Marking of emergency-use attachment points and lifting equipment
Article published in the Regulator Issue 3:2015
In recent facility inspections, NOPSEMA inspectors have found that some permanent attachment points and other lifting equipment used in emergencies are not being subject to regular inspection or testing.
Permanent attachment points, such as davits and padeyes with shackles or master links, are routinely used as lifting equipment in emergency-response, for example casualty extraction. They are typically found at the top of engine and pump room emergency escape tunnels. Other emergency-response arrangements including ‘donut’ descent type arrangements and attachment points on a MODU derrick are often exposed to conditions causing deterioration.
It is good practice to implement a colour-coding system, along with a tag number and safe working load (SWL) markings. This practice indicates that the lifting equipment and permanent attachment points have been appropriately tested and/or inspected within a specified time period, typically six months. This practice is also supported by a number of international standards and codes of practice, including the International Association of Oil and Gas Producers ‘Lifting and Hoisting Safety Recommended Practice 2006’, NORSOK standard R-003:2014 and Canadian Association of Petroleum Producers Standard Practice 2013-0012 ‘Safe Lifting Practice’.
During recent planned facility inspections, NOPSEMA inspectors identified that some permanent attachment points and other lifting equipment were not being managed under a colour-coding system with relevant markings, or were not subject to regular inspection or testing. Some equipment was also found in poor condition.
When permanent attachment points and other lifting equipment are not tagged with a colour-code, or otherwise marked, members of the workforce cannot be certain that the equipment is safe to use and that the necessary thorough examinations have taken place. This certainty is important because in an emergency situation there may not be time or competent personnel available to conduct this verification.
Operators are advised that they should review their integrity assurance management system for permanent attachment points and other lifting equipment at their facilities. Such reviews will ensure that all lifting equipment and associated attachment points intended for emergency-use are maintained and fit-for-purpose, and tagged or marked accordingly.
Clause 9(2)(e) of Schedule 3 of the OPGGS Act requires that operators take all reasonably practicable steps to maintain equipment for responding to emergencies. NOPSEMA inspectors will continue to check the fitness of facility emergency response and evacuation equipment during inspections and enforcement action will be considered where operators are unable to demonstrate an adequate assurance program.