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Falls from a height are one of the leading causes of death and major injury in many industries, including the oil and gas sector.
Some tasks involve working at height on a daily basis and are oftentimes performed in harsh weather conditions, or in awkward and cramped positions increasing the risk of falls.
For instance, working on drilling rigs and oil and gas plants, either located onshore or offshore, have a significant number of tasks involving working at height. Workers are expected to climb on derrick ladders that are 30 to 100ft high, or use scaffolding platforms, mobile elevating access platforms, or caged ladders to access a specific vessel or structure. Such tasks present a range of hazards, from dropping objects, to workers falling to lower levels, or the entanglement of fall protection devices in moving machinery, in addition to exposure to heat, cold weather and psychological stress.
According to the International Labour Organisation (ILO), working at height “means work in any place where, if there were no precautions in place, a person could fall a distance liable to cause personal injury (for example a fall through a fragile roof down an unprotected lift shaft, stairwells, etc.)”
This article aims to stipulate existing statistics in relation to work at height incidents in the oil and gas sector; define the best approaches to risk management, while understanding that different regulators and professional bodies have their own definition of working at height; and finally describe main issues that should be included in a company’s fall protection plan, such as risk assessment, training, rescue arrangements, selection of equipment, and supervision.
Statistics
Statistics from professional bodies and regulators clearly reflect the importance of managing risks associated with working at height. According to the Occupational Health and Safety Administration (OSHA) reports in 2019, oil and gas workers have the highest rate of fall-related accidents, with a reported 148.9 severe injuries per 100,000 workers.
Based on the International Association of Drilling Contractors’ annual report, out of 39 lost time incidents which occurred on drilling rigs in Middle Eastern regions in 2019, around 35% have been related to fall incidents. According to the International Association of Oil and Gas Producers (IOGP), 12.4% of lost work day cases in 2020 were related to working at height, and falls from a height were the cause of 10% of fatal cases between 2016-2020 in IOGP members.
“past incidents and high injury risks indicate that fall protection is a serious issue in the oil and gas sector”
The UK Health and Safety Executive’s statistic report also indicates that only six fatalities have been recorded in the UK offshore oil and gas sector in the last 10 years. However, two of them have been related to falls from a height and between 2012-2019, work at height was attributed to 67 major injuries and lost time incidents.
Despite a large number of fall incidents and their severities, literature review indicates that there is a lack of adequate research on fall incidents in the oil and gas sector. The majority of existing data is so generic and trend analysis is not available to find the key areas where most fatal cases are occurring, or which activities should be the centre of attention. Review of past incidents indicates that an entanglement of workers’ fall arresting equipment caused numerous fatalities and major injuries on drilling rigs. A research conducted by The United States Centers for Disease Control and Prevention (CDC) indicated that between 2005 and 2014, 63 workers died due to falls from a height in oil and gas drilling and well service companies, in the United States, while 30% of those fatalities occurred during rig up/rig down processes or during drill pipe trip in/trip out activities.
Regulatory requirements
Compliance with regulatory requirements, company procedures and industry guidance created some confusion amongst workers. The International Association of Oil and Gas Producers (IOGP) defined working at height as one of nine ‘life saving rules’ and recommends companies to define working at height as “work at or above 1.8m/6ft, unless local legislation requires a lower height”. Therefore, where it is more than 1.8m, by using regulations for 1.8m heights you are always in compliance with the law. However, the Occupational Health and Safety Administration (OSHA) requires that fall protection be provided at elevations of 4ft (1.22m) in general industry workplaces, 5ft (1.52m) in shipyards, 6ft (1.83m) in the construction industry and 8ft (2.44m) in longshoring operations. In addition to these, OSHA requires that fall protection be provided when working over dangerous equipment and machinery, regardless of the fall distance.
The goal setting approach in UK regulations, in relation to working at height, is distinguishable from its definition. The UK Health and Safety Executive’s (HSE) definition for working at height is similar to the International Labour Organisation’s (ILO) definition where it says, “any place where, if precautions were not taken, a person could fall a distance liable to cause personal injury”.
Even though many workers still wrongly believe in the 2m fall protection myths, falls can occur from almost any height. Therefore, the best approach to manage related risks, comply with legal requirements, company procedures and guidance, is that any work where there is a likelihood of fall be considered as working at height, and should implement required control measures to mitigate the risks. In fact, instead of following the prescriptive approach, companies can utilise a goal setting approach to better manage associated risks.
Fall prevention and fall protection
It is important to understand the differences between these two concepts. Fall prevention aims to remove the need for people to work exposed to falls. This is done by designing and planning the work. Whereas fall protection is the use of techniques to protect those who are, by necessity, exposed to fall hazards, so as to minimise the risks. Changing bulbs on a high ceiling can be done from access equipment, but a safer solution is to design a fixed a way of access above the ceiling space. In this regard, fall protection systems fall into three categories, listed in the table above.
