44
DROPS MANAGEMENT STANDARD

DROPS MANAGEMENT STANDARDDROPS Calculator The dropped Object Calculator, included as Attachment 1, provides an estimate of the consequence of a Dropped Object event, when a human being

  • Upload
    others

  • View
    9

  • Download
    1

Embed Size (px)

Citation preview

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 1

    DROPS MANAGEMENT STANDARD

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 2

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 3

    Ministry Endorsement

    Ministry of Oil and GasH.E. Eng. Salim bin Nasser Al Aufi

    The Under Secretary

    Ministry of Oil Gas

    Signature:

    Date: 16/8/2018

    Document Approval

    Document Authority Document Custodian Document AuthorChairman, OPAL

    Dr. Amar Al Rawas

    Date: 16/8/2018

    Chief Executive Officer, OPAL

    Musallam Al Mandhary

    Date: 16/8/2018

    For DROPS Standard Working Committee

    QHSE Executive Manager, OPAL Dr Ramesh Sivathanu

    Date: 16/8/2018

    Revision Status

    Revision Version No. Date Status

    Aug, 2021 Next revision due

    Rev. 0 V 1.0 Aug, 2018 Issued for use

    User Notes:

    This document was prepared and agreed upon by the Operators represented through the OPAL Operators’ Safety, Health and Environment Managers Steering Committee (OSHEMCO).

    This document is the property of OPAL and intents to serve the needs of any Oil and Gas Companies li-censed under MOG and/ or registered with OPAL/ JSRS. This document can also be referred and followed in other sectors in Oman. It is the user’s responsibility to ensure that they are referring the latest version of any hard copy or electronic copy. For assistance, contact OPAL QHSE Dept.

    Any printed version or electronic copy down loaded from any website is uncontrolled copy.

    Page I

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 4

    Operators CEO Commitment

    By endorsing this DROPS Management Standard (OPAL-HSE-STD-04), each entity will individually seek its reasonable endeavor to comply with the said standard with effect from 1st August 2018:

    Signatures:

    …………………………..

    Mr. Raoul Restucci Managing Director,

    Petroleum Development Oman

    …………………………..

    Mr. Yousuf Al Ojaili President,

    BP Oman | BP Exploration (Epsilon) LTD

    …………………………..

    Mr. Steve Kelly President and General Manager,

    Occidental of Oman

    …………………………..

    Mr. Gong Changli Chief Executive Officer,

    Daleel Petroleum Company LLC

    …………………………..

    Mr. John Malcolm Executive Managing Director,

    Oman Oil Company E&P LLC

    …………………………..

    Mr. Usama Al Barwani Chief Executive Officer,

    Petrogas EP

    …………………………..

    Mr. Walter Simpson Managing Director,

    CC Energy Development

    …………………………..

    Gary Duncan General Manager, ARA Petroleum

    Page II

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 5

    ………………………..

    Mr. Harib Al Kitani Chief Executive Officer,

    Oman LNG LLC

    …………………………..

    Mr. Ahmed Al Jahadhmi Chief Executive Officer,

    Oman Oil Refineries and Petroleum Industries Company

    …………………………..

    Mr. Steven van Rossem General Manager,

    DNO

    …………………………..

    Mr. Abdulfattah Al Zaabi Country Manager,

    Masira Oil Limited

    …………………………..

    Mr. Mohammed Al Jahwari

    Chief Executive Officer, Hydrocarbon Finder

    ………………………..

    Mr. Chris Breeze Country Chariman,

    Shell Oman

    …………………………..

    Mr. Ahmed Syaifudin Country Manager, Medco Arabia Ltd

    …………………………..

    Mr. Sultan Al Bartmani Acting Executive Managing Director,

    Oman Gas Company S.A.O.C

    …………………………..

    Mr. Amrou A.Al-Sharif President & Chief Executive Officer,

    Oman Lasso E&P

    Page III

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 6

    A. Operators Safety, Health and Environment Managers Steering Committee (OSHEMCO), 2016

    Name Job Title Organization

    Kamil Al Lawati GOO HSE Manager BP Oman

    Dawood Al Badaai QHSSE Senior Manager Daleel Petroleum

    Dr. Ghuddayyer Al Waheibi Corporate QHSE Manager E&P Petrogas EP

    Hassan Al Ajmi Mukhaizna HES Manager Occidental Oman

    Moussa Al Hajri Head of HSE CCED

    Majid Al Saidi Safety Manager ORPIC

    Mohamed Al Salmani / Younis Al Hinai

    Corporate Health, Safety & Environment Manager /Head HSE Corporate Planning & Assurance, MSE/5 PDO

    Moosa Al Habsi HSE Manager Oman LNG

    Nasser Al Yaarubi/ Sulaiman Al Sulaimi

    Head of Resilience HSE Team Lead OOCEP

    Dr. Ramesh Sivathanu QHSE Executive Manager OPAL

    Steve Piscina HSE Manager ARA Petroleum

    B. OPAL DROPS Management Standard- Working Group, 2017

    Page IV

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 1

    Name Job Title Organization

    Adnan Al Musharafi HSE Advisor OLNG

    Andrew Clarke HSE Manager for BP GWO Oman BP Oman

    Anfal Al Alawi QHSE Officer OPAL

    Arun Abraham Snr HSE Advisor, Well Engineering & Logistics PDO

    Faizan Ahmed Wasfi Project HSE Superintendent OOCEP

    Hassan Al Ajmi Mukhaizna HES Manager Occidental Oman

    Jamal Al Rashdi QHSE Inspector Daleel Petroleum

    Peter Michael Hamel QHSE Team Leader Shaleem Petroleum

    Dr. Ramesh Sivathanu QHSE Executive Manager OPAL

    Said Al Dalhami Safety Officer ORPIC

    Scott Murray Safety & Environment Manager Shell Development Oman

    Sulaiman Al Sulaimi HSE Team Lead OOCEP

    TABLE OF CONTENTS

    1 ABBREVIATIONS & DEFINITIONS ................................................................................................................2

    2 GLOSSARY ....................................................................................................................................................3

    3 PURPOSE ......................................................................................................................................................4

    4 APPLICABILITY .............................................................................................................................................4

    5 REQUIREMENTS ...........................................................................................................................................4

    5.1 Introduction ........................................................................................................................................4

    5.2 Dropped Object Prevention Scheme (DROPS) .................................................................................5

    5.3 DROPS Requirements ......................................................................................................................9

    5.4 Reporting and Performance ............................................................................................................21

    5.5 Minimum Requirements for DROPS Management ..........................................................................23

    6 REFERENCES .............................................................................................................................................24

    7 APPENDICES ..............................................................................................................................................24

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 2

    Appendix A: Dropped Object Calculator .......................................................................................................25

    Appendix B: Prevention of Dropped Objects Training ..................................................................................26

    Appendix C: Sample Completed Dropped Objects Inspection Checklist .....................................................28

    Appendix D: Sample Failed Items Report – Corrective Action Register .......................................................30

    Appendix E: Example of Zone Map ..............................................................................................................31

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 3

    1 ABBREVIATIONS & DEFINITIONS

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 7 of 39

    2 GLOSSARY Term Definition

    Assurance

    A process in which management provides accurate and current information to the stakeholders about the efficiency and effectiveness of its policies and operations, and the status of its compliance with the statutory obligations, in terms of this standard a systematic review in order to gather evidence of compliance with the DROPS requirements.

    Audit (ISO 9000:2015)

    A systematic, independent and documented process for obtaining objective evidence and evaluating it objectively to determine the extent to which the audit criteria are fulfilled. Note 1 to entry: The fundamental elements of an audit include the determination of the conformity of an object according to a procedure carried out by personnel not being responsible for the object audited. Note 2 to entry: An audit can be an internal audit (first party), or an external audit, and it can be a combined audit or a joint audit.

    Color code A system of marking things with different colors as a means of identification of the status of certification / Inspection cycle of an equipment.

    Dropped Object (DROPS Reliable Securing Rev.04)

    Any item or object that falls or has the potential to fall from its previous position.

