Petroleum & Gas Inspectorate | Alert | No.114 V 1 | 15 May 2023
Compliance with competency standard for petroleum and gas well drilling and well servicing
What happened?
An operator of drilling operating plant has been unable to demonstrate compliance with a safety requirement to ensure its workers have the mandated competencies to conduct work at well sites. [Drilling operating plant is plant used to drill, complete, maintain or work on, plug and abandon a petroleum well]
How did it happen?
An audit of how the operator’s safety management system met requirements in section 675 of the Petroleum and Gas (Production and Safety) Act 2004 (the Act) for a skills assessment of its workers and their training program revealed unacceptably high levels of personnel without qualifications, and excessive reliance on direct supervision.
Key issues
- The competency standard for petroleum and gas well drilling and servicing (the Competency Standard) lists the minimum qualifications a person must attain, or be enrolled in, to be competent in an operational position of a drilling or well service rig. Attainment of the qualification or enrolment must be in place prior to commencing work on drilling operating plant.
- The Competency Standard calls up qualifications under the nationally recognised Resources and Infrastructure (RII) training package.
- Operators of drilling and well servicing operating plant are required to ensure their rig crews have the relevant competencies in the Competency Standard. This is a prescribed safety requirement in section 21 of the Petroleum and Gas (Safety) Regulation 2018. Section 21 provides two options for achieving the safety requirement:
- Option 1: the person attains the relevant RII qualification for their position;
- Option 2: the person is enrolled and undergoing training under direct supervision to attain the relevant RII qualification for their position and is acting under the direct supervision of a competent person.
- ‘Direct supervision’ means the competent person must be able to provide face-to-face supervision every shift to clearly instruct the trainee on the work site and hold the necessary competency they are supervising the trainee in.
- In practice, workers must hold all relevant competencies up to and including for their position, to demonstrate compliance with ‘hands on’ experience as set out in Table A and Table B in the Competency Standard and reproduced below.
- Records generated to demonstrate safety management system requirements e.g., certificates of competency, must be open for inspection at the operating plant as required by section 678A of the Act.
- The Competency Standard also establishes obligations for petroleum and gas tenure holders to ensure these legislative competency requirements are met by their drilling and well servicing contractors. The Competency Standard also requires tenure holders to conduct audits to ensure ongoing compliance.
Recommendations
Operators of drilling and well servicing operating plant should:
- review their safety management system to ensure each person who works to drill or service a petroleum well or bore, meets the competencies in the Competency Standard for drilling or servicing a petroleum well and
- ensure the skills and training records required in their safety management system are in order to demonstrate competency and are available to the Inspectorate upon request
Tenure holder operators should:
- review their ‘contract management’ arrangements to ensure legislated competency requirements for drilling and well servicing operating plant at wells are being met and
- undertake appropriate audits to ensure ongoing compliance.
Investigations are ongoing and further information may be published as it becomes available. The information in this publication is what is known at the time of writing.
We issue Safety Notices to draw attention to the occurrence of a serious incident, raise awareness of risks, and prompt assessment of your existing controls.
References and further information
Competency standard for petroleum and gas well drilling and well servicing, v4, 1 September 2018.
Petroleum and Gas (Production and Safety) Act 2004
Petroleum and Gas (Safety) Regulation 2018
Contact: Nathan Wilkins, Principal Inspector Petroleum & Gas , 0455 069 158 nathan.wilkins@rshq.qld.gov.au
Issued by Resources Safety & Health Queensland
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