in the Safety Catalogue Pg 100 & 101.

Batteries for the ACR approved lights are to be ordered separately

Battery Type is 6 Volt, Lantern Style battery. NEDA No 915, 915AC, 908 or 908AC

and / or IEC # 4R25 or 4R25Y

83- Life jackets and life vests should have the vessel name and reflectors. All life saving equipment

should be listed and numbered for easy inspection.

84- PPE and safety equipment like lanyards and safety belts should be kept in a designated areas and

not stored with heavy equipment

PPE boxes should be provided for crew to store their PPE in various areas of the rig.

85- Emergency equipment like eyewash stations should be kept clear and clean at all times. Caps to

be provided for the nozzles. Foot pedal was not functional on this one at the mixing hopper.

Water filters need to be installed on all eye wash stations.


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86- Portable eye wash & Lens cleaning stations should be listed for frequent inspection, kept clean

and solution changed. One bottle as seen below was outdated and covered with dirt.

87- Service and 3rd part crew including catering company crew to have full PPE on while on main deck.

Full sleeved coverall, gloves, steel toed boots and safety glasses are a minimum requirement

outside the accommodation.

88- Hearing protection to be provided outside all high noise areas. Earplug dispensers to be installed at

both entry points to machinery spaces and areas like engine room, pump room etc.

89- Un-controlled use of nylon straps should be avoided. Nylon straps should only be used under a

PTW. Review Policy SAF 360.00 on synthetic web slings


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90- All vertical ladders to be provided with a Lad safe device.

91- Alluminium ladders are not allowed on the rig. Home made ladders are also not allowed to be used

on the rig. Rig to order approved ladders as per safety catalogue.

92- Engine room

Catch pans below the engines in the engine room have stagnated oil in them. This is a hazardous

area and should be kept free of such flammables. Catch pans should be kept clean and clear at all

times. This is also a fire hazard in this environment.


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93- One hose with a catch bottle was found hanging over one engine. One oil tank had a leak in the

pipe connection and needs to be fixed.

94- Fire fighting devices like hoses and fire manifolds to be well maintained, Hoses kept clean, lines

frequently flushed. All fire hose points inside and outside accommodation to be tagged and

inspected monthly.

95- Spare hoses and nozzles to be provided for crew for general use. Dedicated fire fighting hoses and

nozzles are not to be used for general purpose like at shakers/ filling casing.

96- Fire monitors to be flushed at frequent intervals and tagged for inspection


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Area around helideck monitors to be kept clear. Currently exercise equipment is cluttered around

the monitor on port side. There is also a makeshift exercise machine using scaffolding pipe. This

should be removed and a proper exercise area and equipment be provided if needed.

97- All fire extinguishers to be listed, monthly inspected and tagged.

98- The Heli-deck foam system line up should be explained to the persons responsible for this

operation and a schematic displayed at the site showing the valve line-up for the foam monitors.

Training on the foam line-up to the monitor and how to activate should be conducted.

99- Frequent drills to be conducted and all equipment maintained in optimum readiness for use.

Crew to refer Policy ISM 801.00 on Emergency Preparedness

One extinguisher #37, found

missing from its location. Crew to

be educated to use dedicated fire

extinguishers for fire fighting only.

Seperate fire extinguishers to be

provided for general purpose like

firre watch etc.


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Galley and accommodation

100- Lights inside the vent, over the hot plates in the galley were not working. Maintenance crew

to identify and rectify.

101- Ice machine in the galley is being used as a storage cabinet. This need to be repaired and

put in use or another one supplied for crew use.

102- Discussed with camp-boss and HSE the requirement of changing out oil in deep fryer .

103- Fire extinguisher stands not to be used as equipment stands.

104- Fire blanket in the galley was found to be expired with dirt, grease and grime on it and could

not be pulled out of the case. This is emergency equipment for crew use and must be inspected

regularly and maintained.

105- Food is not to be stored next to bins. Proper bins with lids to be provided for galley and

general use. Frequent routine checks to be done by Medic / HSE to ensure proper hygiene

procedures are maintained. Review TRM 104.01/02/03/05/11/13 &19 with camp-boss

106- Galley and mess flooring is very old and worn out and cracked in places. Rig management

needs to look into refurbishing the flooring.


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107- Camp boss room is being used as a partial storage area. Rig management needs to look at

the possibility of providing extra storage space outside, possibly at the bow main deck in the form

of fiberglass cabinets.

108- There is also water leakage/ seepage at corners and some areas of the galley.

109- Food processor cap is cracked and needs to be replaced. Galley crew to be provided with

safe equipment to work with.

110- Stainless steel gloves for meat and fish and Kevlar cutting gloves for vegetables should be

provided to galley crew..

111- AED defibrillator pads have expired and there are no good pads available for use. Pads are

on order and should be procured as a priority. The AED battery also shows an expiry date of 2008.

Two batteries to be ordered, one for AED use and one spare. This is critical equipment and should

be inspected and maintained as such. Weekly test checks must be run on the AED and logged.

Medic and HSE/ SMO to review Policy, HLT 100.00/ 200.00/ 220.00 and 300.00.

Miscellaneous

112- All electrical switchboard rooms to be provided with emergency electrical equipment like high

voltage gloves, boots and a fiberglass rescue stick. Ordering information is as provided below.


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113- The rig needs a SPIDER basket for access to areas at-height which are not accessible by

cranes. The ordering information is provided below. Spare cable spool should also be ordered as

this is equipment for personnel hoisting and a spare cable should be available.