    DROPS Calculator

    The dropped Object Calculator, included as Attachment 1, provides an estimate of the consequence of a Dropped Object event, when a human being is impacted by an object of a particular mass, falling from a particular height. Refer to Appendix A for DROPS Calculator Functional Excel Sheet.

    Dynamic Dropped Object (DROPS Reliable Securing Rev.04)

    Any object that falls from its previous position due to applied force. Examples of dynamic dropped objects include the top drive hitting the rig floor, a stand of drill pipe falling across the derrick and hitting and breaking a light resulting in the light falling to the rig floor.

    HIPO

    An unplanned HSE event, i.e. incident / near miss, which has the potential severity to cause permanent disablement or death. HIPOs will be restricted to high potential with respect to consequences on People and will include violation of Life Saving Rules and all significant (ref. DROPS Calculator) dropped objects. To be used interchangeable with the Term PSI.

    Impartiality (ISO 17020:2012)

    Presence of objectivity Note 1: Objectivity means that conflicts of interest do not exist or are resolved so as not to adversely influence subsequent activities of the inspection body.

    Inspection (ISO 17020:2012)

    Examination of a product (3.2), process (3.3), service (3.4), or installation or their design and determination of its conformity with specific requirements or, on the basis of professional judgment, with general requirements.

    Inspection body (ISO 17020:2012)

    Body that performs the Inspection

    Inspection System (ISO 17020:2012)

    Rules, procedures, and management for carrying out inspection

    Lifting equipment (LOLER)

    Lifting equipment is any work equipment for lifting and lowering loads, and includes any accessories used in doing so (such as attachments to support, fix or anchor the equipment).

    Term Definition

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 4

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 8 of 39

    Term Definition

    Likelihood (ISO Guide 73:2009)

    Chance of something happening Note 1 In risk management terminology, the word “likelihood” is used to refer to the chance of something happening, whether defined, measured or determined objectively or subjectively, qualitatively or quantitatively, and described using general terms or mathematically [such as a probability or a frequency) over a given time period]. Note 2 The English term “likelihood” does not have a direct equivalent in some languages; instead, the equivalent of the term “probability” is often used. However, in English, “probability” is often narrowly interpreted as a mathematical term. Therefore, in risk management terminology, “likelihood” is used with the intent that it should have the same broad interpretation as the term “probability” has in many languages other than English.

    Near Miss (OHSAS 18001:2007)

    An incident where no injury, ill health, or fatality occurs may also be referred to as a “near-miss”, “near-hit”, “close call” or “dangerous occurrence”. e.g. Any object that falls from its previous position under its own weight but does not cause injury or property damage.

    No-Go-Zone

    An area in which a Dropped Object potential has been recognized as high (e.g., where moving equipment is present, where personnel are working at heights) and personnel are not permitted while the hazard is present or active. These zones are identified in the permit-to-work, controlled to prevent access and differentiated from the Restricted Access Zones by barricades and signage (Example - lifting exclusion zones).

    Primary Securing Method (Common Guidelines for Independent DROPS Survey Rev.2)

    Description of the method securing the equipment to the structure (i.e. nuts, bolts, screws, clamps, brackets, turnbuckles, weld etc.).

    PSI Potentially Severe Incident, to be used interchangeable with the Term HIPO.

    Restricted Access Zone

    An area in which a Dropped Object potential has been recognized. The area is identified and authorized entrants are limited to the personnel needed to perform the work. Physical barricades and signage (i.e., Restricted Access Zones) clearly identify the covered area and the specific risk of the zone (example - Rig Floors).

    Risk (ISO/IEC Guide 51:1999)

    Combination of the probability of occurrence of harm and the severity of that harm

    Risk Matrix (ISO Guide 73:3009)

    Tool for ranking and displaying risks by defining ranges for consequence and likelihood

    Safe Working Load (SWL)

    It is the maximum safe force that a piece of lifting equipment, lifting device or accessory can exert to lift, suspend, or lower, a given mass without fear of breaking. Usually marked on the equipment by the manufacturer.

    Safety (ISO/IEC Guide 51:1999)

    Freedom from unacceptable risk

    Secondary Retention Method (Common Guidelines for Independent DROPS Survey Rev.2)

    Description of the method providing secondary securing the equipment to the structure (i.e. wire slings, encasement, lock nuts, lock washers, tab washers, lock wire, split pins, roll pins, spring clips, clamps, safety chains etc.).

    Term Definition

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 5

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 9 of 39

    Term Definition

    Shall (ISO / IEC Directives Part 2)

    - is to - is required to - it is required that - has to - only … is permitted - it is necessary

    Should (ISO 9001:2015)

    indicates a recommendation

    Static Dropped Object (DROPS Reliable Securing Rev.04)

    Any object that falls from its previous position under its own weight (gravity) without any applied force. Examples of static dropped objects include nut dislodged in rig derrick, fallen cable tray due to failed (corroded) fastenings.

    Working at Heights Work 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.

    Working Load Limit (WLL)

    It is the maximum working load designed by the manufacturer. This load represents a force that is much less than that required to make the lifting equipment fail or yield, also known as the Minimum Breaking Load (MBL).

    Workplace (ISO 45000:2018)

    Place under the control of the organization (3.1) where a person needs to be or to go for work purposes. Note: When giving consideration to what constitutes a workplace, the organisation should take into account the OH&S effects on personnel who are, for example, travelling or in transit (e.g. driving, flying, on boats or trains, working at the premises of a client or customer; or working at home.

    3 PURPOSE The purpose of this document is to provide requirements and guidelines for employers to develop and implement programs to protect workers who are at risk of death or injury caused by objects falling from height.

    This standard complies with Oman Labor Law No. 35/2003 and Ministerial Decision (MD) No. 286/2008.

    4 APPLICABILITY This standard is applicable to all Industrial sectors of the Sultanate of Oman.

    5 REQUIREMENTS 5.1 Introduction The standard defines the requirements of Dropped Objects hazard control in daily operation, which means that existing checklists and maintenance programs will be utilized wherever possible, to provide the necessary hazard identification and controls.

    The standard details some important considerations, precautions, checks and procedures. These are not exhaustive and should be supplemented with additional checks and processes specific to the individual location, task and environment.

    The objectives of the Dropped Objects Prevention Programme are:

    • Eliminate injury to people

    Term Definition

    3 PURPOSE

    4 APPLICABILITY

    5 REQUIREMENTS

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 6

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 10 of 39

    • Eliminate the incidence of damage sustained by dropped objects

    • Eliminate damage to other associated equipment

    5.1.1 Preventive Controls and Mitigating Measures for Dropped Objects Dynamic and static dropped objects demand differing approaches in respect of their preventive controls and mitigating measures. Table 1 presents the common measures and controls for each Dropped Object type.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 7

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 11 of 39

    Table 1: Dropped Objects - Preventive Controls and Mitigating Measures

    Type of Dropped Objects

    Preventive Controls Mitigation Measures

    Static* • Preventive Maintenance Tasks • Calendar-based Dropped Objects

    Inspections • Primary Securing Devices • Independent Dropped Object Surveys • Dropped Object Inspection Books

    • Secondary Retention • Effective Use of Barriers & warning

    signs to clearly mark Restricted Access Zones and No-Go Zones

    • Restricted Access Areas to No-Go Zones

    Dynamic** • Individual Awareness • Effective Task Planning (including Lift

    Plans) • Anti-Collision Controls • Pre-task Assessment and Checks • Observation and Vigilance • Management of Change • Time Out For Safety (TOFS) / Tool Box

    Safety Talks (TBST) • Management of Distractions • Tools Aloft Log Book • Subcontractor Equipment Inspections

    • Individual Awareness • Use of Approved Tools for Working at

    Height • Public Address (PA) Announcements /

    Warnings (e.g. overhead operations, crane operations, work in derrick etc.)

    • Effective Use of Barriers & warning signs to clearly mark Restricted Access Zones and No-Go Zones

    • Restricted Access Areas to No-Go Zones

    * Dropped Objects Prevention Programme has proven to be the most effective and primary preventive tool and resulted in a significant reduction in static dropped objects. ** The preventive controls and mitigation measures for dynamic dropped objects are behaviour-based and rely on the individual vigilance, caution, planning and awareness among workforce.