“those who work at height should have a minimum of 12 hours training on fall protection devices”
Due to the nature of work in the oil and gas sector, from exploration of oil and gas fields via drilling wells, to construction and commissioning of oil and gas plants, operation and finally decommissioning, most of the time, people are exposed to falls. This article concentrates on this fall protection concept, and in particular, the fall arrest system. When we are talking about fall protection, we are not talking about any individual items such as a harness, lanyard, etc., it is a system. The system includes the four elements of ABCD: A stands for Anchor Point (what you actually tie to), B stands for Body Wear (such as a harness), C stands for Connecting Device (either a shock absorbing lanyard or a retractable lifeline), and D stands for Descent/Rescue, (where devices are used to retrieve a fallen worker). Therefore, all four components are equally important in a fall arrest system.
Risk control strategies
Even though all risk control strategies in a fall protection plan for any work at height should start with hierarchy of control, such methodology is not possible most of the time in the oil and gas sector. Even with emerging cutting-edge technology, such sectors still heavily depend on human involvement and the use of fall arrest systems to ensure worker safety. For instance, eliminating work at height is not possible when you need to send a worker to the top of a drilling mast to make a dropped inspection from all sections of derrick, or do maintenance work on a travelling block.
Past incidents and high injury risks indicate that fall protection is a serious issue in the oil and gas sector. The dynamic nature of the risk sees many companies’ golden rules, and companies constructing or maintaining oil and gas plants, request all workers who visit or work in the plant to wear a safety harness at all times. This is because it is difficult to know which section of the plant had been modified or when, and what additional fall hazards may have been created since. For instance, for those working on the construction of oil and gas plants and using a personal fall arrest system, constant vigilance and coordination is required. This is because, when one worker is working on a level, another worker may simultaneously work on the level below, meaning the free fall distance may change within hours for the worker above, and so his anchorage point cannot be considered safe after a few hours. Considering the facts, limiting free fall distance to 2ft is not always achievable.
Technology in risk management
Using technology is a typical example of an application of hierarchy of control for working at height. A significant number of work at height tasks, including equipment inspection and surveying, have used drones to reduce risks, as they can be flown over an installation or go deep into a specific structure or vessel, in order to decrease the number of work at height tasks. For example, an inspection of a flare tip in a process plant may cost around 1-5 million USD in production loss per day, in addition to the preparations made days in advance to bring a plant to offline status for safe access. However, using drone technology helps companies to avoid shutting down the asset, reduce associated risks, and ultimately reduce time and cost.
Safe system of work
It has been estimated that at least a quarter of all fatal accidents at work involve failures in safe systems of work. A safe system of work is a formal procedure, resulting in the systematic examination of a task to identify all hazards and assess risks. By doing this, safe methods of work can be identified, and hazards are either eliminated or minimised. The provision of safe systems of work at height is essential and should include risk assessment and hierarchy of controls, planning, training and competency requirements, as well as rescue arrangements and supervision. Some work at height activities require a permit to work, and therefore, should be included in the relevant safe system of work. The use of fall arresting equipment should always be the last option and, where possible, priority should be given to the provision of scaffolding or other working platforms. Those who are approving a safe system of work, particularly when a fall arrest system is selected, should put themselves in the worker’s shoes and consider other mitigation measures, such as a safety net or air bag, in case of a fall.
Fall protection plan
With a review of incidents involving working at height, we realise that in most cases, planning for the execution of a job was either not provided or was substandard. Having generic risk assessments and equipping workers with fall arresting equipment will not help if the worker does not, a) know where the appropriate anchorage point is to hook his lanyard, and b) simultaneously having to avoid swing hazards and other surfaces should a fall occur. Calculating swing fall distance may be necessary when a worker’s anchorage point is not directly above him. This means that we have to know the exact location where a fall arrest system will be set up and the exact location that the job will be carried out. Therefore, as each job is different, each solution must be crafted to the specific job site. Planning is the most important measure when workers are performing non-routine jobs, such as climbing over the top of a vessel or surveying on a drilling derrick, and in particular when workers need to access the equipment in an awkward and cramped position. Thus, providing rescue arrangements becomes more important, particularly if the job site is located in a remote area.
Role of training
Climbing 30m above the water or 35m over the derrick above the rig floor, are tremendously high-risk tasks and in order to ensure the safety of the involved personnel, they must be properly trained. Research conducted by The United States Centres for Disease Control and Prevention on fatal fall incidents in the oil and gas sector, showed that 86% of those who died in incidents had a fall protection device, and in 63% of these cases, they had a safety harness that was not attached to an anchorage point, and a further 3% of cases saw a harness worn incorrectly.