114- Tripod with complete Emergency Rescue system is required, one kit for use on main deck

and one kit below deck. This kit should include two winch type SALA blocks for each tripod. Crews

should be trained in the assembly and use of the tripod system.


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115- Individual Tool Spiders to be ordered and used with smaller hand tools while working

overhead.

116- BW Gas Alert Max, 04 No‟s will be needed on the rig where two can be put in service and

two kept as spare. This is critical equipment and the rig must have spare detectors. The small clip-

on personal detectors are generally supplied by the clients in H2S locations and they need not be

ordered by the rig for H2S applications, however the rig should have sufficient personnel clip-on

detectors for confined space entry work.. Crew should be trained in the use of this equipment.

Course needed- “Authorized Gas tester” and “Confined space entry and Rescue”.

117- Use of Grinders, chop-saws, Drill press etc to be controlled and preferably this equipment to

be locked out to prevent use by unauthorized persons. Tampering of this equipment by removing

protective shields or adjusting guards to fit larger grinding material to be discouraged.

PPE like Face shield to be provided at each of these stations.

Crew to review TRM 103.03 on Machine shop equipment

118- The complete eye wash stations with shower should be as a minimum installed in the

following locations. 1-Sack room 2 - Rig Floor 3- Pit room 4 -Shaker deck 5-Cement unit


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119- Rope is not to be used as a tag line. The industry has moved away from using rope as Tag-

lines as it can get snagged and has caused many incidents. Tangle free tag lines are now available

in the market and these should be ordered. As a minimum at least six of each length (15‟- 20‟)

should be ordered. Two tag lines should be used for ALL lifts.

Ordering information is available on page 108 of the safety catalogue.

120- Spill containment is a major concern with many clients and work locations and one aspect is

assigned bunded Storage areas for different type of liquids. The rig should have dedicated storage

areas for oil drums, grease and other such environmentally hazardous substances. These areas

should be marked as such and have a contained area with a bunding around it and spill prevention

equipment in this area. Currently these drums are being stored in different areas of the rig with no

containment.

Spill containment information is available in the safety catalogue on Pg.98

121- Lock-out-Tag 0ut, procedures were not evidenced as being followed as per requirements of

Policy SAF 320.00. There were locks installed on panels with no long term isolations in place as

per the policy. The rig management needs to implement this policy in a strict manner. Only

electrically qualified persons assigned by the OIM should be authorized to carry out electrical Lock

outs.

Mechanical lock outs should also be used on bulk lines/ pressure lines.

122- Load test and MPI of lifting gear needs to be done and this should be followed as a minimum

bi-annually by a certified third party. A lifting gear locker and quarantine locker should be provided

so that the equipment can be stored and damaged equipment or equipment that needs certifying

can be quarantined.

123- It is recommended that Man-riders on rig floor are equipped with a nitrogen bottle

emergency release system as a back-up in case of rig air failure.

124- Prescription safety glasses should be made available to all crew requiring them as per

Policy SAF 540.00 Eye Protection Program.

125- Marine Operations procedure MAR 505.00 on Hydrocarbon transfer to be reviewed by

rig

126- The rig will need its own scaffolding system. The Layher Modular scaffolding is

recommended as it is a very easy to install scaffolding system and has no clamps. A single

scaffolding of 3 meters can be installed by one person in about 10 minutes.

127- Sack room/ Pit room needs a designated area marked for corrosive chemicals. An area to be

designated and assigned as such. Currently the Caustic buckets are stored in the pit room and the

area is not demarcated. Empty caustic containers/sacks should be discarded as hazardous waste

and not re-used.

128- The Management Of Change Policy and procedure to be used by the rig for any structural

changes/ modification to the rig. This should also be used for updating Policy/ procedure

requirements. Crew to Review Policy ISM 900.00 on Management OF Change.

129- Documentation- Policy documents displayed on the rig inside the accommodation are

out dated. They all show September 2001. ALL these documents need to be updated and

replaced.


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Rig to constantly review the Aban intranet management system and use only updated documents

from all activities.

130- SMART card participation on the rig is very minimal. Rig senior management needs to encourage involvement of all crew and stress on the supervisors to lead by example. Almost all issues in this report may be considered a SMART card observation. Supervisors to train their crew to identify these and other issues and rectify them. SMART cards help in developing not only a safe working environment but also lead to a discussion with crews and hence serve as a learning process for all.

Crew to review SAF 112.00 on Behavioral based Safety Program.

131- Some MSDS sheets available with the rig are outdated. Rig to review all MSDS sheets and ensure that they are less than five years old. Mud engineers to provide updated MSDS for all chemicals used.

132- A list of General Operating Procedures is available on the company intranet and this should

be used by the rig as a guideline for their drilling operations. A Task Risk Mitigation manual is also

available on the intranet for the various departments and this should be used for routine activities.

In short the Aban management system is available on line and is a rich source of information on

various activities carried out on the rig. The rig crew is encouraged to source information from the

management system and use it as a guideline to carry out their daily activities. The Safety

catalogue is to be used to order company approved equipment.

133- The rig is a four legged rig with a slotted jacking system. The rig is advised to have a written

procedure for the jacking systems which should include steps. Hazards and mitigation carried out

to ensure a safe jacking operation. Crew is required to traverse between the chords of each leg for

slotting the pins and this is a hazardous operation which should involve proper fall protection and

other necessary safety procedures.

These pictures and findings were discussed with the OIM and the HSE officer, Barge Master, Chief

Electrician and Chief Mechanic before leaving the rig on the 19th.

------------------------------------------------------End of Report -------------------------------------------------------

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General Internal HSE Audit thAban VI, 17 -18th

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