    5.1.2 Strategy The principal actions required to adopt the Dropped Objects Prevention Programme include:

    • Form a joint workgroup with the crews and sites involved, with identified focal points from each team at those sites;

    • Identify the common problem areas;

    • Generate appropriate action items and track implementation until closeout, in a timely manner.

    5.1.3 Workgroup The dropped object workgroup shall be formed and the working group may include, but not limited to the following persons:

    • Management Representative

    • DROPS Focal Point

    • Occupational Health and Safety Representative

    • Maintenance representative

    The workgroup can request the support of technical personnel in order to achieve the Dropped Objects Prevention Programme objectives.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 8

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 12 of 39

    5.2 Dropped Object Prevention Scheme (DROPS) 5.2.1 Elements There are 10 elements to the Dropped Objects Prevention Programme, as listed below:

    • Element 1 Awareness Campaign

    • Element 2 Training

    • Element 3 Action Plan

    • Element 4 Remedial Action

    • Element 5 Manufacturers & Suppliers

    • Element 6 Automated Systems

    • Element 7 Third Party Equipment

    • Element 8 Operations

    • Element 9 Assurance

    • Element 10 Continual Improvement

    5.2.2 Element 1 - Awareness Campaign • The workgroup shall raise the awareness and alert everyone to the nature of the problem

    and the actual and potential consequences of dropped objects on the work site. The awareness campaign should include reviewing specific incident reports from similar worksites for dropped object events and highlight the problem, utilizing safety meeting discussions, pre-tour meetings, toolbox meetings and special emphasis programs.

    • The awareness campaign shall include numerous posters and safety alerts to provide constant reminders to employees and contractors of the dangers resulting from dropped objects and the appropriate control and mitigation measures.

    • Video clips should be utilised as appropriate to enhance the awareness campaign.

    • Awareness campaign shall stress importance of individual awareness of and adherence to procedures and requirements for working at height or the adherence to Restricted Access Zones and No-Go Zones.

    5.2.3 Element 2 – Training • The training shall be delivered by a competent trainer who holds a valid “Train the Trainer”

    certification. An assessment shall be conducted at the end of the training to assess the understanding of the participants. See Appendix B for details.

    5.2.4 Element 3 - Action Plan • The facility or worksite should be divided into small manageable sections. These sections

    should provide manageable boundaries that can be clearly understood and identified. This will ensure all equipment is included in the analysis and inspection program.

    • An inventory of every potential dropped object shall be recorded on the relevant section of each site–specific inspection form.

    • The workgroup shall document all findings in the inventory.

    • The inventory can be completed by a group or individual.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 9

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 13 of 39

    • Members of the team doing the inventory should be intimately familiar with the facility and the workings of the equipment on it.

    • Each item identified in the inventory shall be photographed for reference purposes and as a resource for training purposes.

    • Major equipment drawings should be documented; if other items are attached to this equipment they should also be identified on the drawing.

    5.2.5 Element 4 - Remedial Action • Determine if each item included in the inventory is essential for the operation; a review of

    all operations and procedures are required. Items which are not essential or redundant for the operation shall be removed (e.g. Beams are only required during Inspection) under a formal Management of Change (MOC) Process. The Site Supervisor and Subject Matter Experts shall perform this review.

    • Using the site-specific DROPS inspection form (See Appendix C], each item of equipment deemed required should be examined to ensure the fastening method is adequate. Equipment deemed to constitute a DROPS hazard should be fitted with an appropriate secondary method of securement.

    o Generate a failed items list based on the DROPS Survey.

    o Generate a DROPS Register as mentioned later in this standard.

    Note: The DROPS Register is a register of ALL potential dropped objects found on the worksite. This is to be worksite specific, i.e., a different register for hoists, wire line units, etc and the register needs to be unit specific and be identified as per company document control procedure.

    o Generate a DROPS inspection checklist which will be followed on periodic basis as per the company’s policies and procedures.

    Note: As part of each company’s DROPS Program, a Pictorial DROPS Inspection Checklist shall be available on site and shall be filled out by DROPS Focal Point as per the company policy, normally, at a minimum, each time the unit is rigged up. The DROPS Inspection shall be signed off and verified by the Site Manager/Supervisor (example, construction supervisor / tool pusher/ man-in charge etc)

    • Identify the risks associated with the remaining essential items. The Site Manager/ Supervisor shall classify the risks in terms of likelihood and consequence. These hazards shall be addressed in the corresponding Job Safety Analysis (JSA).

    • Determine and Identify any additional controls in use.

    • Record specific details where applicable, such as serial numbers, tag numbers or identification numbers. This will be useful where several items of the same or similar equipment are in use, e.g. hang off line snatch blocks.

    • The site-specific inspection form should be used to identify the frequency and inspection standards for each item, e.g. a light at height such as the light tower/ monkey board – secured with clamps and a safety net attached would be checked weekly and the check would be noted on the weekly maintenance checklist.

    • Review inspection checklists and, if necessary, revise DROPS controls accordingly.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 10

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 14 of 39

    • Inspections should be at a set regularity in line with the risk levels posed.

    5.2.6 Element 5 - Manufacturers and Suppliers • The workgroup shall identify all the major equipment manufacturers and suppliers using a

    suitable Major Equipment Manufacturer Register. Identification details for each item should be included in this register.

    • The workgroup should maintain a set of relevant and current drawings for each item and include details such as model, serial number and year of manufacture.

    • The manufacturers or suppliers shall be asked to provide any alerts or product bulletins relevant to DROPS.

    • The manufacturers or suppliers shall also be asked to provide a dropped object prevention analysis for each item (if available).

    • Relevant service and testing requirements shall meet the applicable technical standards and proper records shall be maintained.

    5.2.7 Element 6 - Automated Systems • The principles described in this document for preventing dropped objects do not change in

    the automated environments of remote controlled systems, such as Distributed Control Systems (DCS), Supervisory Control And Data Acquisition (SCADA) operated equipment at height. However, stringent inspection routines and familiarity with the proper use of automated systems shall be maintained at all times.

    5.2.8 Element 7 – Third Party Equipment • The workgroup shall maintain a record of all equipment used on the asset (including

    equipment used or provided by third parties) that has the potential to introduce a dropped object hazard into the work place, using a Third-Party Equipment Checklist.

    • Each third-party company supplying equipment that has the potential to introduce a dropped object hazard shall provide a risk assessment which can be in the form of a detailed Job Safety Analysis (JSA).

    • Drawings and photographs of equipment (including third party equipment) shall be documented for future reference.

    5.2.9 Element 8 – Construction, Operations and Maintenance • All asset operations’ procedures and maintenance routines shall be reviewed and with the

    proper authority modified to include measures identified by the workgroup that improve the control of dropped objects on the asset.

    • A pre-job inspection shall be performed and Dropped Object Hazards need to be addressed at Tool Box Talks, before commencing work. This shall include work conducted at ground level, near structures or equipment where dropped objects may constitute a hazard.

    • All activities shall be performed in accordance with the following procedures:

    o Safe Work / Permit to Work Procedure,

    o Material Handling,

    o Rigging & Lifting Procedure,

    o Process/Mechanical Isolation Procedure,

    o Lockout / Tagout Procedure,

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 11

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 15 of 39

    o Working at Height Procedure,

    o Electrical Safety Rules,

    o Job Safety Analysis (JSA), and

    o the appropriate Standard Operating Procedures (SOPs).

    • Working with tools at height has a potential for injury or equipment damage from dropped

    objects. All tools used at height shall be logged out at the start of a job and logged in after the job has been completed and before operations continue using the Tools at Height log sheet. All tools shall be suitable for working at height and therefore shall be tethered with an approved and certified lanyard.

    • Risk Assessments or Hazards & Risks register shall include hazards involving Dropped Object Hazards.

    5.2.10 Element 9 – Assurance • Provides a regular and independent view of the status of potential dropped object

    management.