“the provision of suitable rescue arrangements is a fundamental part of an effective fall protection plan”
Therefore, those who work at height should have a minimum of 12 hours training on selection, inspection, use, and rigging of fall protection devices and other accessories. Having a hands-on approach and the engagement of all participants during a training session is an absolute necessity for effective training. Site leaders or supervisors who develop fall protection programmes and complete site assessments, should attend 20 hours training as minimum, which should be a combination of theory and practical, followed by a final examination.
Working at height, and in particular when a fall arrest system is being used, is a technical subject and as such a common-sense approach does not always work. In addition to technical knowledge, a trainer should have practical experience in using and testing all relevant equipment and techniques, and in particular, experience with rescue operations. Watching a two-hour video, or simply completing an online training course, cannot equip workers with the required knowledge and skills. However, nowadays the majority of fall protection manufactures offer substantial training and consulting services tailored to the specific needs of a company.
Role of supervision
Effective supervision has a significantly positive impact on a range of human activities such as compliance with procedures, training, competence, safety critical communication, staffing levels, workload, fatigue, and risk assessment. The key is that supervisors are expected to oversee the activities or tasks of others, and as such, a supervisor is the link between the planning of a job and its actualisation.
Supervisors have a crucial role in work at height activities. They manage a range of issues, from increasing situational awareness among workers by conducting toolbox talks, to coordination with other parties, equalizing workload and prevention of fatigue, and ensuring compliance with fall protection plans. The direct involvement of an experienced job supervisor in the assessment of a work location and the preparations of a fall protection plan is fundamental.
Fall Protection Equipment
Due to the nature of most jobs in the oil and gas sector, and factors such as long shifts, location requirements, weather conditions, using other PPE, ect., fall protection equipment should be selected properly. Available equipment ranges from rope grabbers, self-retracting lifelines, full body harnesses, vertical and horizontal lifelines, netting and guard rail systems. Today’s fall protection equipment is more lightweight, customisable, user-friendly and comfortable than ever before. When selecting equipment, the right size, durability, its inspection status and application requirements, as well as its resistance to extreme temperatures, oil and grease, are all important factors to consider. It is important workers know the limitations of their equipment because a single wrong assumption could lead to an incident. For example, it is easy for a worker to tie his lanyard onto the anchorage point without realising that his snap hook is not designed to sustain the 5000 pounds of force and would break during a fall. This is because most designs can only sustain up to 350 pounds of force (front or side load).
Providing fall protection equipment with extra features may lead to incidents or unsafe behaviour if proper training or supervision is not provided. Some people wrongly believe that selecting a harness with all the extra features will cover them in all scenarios, however, by doing that they are adding additional cost and weight, and more importantly, they are giving people an opportunity to make mistakes. Climbing with extra weight increases fatigue and muscle stress, or could obstruct the wearer when passing through hatchways and trapdoors. It can also present problems if the worker has to wear additional PPE, such as immersion suits or life jackets, either by restricting their movements or reducing a worker’s buoyancy.
Rescue
Rescue is an important part of the planning phase, and companies must plan for emergency and rescue for all reasonably forceable circumstances. Because of the remoteness of most oil and gas plants, calling the emergency services is not always possible, and so someone with adequate training on rescue at height is required on the job site. The role of rescue arrangements while using fall arrest equipment becomes more notable due to the risk of suspension trauma. Readiness and quick reaction on such rescues are important, and must include the hierarchy of rescue options available on site for getting a worker to safety from dedicated safety equipment, such as controlled decent devices or winches, to accessing work equipment such as a mobile elevating working platform (MEWP). The plan should also ensure all staff know the relevant first aid procedures when dealing with a person involved in fall incident.
Conclusion
Fall from height is one of the leading causes of fatality and major injury in many industries, including the oil and gas sector. Fall protection plans which have all the necessary components, such as risk assessments, safe systems of work, training and equipment selection, are essential for accident prevention. Preventing the exposure of workers to falls by using scaffolding platforms or other equipment, should always be a priority during the preparation of a safe system of work. Considering the remoteness of most job sites in the oil and gas sector, the provision of suitable rescue arrangements is a fundamental part of an effective fall protection plan. Thus, importance of proper hands-on training for workers should not be underestimated. Selecting the right equipment is key in the prevention of worker mistakes and enhanced job performance. Where human risk can be avoided, using drone technology for inspection purposes on oil and gas plants, is one great example of the application of hierarchy of control for working at height.
References
1. International Labor Organization (2016) Safety and Health at Work
2. Dubois, R. (2016) Safety first – working at height on oil and gas platforms
3. Smith, E., Roels, R., (2015) Occupational Fatalities Resulting from Falls in the Oil and Gas
4. Offshore Petroleum Industry Training Organization (2020) Working at height essential theory standards
5. International Asscoiation of Oil and Gas Producers (2020) IOGP Safety performance indicators – 2020 data
6. Holt, J. (2002) Principal of Health and Safety at Work
7. Centers for Disease Control and Prevention (2017) Occupational Fatalities Resulting from Falls in the Oil and Gas Extraction Industry, United States, 2005–2014