    • Conduct Risk based independent review of Third Party Inspection Bodies performance.

    • Develop requirements for Third Party Inspection Bodies executing DROPS Inspections.

    • Development of an assurance model, suitable for those organisations with a dropped object risk.

    5.2.11 Element 10 - Continual Improvement • Ensure to update the Dropped Objects Prevention Programme whenever changes are

    made to the asset inventory or the structure itself.

    • Share ideas and lessons learned between assets and areas, to continually improve results. This can be done through safety meetings and other means of communication as appropriate.

    • Dropped objects that do not cause injury and/or damage should be considered as a near miss and must be reported and investigated, in accordance with approved Incident Reporting & Investigation Procedure. Action Items, recommendations and requirements resulting from the Investigation Report, should be managed on a timely manner until close out. The Incident Reports should be used for training purposes.

    5.3 DROPS Requirements 5.3.1 General

    i) All employers are required to develop a DROPS Management Procedure.

    ii) Operating Procedures / Work instructions shall have the risks of Dropped objects included.

    iii) All personnel are required to familiarize themselves with this standard to perform all work in accordance with its requirements and to maintain awareness of DROPS hazards, while performing any work.

    iv) Prior to performing work, Company shall develop a written Dropped Objects Prevention Programme that includes the following:

    • Written program detailing the DROPS program elements

    • Compliance with applicable lifting & hoisting standards.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 12

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 16 of 39

    • Independent (third party) facility inspection, repeated as a minimum every 24 month.

    • Re-survey of the rig, hoist or unit following any dropped object incident

    • Post jarring / excessive vibration event inspection.

    • DROPS inspections of Facility or Rig/Hoist:

    o Weekly

    o Specific to rig up/down activities during rig move activities, which includes an inspection of the mast

    • Tethered Tools as part of a Working at Heights Tool Kit.

    • Facility Inventory to include all equipment in the facility and its secondary retention method. The facility equipment inventory shall be updated immediately with location and precise details of all new / modified equipment in the facility.

    • Facility equipment register.

    • Facility log (tools up/down) with sign-off by an accountable person.

    • Secondary retention for fixed equipment at height.

    • All equipment at height to be logged for regular visual/Non-Destructive Testing (NDT) inspection.

    • System to audit and assure DROPS program compliance, including periodic facility audits.

    o Process to mitigate any identified overhead dropped objects’ findings

    o Annual audit of the DROPS program

    o Review of high-risk activities (SOPs) on an annual basis that could contribute to a potential dropped object, e.g. jarring on a rig.

    • Incident Reporting of all dropped objects.

    • Pre-job checklists, JSA's, work permits that specifically include DROPS hazards and controls.

    • Third-Party equipment inspection and control.

    • Training & Competence Development.

    o Annual refresher training for all personnel n the Employer’s DROPS program

    o Refer to Appendix B for minimum requirements of DROPS training • Inspection areas to be clearly specified.

    • Access control with Defined “Restricted Access Zones” or “No-Go” Areas.

    5.3.2 Equipment Requirements 5.3.2.1 Fastening Requirements for Equipment at Height All fasteners used for fixing equipment at height should conform to best industry practice, as defined in DROPS Reliable Securing - Best Practice recommendations for the securing of structures and equipment at the worksite. All equipment at height shall be fitted with a secondary retention device.

    Where possible, Safety Securing shall be installed. Safety Securing is a device installed to catch the potential dropped object should the primary and secondary retention fail. These might be cables or nets or brackets designed to act as a backup to the Primary and Secondary Retention.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 13

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 17 of 39

    5.3.2.2 Tools at Height • All tools used at height should be logged out at the start of a job and logged in after the job

    has been completed and before operations continue.

    • Tools that are regularly used when working at height should be stored separately and kept specifically for use at height.

    • All tools shall be tethered with a lanyard.

    5.3.3 Management Controls/Systems The following Management Control Systems should be implemented, as part of the DROPS program.

    5.3.3.1 Restricted Access Zones Restricted Access Zone – An area in which a Dropped Object potential has been recognized. The area is identified, and authorized entrants are limited to the personnel needed to perform the work. Physical barricades and signage (i.e., Restricted Access Zones) clearly identify the covered area and the specific risk of the zone (example - Rig Floors).

    5.3.3.2 No-Entry Zones (No-Go Zones) An area in which a Dropped Object potential has been recognized (e.g., where moving equipment is present, where personnel are working at heights) and personnel are not permitted while the hazard is present or active. These zones are identified in the permit-to-work, controlled to prevent access and differentiated from the Restricted Access Zones by barricades and signage (Example - lifting exclusion zones).

    5.3.3.3 Determination of potential for dropped objects a) A comprehensive documented Hazard Identification shall be undertaken for all areas of the

    installation or facility to determine the potential for dropped objects. The potential consequences shall be based on DROPS calculator.

    b) DROPS Calculator has been developed on the basis of kinetic energy calculations and is to be used as a guide, in combination with the Risk Assessment Matrix (RAM). The calculator does not take account of the shape of the dropped object, e.g. sharp objects, which can potentially increase the consequences should the object strike a person.

    c) The unit shall be fully rigged up during the survey to allow successful survey and hazard Identification. This process demands input from personnel with strong operational knowledge of the respective areas. The output of the hazard identification and assessment process shall define all areas of the installation or facility (under normal routine operations) are categorized as one of the two zones and controls determined.

    d) To avoid incidents, as a minimum, the following examples of high risk items related to DROP are forbidden:

    1) Uncertified lifting equipment including ‘home made’ lifting devices.

    2) Use of hammers with wooden handles at height.

    3) Bolts secured with a double nut arrangement.

    4) Use of welding rods/wire/tie wraps instead of properly engineered split pins.

    5) Use of open hooks.

    6) Use of uncertified anchor points, for example slings wrapped around derrick/mast beams.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 14

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 18 of 39

    7) Unsecured water bottles, grease tubes/guns, etc.

    8) Drifting stands in the derrick without a formally documented procedure and JSA detailing how the No-Entry Zones or Restricted Access Zones will be controlled.

    9) Surface drill pipe filters.

    5.3.3.4 Designating Area Authorities For each designated area, an Area Authority shall be assigned. The Area Authority should be the supervisor or manager responsible for the main activity in that particular area. As an example, on a drilling rig, the drill floor would have a designated Restricted Access Zone and the Driller would be an appropriate Area Authority.

    5.3.3.5 Access Diagrams / Zone Maps Access diagrams or Zone Maps shall be prepared and mounted at all access points to DROPS Zones and at the common workplace of the relevant Area Authority. The diagrams should clearly define and demarcate, as well as access and egress routes. They should identify the Area Authority’s common workplace location. Refer to Appendix E for an example of a Zone Map. The Access Diagrams / Zone Maps shall be part of the site induction.

    5.3.3.6 Access to Restricted Areas a) All personnel and third parties shall require the Area Authority’s permission in order to enter

    or work in that zone, e.g. third-party inspector would like to enter the Unit location Restricted Access Zone would require permission from Unit Manager.

    b) In Restricted Access Zone, personnel may be more exposed to falling objects, the movement of remotely operated equipment, high pressure, and/or other hazards as determined by risk assessment.

    c) Any personnel in the Restricted Access Zone required for the current operation shall be authorized by the Area Authority e.g. a permission is required from Driller when a roustabout would like to enter Rig Floor.

    d) The Area Authority shall also ensure that any personnel entering a Restricted Access Zone are aware of moving equipment, e.g. top drive and/or draw-works, pipe handling equipment & cranes, etc. Furthermore, the Area Authority shall ensure an appropriate plan is in place for specific operations in a Restricted Access (e.g. running casing, completions, maintenance, lifting etc.

    e) Additional personnel shall not join any task being conducted in a Restricted Access Zone unless approved by the Area Authority, attended the Tool Box Talk (TBT) and task plan discussed.

    f) The Area Authority, once satisfied, shall give approval before the task start.

    5.3.3.7 Permanent Changes to Restriction Classification It may become necessary to reclassify a restricted area in response to permanent modifications or changes in operation within that zone. Such permanent changes to zone classification should be captured through the formal Management of Change (MOC) process and will require amendment and reposting of the relevant Access Diagrams.

    5.3.3.8 Temporary Changes to Restriction Classification a) It may become necessary to temporarily reclassify or restrict an area in response to operational, environmental or other conditions, e.g. area around catwalk during picking up/laying down operations, scaffold erection maintenance intervention, pressure testing, high winds etc.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 15

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 19 of 39

    In such temporary circumstances, authority will determine the reclassification of the area.

    b) Any personnel, other than those who are required for current operations, want to enter and work in the Restricted Access Zone shall obtain permission from Site Supervisor / Area Authority.

    NOTE:

    Safe Work Permit shall be raised for any Work/Task which requires PTW.

    c) Signage shall also be posted at all access points denoting the temporary zone classification, the restricted access and the respective Area Authority. The temporary sign should be in English and the predominant local language.

    d) The Area Authority should arrange for Public Address announcements reflecting the temporary reclassification and access restrictions.

    e) Temporary barriers and signage should be completely removed when the Area Authority has deemed the area can return to its normal and permanent classification.

    5.3.3.9 Stricter Requirements Where legislation dictates stricter requirements than specified in this procedure, then the legislative requirement shall take precedence over the governing requirements of this procedure.

    5.3.4 DROPS Inspection Procedure The DROPS inspection procedure consists of the following steps:

    1) Initial Survey

    2) Identifying & calculating of the safety securing devices required

    3) Reviewing the Secondary retentions

    4) Generating the failed items report

    5) Supervising the rectification of the field items and installation of the safety securing devices

    6) Final survey & training of internal DROPS survey

    7) Generating final reports & checklists

    5.3.4.1 Initial Survey Survey is performed in a systematic approach via:

    Collection of data, from Original Equipment Manufacturer (OEM) documents, inspection reports, photographs of items being inspected and observations of procedures where items are used or performed in proximity to the item.

    5.3.4.2 Identifying & Calculating of the Safety Securing Devices Required Identifying the weight of the item to determine the optimum method of safety securing.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 16

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 20 of 39

    Weight calculation

    • The weight of some loads may be easy to calculate because of their simple shape and uniform density. Due to the complexity of their construction, the weight of other loads is difficult to determine and may require the assistance of an engineer.

    • When calculating load weight, simplify the process by enlarging the size of irregularly shaped portions of the load into simple shapes such as blocks or cylinders. Doing this will ensure that the estimated weight is higher than the actual weight.

    Safety Securing • All items connected to the main structure by a primary fixing.

    • In order to prevent an object from falling in case the primary fixing is failing it shall be fitted with a proper secondary retention.

    • A Safety Securing system shall be installed where a single secondary retention is not practical, or where a secondary retention cannot secure all parts of a component.

    • For the high potential risk items which consist of different components connected to each other the best way to be secured after insuring proper primary fixing and secondary retention has been installed is to provide a safety net.

    5.3.4.3 Reviewing the Secondary retentions The primary securing and secondary securing are examined to ensure that each conforms to OEM recommendations and international standards. Anchor points for the secondary retention shall be engineered to take the maximum weight of the potential DROP object.

    5.3.4.4 Generating the Failed Items Report Failed Items List shall be delivered and presented to client within four days of the survey and it shall be included in the Dropped Object Survey Report (refer to Section 5.3.6.9 for content of Failed Items Report and refer to Appendix D for a sample Failed Items Report).

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 20 of 39

    Weight calculation

    • The weight of some loads may be easy to calculate because of their simple shape and uniform density. Due to the complexity of their construction, the weight of other loads is difficult to determine and may require the assistance of an engineer.

    • When calculating load weight, simplify the process by enlarging the size of irregularly shaped portions of the load into simple shapes such as blocks or cylinders. Doing this will ensure that the estimated weight is higher than the actual weight.

    Safety Securing • All items connected to the main structure by a primary fixing.

    • In order to prevent an object from falling in case the primary fixing is failing it shall be fitted with a proper secondary retention.

    • A Safety Securing system shall be installed where a single secondary retention is not practical, or where a secondary retention cannot secure all parts of a component.

    • For the high potential risk items which consist of different components connected to each other the best way to be secured after insuring proper primary fixing and secondary retention has been installed is to provide a safety net.

    5.3.4.3 Reviewing the Secondary retentions The primary securing and secondary securing are examined to ensure that each conforms to OEM recommendations and international standards. Anchor points for the secondary retention shall be engineered to take the maximum weight of the potential DROP object.

    5.3.4.4 Generating the Failed Items Report Failed Items List shall be delivered and presented to client within four days of the survey and it shall be included in the Dropped Object Survey Report (refer to Section 5.3.6.9 for content of Failed Items Report and refer to Appendix D for a sample Failed Items Report).

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 17

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 21 of 39

    5.3.4.5 Recertification of the failed Items and Installation of the Safety Securing Devices Based on the failed items list and OEM recommendations, the maintenance team shall rectify the failed items and it shall verify that the corrections have been performed according to all relevant specifications.

    5.3.4.6 Final DROPS Survey After completion of remedial actions, a final survey shall be performed by the asset owner, in order to provide assurance that all potential dropped object hazards are identified, assessed and recorded such that control measures and corrective actions implemented within the Asset’s Management System.

    5.3.4.7 Generating Final Reports & Checklists After completing the Dropped Object Survey, electronic copy and hard copy (if requested) of the following documentation to be provided to the Area Authority.

    • Failed Items List

    • Dropped Objects Survey Report

    • Inspection Book

    Refer to Section 5.3.6.9 for details of contents.

    5.3.5 Roles and Responsibilities 5.3.5.1 DROPS Focal Point

    • Responsible to the Employer for communicating this Standard in his/ her Company and facilitating its implementation. The DROPS focal point should become the Company Subject Matter Expert (SME), be fully familiar with the content of the standard and contribute to updates to it.

    • Responsible for verification inspections; follow through on actions arising and identification and reporting of non-compliances. Acts as the Focal Point and offers expert knowledge and skills in order to generate and promote a positive DROPS safety culture within his/ her organization. This represents a key role in helping control occupational risk and equipment damage.

    • Responsible for ensuring that all relevant legislation is adhered to and that the applicable standards and practices are adopted. The DFP helps to plan, implement, monitor and review the protective and preventive measures to follow and work to minimise operational losses, accidents and injuries.

    • Job Tasks:

    o Participate or lead Regional/ local DROPS forum.

    o Post incident prevention programs and lessons learned.

    o Act as a Subject Matter Expert (SME) representative on any industry-wide DROPS steering committee.

    o Collate Dropped Objects data, identify trends and disseminate to management.

    o Facilitate regular meetings with representatives of Contractor’s installations and sub-contractors, focusing on management and control of DROPS issues.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 18

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 22 of 39

    o Act as a focal point for providing support for resolving issues (e.g. secondary retention, derrick surveys, etc.).

    o Disseminate the requirements of this Prevention of Dropped Objects Standard to engineers and supervisors in the region/ local teams and within his/ her organization.

    o Convey the ‘Life Saving’ rules as they apply to DROPS.

    o Facilitate or carry out DROPS risk assessments.

    o Participate in installation audits to check the effectiveness of DROPS inspections and DROPS hazard identification.

    o Lead In-house training programme covering DROPS issues and risks.

    o Consolidate records of inspection findings and produce reports highlighting action for continuous improvements.

    o Liaise with regulatory bodies where applicable.

    o Issue timely safety alerts for Dropped Object incidents in co-operation with the Occupational Health and Safety Department and the Line Management.

    o Participate in significant DROPS incident investigations.

    o Participate in Incident Review Committee for Dropped Object incidents.

    5.3.5.2 Functional Team Leaders / Managers • Responsible for ensuring that the requirements of this standard are implemented on the

    facility he/ she is responsible for and liaise with the other Drops focal points for any issues arising during implementation.

    5.3.5.3 Contract Holder • Responsible for clarifying the requirements of this standard during the contracting process

    for ensuring the contractor or subcontractor(s) has a Dropped Objects Management system in compliance with this standard. He/ She is also responsible for verifying the DROPS inspections carried out by the contractor on location.

    5.3.5.4 Area Authority • Responsible to ensure that the controls for Zone management are available for the area

    he/ she is responsible. He/ she shall ensure that the Restricted Access Zone is extended or upgraded to a No-Go zone depending on the activity and the area is clearly identified. The Area Authority should act as the area controller to prevent entry of personnel into the No-Go zones.

    5.3.5.5 Worksite DROPS Lead • Accountable for implementation and compliance to this standard for the asset(s) they are

    responsible for. As owner of the site DROPS campaign, the contractor worksite DROPS lead is responsible for verification inspections; follow through on actions arising and identification and reporting of non-compliances

    • Job Tasks:

    o Ensure the requirements of the Employer's DROPS Object Program is implemented in their assets.

    o Ensure Drops inspections are done on a weekly basis and they are verified.

    o Ensure the DROPS picture book is maintained and up to date.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 19

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 23 of 39

    o Ensure that the crew is trained in the DROPS campaign modules.

    • Individuals with DROPS accountabilities should ensure that DROPS documentations are regularly reviewed and updated. This includes revising the DROPS Management Program and Standard Operating Procedures (SOPs) to reflect organizational and other changes, incorporating lessons from past experiences (good and bad) and responding to input from the workforce or external best practices.

    5.3.6 Assurance This section provides a framework for the development of an assurance model, suitable for those organisations with a dropped object risk. It can also be used to adapt an existing assurance model.

    5.3.6.1 Assessment and Audit. Assessments and Audits are based on three independent lines of defense.

    Figure 1 DROPS Management Program Assurance

    Level 1: Inspections performed at the site/supplier/operator to assure that the controls in place are effective and are being followed. These inspections may be referred to as Self Assessments and are included in the self-assurance programme.

    Level 2: An audit performed by independent assurance providers (as defined in ISO 17020:2012). They are utilized to address specific concerns, assess whether a fit-for-purpose risk-based control framework is in place and operating effectively and determine if specific processes comply with relevant requirements.

    Level3

    Level2

    Level1

    Provides a regular and independent industry-wide view of the status of potential dropped object management.

    Operator provides a risk based independent review of a supplier’s performance.

    Supplier’s own internal assurance process

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 20

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 24 of 39

    Level 3: An independent audit performed by external assurance providers. These audits typically indicate how robust and effective the Suppliers Level 1 & 2 assurance practices are and verify the scope of topics covered with self-administered audits.

    5.3.6.2 Requirements for Inspection Bodies To ensure expectations are met with regard to the prevention of dropped objects, all subcontractor personnel conducting third party Independent Dropped Objects Surveys / Inspections shall demonstrate competence in:

    • Survey and Inspection Techniques

    • Structural Integrity Assessment

    • Industry Recognised Rope Access Certification

    • Safe Working at Height Procedures

    • Permit to Work Procedures

    • Use of approved Tools at Height systems

    5.3.6.3 Survey and Inspection Techniques In order to demonstrate the ability of executing a Survey and to have the required Inspection Techniques, internal procedures and processes shall be available. The Procedures and Processes need to be in alignment of:

    1) ISO 17020:2012 - Conformity assessment - Requirements for the operation of various types of bodies performing inspection

    2) Reliable Securing Guideline - Best Practice recommendations for the securing of structures and equipment at the worksite

    3) Common Guide Dropped Object Surveys Issue Rev.02

    4) The OPAL Drops Management Standard OPAL-STD-HSE-04 Rev 0

    The Assurance Program includes the following requirements:

    1) Approval process for Inspection Bodies containing:

    a) A documented audit against above mentioned standards

    b) An implementation audit (site audit) against internal procedures of Inspection Bodies.

    5.3.6.4 Structural Integrity Assessment / integrity of retention of primary and secondary securing

    In order to provide evidence of the capability to execute structural Integrity Assessments, the Inspection body shall have the capability to execute brittle fracture assessments. Below list provides standards that shall be available, known and understood by the Inspection Body:

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 21

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 25 of 39

    Table 3 Summary of Available Procedures for Brittle Fracture Assessment

    Procedures / Standards

    Type of Assessment Remarks Fracture Fatigue Creep Corrosion

    BS7910 ü ü ü ü Standard

    API 579 ü ü ü ü Recommended practice

    SINTAP ü - - - European procedure

    ASME B31.G - - - ü Standard

    API 1104 ü Standard

    FITNET* ü ü ü ü European procedure

    *Under preparation/certification

    5.3.6.5 Industry Recognised Rope Access Certification Technicians need to have an international recognized Rope Access Certification. IRATA has 3 levels.

    The three technical grades are:

    Level 1 This is a rope access technician who is able to perform a specified range of rope access tasks under the supervision of a Level 3.

    Level 2 This is an experienced rope access technician who has Level 1 skills plus more complex rigging, rescue and rope access skills, under the supervision of a Level 3.

    Level 3 This is a rope access technician who is capable of complete responsibility for rope access safety in work projects; is able to demonstrate the skills and knowledge required of Levels 1 and 2; is conversant with relevant work techniques and legislation; has an extensive knowledge of advanced rigging and rescue techniques; holds an appropriate and current first aid certificate and has knowledge of the IRATA training, assessment and certification scheme.

    5.3.6.6 Safe working at Height procedures The respective Operators safe working at Heights procedures shall be followed at all times.

    5.3.6.7 Use of approved Tools at Height systems The DROPS Inspectors need to bring their own approved Tools at Height systems and need to follow the documentation process at site for Tools at Height.

    5.3.6.8 Requirements for DROPS Surveyor and Inspector The Inspectors need to fulfil the following requirements:

    • Have a valid work Visa for the Sultanate of Oman

    • Age of 21 years or above

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 22

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 26 of 39

    • Fit to work

    • Have a valid medical examination for working at heights

    • Have an engineering degree (preferably mechanical engineering)

    • Have a valid Training passport or documents with the following courses valid:

    o HSE Induction / Orientation

    o H2S Course

    o Self-Contained Breathing Apparatus (SCBA)

    o First Aid Course

    o Chemical Hazards

    o Permit To Work Holders

    o HSE Leadership for Non-Supervisory Staff

    • IRATA Level 1-3

    o One Inspector requires the IRATA Level 3 Course or equivalent

    • English IELTS Level 5.5 or higher or equivalent

    • Computer literate (Excel, Word, Outlook)

    A tracking System (Log Book) should be available in order to be able to see how many DROPS Inspections one Inspector is carrying out per year.

    DROPS Surveyors and Inspectors shall demonstrate clear understanding of:

    • Reliable Securing Best Practice

    • Safe Bolting Techniques

    • Cargo Handing and Lifting Operations (including Lifting Equipment)

    • Moving / Dynamic Equipment and Machinery

    • Solid Knowledge of Drilling Equipment and Functions

    • Capacity (Safe Working Load - SWL & Working Load Limit - WLL) of the lifting equipment and the calculations related to it

    • Awareness of relevant Safety Alerts and Safety bulletins (HSE) issued by equipment suppliers

    • Task Risk Assessment

    • Hazard Reporting

    • Asset specific DROPS management system

    • DROPS definition (static/dynamic), causes, consequences

    5.3.6.9 Independent DROPS Survey Report The independent DROPS survey report shall be valid for 24 Calendar months as a maximum. A grace period of plus one calendar month shall be given. The renewal date shall be set forth from the date of expiry of the last DROPS Survey report.

    The Inspection Report shall contain the following as general information:

    • Full Company Name of the Third-Party Inspection Company

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 23

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 27 of 39

    • Date of Survey and Date of Report issued

    • Full Company name of the Asset Owner

    • Exact location of Asset

    • Description of the Scope of the Inspection

    • Full name of the Inspector team, residency card number and phone number

    • A list of findings that are NOT fulfilling the Inspection Criteria needs to be provided to the Asset Owner, prior the Inspector leaving the site

    • The report shall contain the following information:

    o Location of Equipment (by Inspection Area)

    o Photograph of the equipment surveyed

    o Equipment tag number or serial number

    o Description of specific item inspected

    o Primary securing method(s) of item

    o Secondary retention method(s) of item

    o Safety securing method(s)

    o Condition (Pass / Fail)

    o Comments (record state i.e. Satisfactory or Reason for Failure)

    o Inspection Frequency (populated from the ‘Inspection Frequency’ column of the Equipment Family Inspection Criteria)

    • The Failed Items List (Refer to Appendix D for a sample Failed Items Report) needs to be notified immediately to the Area Authority and the report issued immediately after the Inspection.

    o Location of Equipment (by Inspection Area)

    o Photograph of the equipment surveyed

    o Equipment tag number or serial number

    o Description of specific item inspected

    o Primary securing method(s) of item

    o Secondary retention method(s) of item

    o Safety securing method(s)

    o Reason for Failure

    o Where appropriate, Remedial or Corrective Action should be recorded.

    o Classification of items into 3 categories using the DROPS Calculator:

    o Red and Orange: No operations are allowed prior to close out

    o Yellow: Rectification within 7 days

    o Green: Rectification within 30 days

    • The Dropped Objects Inspection Book shall be included in the Dropped Object Survey:

    o Photograph of the equipment to be inspected

    o Equipment tag number

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 24

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 28 of 39

    o Description of specific item to be inspected

    o Primary securing method(s) of item

    o Secondary retention method(s) of item

    o Safety securing method(s)

    o Weight of potential dropped object (if safety securing required)

    o SWL for the safety securing item

    o Inspection Procedure (populated from the ‘How to Inspect’ column of the Equipment Family Inspection Criteria)

    o Condition Pass / Fail

    o Quality Assurance suggestion for continual improvement

    o Comments (state to be recorded i.e. Satisfactory or Reason for Failure)

    The Asset Owner is responsible for the close out of findings and shall provide evidence of the close out, e.g. documented in the Action Tracker. The asset owner shall ensure as well that the status is maintained throughout the validity period of the Independent DROPS Survey, e.g. during repair or maintenance work.

    5.3.7 DROPS Associated Occupational Safety Programs The DROP program implemented shall encompass other associated key HSE programs to ensure effective implementation. The Employer shall have formal procedures for those key HSE programs to address the potential DROP hazards associated, including but are not limited to:

    • Lifting and Rigging

    • Tubular Handling

    • Transportation of Equipment and Loads

    • Working at height

    • Walking and working surfaces

    • Safe System of Work (Permit-To-Work)

    • Management of Change (MoC)

    • Hand and Portable Tools and Equipment

    5.4 Reporting and Performance The Dropped Object Survey Report & Inspection Book will be used by Asset personnel to conduct periodic inspections and is comprised of information gathered during the Survey in conjunction with information from the Equipment Inspection Criteria.

    The Report & Inspection Book is grouped by Inspection Areas. Each section will include the following:

    5.4.1 Minimum Reporting Requirements The following is the minimum required records for each site/facility where a Dropped Object hazard may exist:

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 25

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 29 of 39

    • Facility Inventory to include all equipment in the facility.

    o An inventory of every potential dropped object shall be recorded on the relevant section of each site – specific inspection form.

    o The workgroup shall record all potentially hazardous findings.

    o Each item identified in the inventory should be photographed for reference purposes and as a resource for training purposes.

    o Using the site-specific inspection form [created using Dropped Objects Inspection Checklist (TEMPLATE)]

    • Facility equipment register.

    • Major Equipment Manufacturer Register.

    o The workgroup should maintain a set of relevant and current drawings for each item and include details such as model, serial number and year of manufacture.

    o The manufacturer or supplier should be asked to provide any alerts or product bulletins relevant to this particular item.

    o The manufacturer should also be asked to provide a dropped object prevention analysis for each item where one exists.

    • Facility log (tools up/down) with sign-off by accountable person.

    • Secondary retention for fixed equipment at height.

    • Inspections reports, including weekly and pre-job checklists

    • Equipment Drawings

    • Accident / Incident / Near Miss Reports along with investigation reports

    • Alerts (including Recommendations arising from Incident Investigation Reports)

    • Access Zones Maps (refer to Section 5.3.3.5)

    5.4.1.1 Records All records shall be maintained in accordance with the Employer's respective Records Retention Procedure.

    5.4.2 Implementation

    • Effective implementation is essential for the success of DROPS Management Procedure and should lead to continual improvement. This requires that the system is established centrally and implemented business unit-wise, whether for strategic planning or day-to-day operating, so that individual risk controls are consistently applied.

    • Personal commitment and accountability (Element 1) is critical for successful implementation.

    o The ultimate owner of the DROPS Management Program is the Senior Management of the Company, whom retains overall accountability, but delegates clear responsibility, authority and sets expectations so that every part of the system has an owner. This cascading leads to further delegation of the more detailed tiers of the system, including processes, practices and procedures that deliver the expectations or manage specific activities or assets within worksite.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 26

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 30 of 39

    o Many parts of the system are inter-related, and they have many different dependencies, so clarity of ownership is important.

    o Each owner should be knowledgeable and allocated sufficient time and resources to perform their role, and they should regularly review the progress of their part of the system.

    • Hazard hunts, particularly by personnel performing work where there is a DROPS hazard provide a useful source of material for Continual Improvement, as well as analysis of Incident Reports, Near Miss Reports and Industry-wide Safety Bulletins. When hazards are identified, these should be disseminated, through bulletins and discussed at Tool Box Talks, to promote awareness and existing procedures should be amended to reflect newly discovered hazards or improved mitigation measures.

    5.5 Minimum Requirements for DROPS Management The Minimum Requirements for an Employer’s DROPS Management Program are as follows:

    • Work place survey and job hazard risk assessment for potential Dropped Objects Hazards. This shall be performed for all worksites and all activities.

    o Areas where there is a high risk of dropped objects shall be provided with proper warning signs. Zone Map shall be displayed at site and shall be shown to all personnel.

    o Dropped objects mitigation measures shall be specified for activities which are at risk of dropped objects.

    o Pre-job inspection, using site-specific checklist shall be performed, prior to commencing work.

    o Equipment and tools used at height shall confirm to DROPS requirements.

    • Surveying methods for DROPS shall be sufficiently accurate that the DROPS Hazard to which a worker is subject is properly evaluated. DROPS Surveys and Inspections shall be performed and the results disseminated to all personnel performing work in proximity to a DROPS hazard.

    o DROPS assessment shall be updated immediately following any change to equipment of procedure.

    • Employer shall specify reporting mechanism giving details of how the DROPS Hazard is communicated to managers, supervisors and all personnel at the worksite. Employer shall have a reporting mechanism giving details of how the DROPS hazard and mitigation measures are communicated to managers, supervisors and all personnel at the worksite (Tool Box Talk / Safety Briefing).

    o All personnel shall be briefed at job-site Tool Box Meeting on DROPS hazards and shown zone map, immediately prior to performing work at site.

    • Employer shall specify when engineering and administrative controls are required to mitigate DROPS Hazards.

    • Employer shall specify procedures for reporting possible DROPS hazard and ensuring provision of adequate mitigation measures, to be implemented, prior to commencing work.

    • Record management and statistical and trend analyses format: All incidents of Dropped Object Hazard (including Near Miss) shall be reported and recorded, for sharing and shall be subjected to statistical analysis, as part of DROPS management program, to discern possible areas of concern or possible improvements.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 27

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 31 of 39

    • Determine membership of committee of Subject Matter Experts (SMEs) to review and update DROPS Management standard periodically.

    • Employees shall abide by the requirements and shall follow the hierarchical controls and use all appropriate PPEs and shall only use equipment and tools suitable for working at height, if required.

    • Employees shall also report immediately any potential DROPS hazard to the supervisor or intervene when fellow workers is affected by DROPS Hazard by invoking Stop-Work Authority or Empowerment to stop unsafe act.

    6 REFERENCES

    Document Number Description Documents available at the DROPS website

    (http://www.dropsonline.org/) include the following:

    DROPS Recommended Guidelines for the Safe Use of Tools & Equipment at Height

    DROPS Reliable Securing - Best Practice recommendations for the securing of structures and equipment at the worksite

    DROPS Campaign Work pack

    DROPS Prompt Card

    DROPS Training and Hazard Hunts

    DROPS Guidelines for Tools at Height

    DROPS Guidelines for Restricted Access Areas

    7 APPENDICES Appendix A Dropped Object Calculator

    Appendix B Prevention of Dropped Objects Training

    Appendix C Sample Completed Dropped Objects Inspection Checklist

    Appendix D Sample Failed Items Report – Corrective Action Register

    Appendix E Example of a Zone Map

    Document Number Description

    6 REFERENCES

    7 APPENDICES

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 28

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 32 of 39

    Appendix A: Dropped Object Calculator

    http://dropsonline.org/resources-and-guidance/drops-calculator/

    http://dropsonline.org/resources-and-guidance/drops-calculator/

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 29

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 33 of 39

    Appendix B: Prevention of Dropped Objects Training Purpose Prevention of Dropped Objects Training describes the requirements for ensuring that all personnel on work location are properly trained and competent in prevention of dropped object prevention.

    Scope This Standard applies to all organizations where there is a potential of Static or Dynamic dropped objects and any Operator/Company staff, contractors, subcontractors and vendors can be exposed to the risk of dropped object, anywhere whilst on Company business.

    Training & Target Audience

    Training Content Target Audience Requirement Frequency Prevention of Dropped Objects - Awareness Training

    Awareness Level. Awareness training on specific topics pertaining to DROPS to educate site-based staff on content and mandatory and recommended controls as included in the DROPS Specification and supporting documents.

    All Mandatory Annual

    Prevention of Dropped Objects - Advanced Training:

    Knowledge Level. Advanced training with practical sessions on specific topics pertaining to DROPS to enhance the understanding and application of mandatory and recommended controls as included in the DROPS Specification and supporting documents. The contents of the training will focus on the dropped object management of following areas as a minimum • No-Go Zones and Restricted

    Access Zones • Tools at Height • Tubular and Equipment

    Handling • Temporary Equipment at

    Height (e.g. Handling Tool strings and Lubricators)

    • Winches and Tuggers • Lifting and Hoisting

    Worksite DROPS Lead / DROP focal point / SMEs / DROP trainer

    Mandatory Once with annual competency assessment

    Training Content Target Audience Requirement Frequency

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 30

    Oman Society for Petroleum Services DROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 34 of 39

    Contents of Prevention of Dropped Objects Awareness Training The awareness training shall cover as a minimum the following requirements THE HAZARD

    1. Definition of “Dropped Object” 2. Classification of Dropped Objects (Static & Dynamic Dropped Objects) 3. Creating the correct risk perception – Safety Culture 4. DROPS Hazard Identification – Causal Factors 5. DROPS Calculator – The Consequences

    PREVENTION

    1. Stages of the dropped object preventions through supply chain 2. Inspection 3. Securing 4. Secondary Retrenchment 5. Tools At Height 6. Tool Log 7. Zones

    ROLES, RESPONSIBILITIES AND ACCOUNTABILITY

    1. DROPS Focal Point 2. Functional Team Leaders / Managers 3. Contract Holder 4. Area Authority 5. Worksite DROPS Lead 6. All staff

    MONITORING AND PERFORMANCE REPORTING

    1. Hazard reporting (proactive unsafe acts and conditions reporting and correction) 2. Inspection regime (proactive on-going DROPS inspection to be included in the regular inspection

    themes) 3. Incident reporting and investigation 4. Corrective actions design that proactively prevent potential dropped objects

    Training Delivery & Assessment The training shall be delivered by experienced trainer who holds a valid “Train the Trainer” certification. An assessment needs to be conducted at the end of the training to assess the understanding of the participants.

    Responsibility The HSE department in any organization has the full responsibility to ensure a system is in place to monitor expiry of the training of their employees and initiate recertification / booking process.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 31

    Om

    an S

    ocie

    ty fo

    r Pe

    trol

    eum

    Ser

    vice

    s

    DR

    OPS

    Man

    agem

    ent S

    tand

    ard

    Doc

    umen

    t No:

    OPA

    L-ST

    D-H

    SE-0

    4 R

    ev 0

    Issu

    e D

    ate:

    01/

    08/2

    018

    Vers

    ion

    1

    Page

    35

    of 3

    9

    App

    endi

    x C

    : Sam

    ple

    Com

    plet

    ed D

    ropp

    ed O

    bjec

    ts In

    spec

    tion

    Che

    cklis

    t

    G

    EN

    ER

    AL

    RIG

    INS

    PE

    CTI

    ON

    Insp

    ecte

    d by

    :

    Dat

    e:

    Num

    bers

    of o

    pen

    item

    s:

    C

    lose

    out

    targ

    et d

    ate:

    ITE

    M

    DE

    SC

    RIP

    TIO

    N

    LOC

    ATI

    ON

    P

    HO

    TOG

    RA

    PH

    P

    HO

    TOG

    RA

    PH

    H

    OW

    TO

    IN

    SP

    EC

    T FA

    STE

    NIN

    G

    ME

    THO

    D

    CO

    ND

    ITIO

    N

    CO

    MM

    EN

    TS

    Pas

    s Fa

    il

    1 C

    row

    n Bl

    ock

    Han

    d R

    ail

    (Bas

    e)

    1.

    Che

    ck P

    in is

    in

    its p

    lace

    . 2.

    Che

    ck P

    in

    Con

    ditio

    n.

    3. C

    heck

    Saf

    ety

    Pin.

    Pri

    mar

    y S

    ecur

    ing:

    fo

    und

    inse

    rt ty

    pe h

    and

    rail

    secu

    red

    with

    pin

    .

    S

    econ

    dary

    R

    eten

    tion:

    sa

    fety

    pin

    .

    2 H

    and

    Rai

    l (T

    op)

    1. C

    heck

    Nut

    &

    Bolt

    is in

    its

    plac

    e.

    2. C

    heck

    Nut

    &

    Bolt

    for p

    rope

    r

    tight

    enin

    g.

    3. C

    heck

    cla

    mp.

    Pri

    mar

    y S

    ecur

    ing:

    co

    nnec

    ted

    with

    nut

    &

    bolt

    and

    clam

    p.

  • Oman Society for Petroleum ServicesDROPS Management Standard

    Document No: OPAL-STD-HSE-04 Rev 0

    Issue Date: 01/08/2018

    Version 1 Page 32

    Om

    an S

    ocie

    ty fo

    r Pe

    trol

    eum

    Ser

    vice

    s

    DR

    OPS

    Man

    agem

    ent S

    tand

    ard

    Doc

    umen

    t No:

    OPA

    L-ST

    D-H

    SE-0

    4 R

    ev 0

    Issu

    e D

    ate:

    01/

    08/2

    018

    Vers

    ion

    1

    Page

    36

    of 3

    9

    ITE

    M

    DE

    SC

    RIP

    TIO

    N

    LOC

    ATI

    ON

    P

    HO

    TOG

    RA

    PH

    P

    HO

    TOG

    RA

    PH

    H

    OW

    TO

    IN

    SP

    EC

    T FA

    STE

    NIN

    G

    ME

    THO

    D

    CO

    ND

    ITIO

    N

    CO

    MM

    EN

    TS

    Pas

    s Fa

    il

    3 C

    row

    n M

    ain

    Shea

    ves

    (Mou

    ntin

    g)

    1. C

    heck

    bol

    ts

    are

    in it

    s pl

    ace.

    2.

    Che

    ck b

    olts

    for

    prop

    er s

    ecur

    ing.

    3.

    Che

    ck w

    elde

    d ar

    ea.

    Pri

    mar

    y S

    ecur

    ing:

    m

    ount

    ed o

    n th

    e w

    elde

    d ba

    se w

    ith

    bolts

    S

    econ

    dary

    R

    eten

    tion:

    w

    eldi

    ng.

    4

    Cro

    w