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Guidelines Part 23 Contents

GENERAL REQUIREMENTS

G23.4 Coordination of multiple-employer workplaces – Owner
G23.5 Safe work procedures
G23.8 Control of ignition sources
G23.9(5) Flare pits and flare lines – Ignition sources
G23.10 Fire extinguishers – Fracturing
G23.14(5) Pressure control measures at pumping wellheads
G23.15(1)(a) Power Engineers and Boiler and Pressure Vessel Safety Act repealed [Retired]
G23.22 Driver training
G23.26 Gauging – Safe access

DRILLING AND SERVICING RIGS

G23.39.1 Emergency escape systems for snubbing units
G23.39.2 Auxiliary escape
G23.43 Ventilation openings
G23.60 Rotary tongs
G23.61 23.5, and 12.3 Safeguarding at the rotary table area of drilling and service rigs

DRILL STEM TESTING, SWABBING, CEMENTING, WELL SERVICING AND STIMULATION

G23.64.1 Snubbing operations
G23.69 Flow piping
G23.69(3) Restraint of piping systems

PRODUCTION AND PLANT OPERATIONS

G23.80 Venting of trucks

Guidelines Part 23 - General requirements

G23.4 Coordination of multiple-employer workplaces – Owner

Issued August 1999; Editorial Revision June 14, 2013

Regulatory excerpt
Section 23.4 of the OHS Regulation ("Regulation") states, in part:

(1) If an activity involves the work of 2 or more employers or their workers, each employer must notify the owner, or the person engaged by the owner to be the prime contractor, in advance of any undertaking likely to create a hazard for a worker of another employer.

(2) If a work location has overlapping or adjoining work activities of 2 or more employers that create a hazard to workers,

(a) the owner, or if the owner engages another person to be the prime contractor, then that person, must

Section 106 of the Workers Compensation Act ("Act") defines "owner" as including

(a) a trustee, receiver, mortgagee in possession, tenant, lessee, licensee or occupier of any lands or premises used or to be used as a workplace, and

(b) a person who acts for or on behalf of an owner as an agent or delegate;

Purpose of guideline
This guideline explains who is typically the owner of an oil and gas plant.

Owner
The "owner" for the purpose of Part 23 is commonly termed the "operator," meaning the owner of the plant and of the license under which the operation runs. The fact that this person subcontracts the operation of the facility and has no workers at the site does not affect their status as "owner."

Additional obligations are placed on the owner by sections 23.31, 23.63, and 23.72 of the Regulation as well as owner obligations under the Act.

G23.5 Safe work procedures

Issued August 1999

Section 23.5 of the OHS Regulation ("Regulation") states:

(1) The employer must identify the work activities or circumstances, including releases of gases, that have caused or may cause significant risk of injury or occupational disease to workers.

(2) The employer must analyze the risks arising out of the work activities or circumstances identified under subsection (1) and implement safe work procedures if the activities or circumstances create a hazard.

(3) The procedures implemented under subsection (2) must state the number of workers involved, the steps to be followed and the safety equipment required.

The measures taken by the employer under this section must be consistent with the other sections of the Regulation.

Industry recommended practices
Consideration should be given under section 23.5 to recommended practices for safe work developed by recognized industry associations. These include the Industry Recommended Practices (IRPs) of the Petroleum Safety Council and the Alberta Recommended Practices (ARPs).

G23.8 Control of ignition sources

Issued August 1999; Editorial Revision June 14, 2013

Regulatory excerpt
Section 23.8 of the OHS Regulation ("Regulation") states, in part:

(1) If regular monitoring and hotwork permits are not in use to control ignition sources

(b) diesel engines required to operate within the zone defined by the BC Electrical Code and the Drilling and Production Regulation as a Class 1 Division 2 or higher classification must have a positive air shutoff or other effective method for engine shut down.

(2) Mobile equipment powered by a diesel engine and used for maintenance or repair work on pressurized gathering, distribution and transmission equipment must have a positive air shutoff or other effective method of engine shut down.

Purpose of guideline
This guideline gives examples of other effective methods for engine shut down.

Other effective methods for engine shut down
Some effective methods for engine shut down, other than a positive air shutoff include the following:

  • A system for injecting inert gas into the engine's cylinders, equipped with a readily accessible remote control
  • A suitable duct so that air for the engine is obtained at least 25 metres from a well (this allows shutting off the fuel to effectively stop the engine)
G23.9(5) Flare pits and flare lines – Ignition sources

Issued August 1999; Editorial Revision June 14, 2013

Regulatory excerpt
Section 23.9(5) of the OHS Regulation ("Regulation") states:

If feasible, there must be a continuous ignition source before flow to a flare pit or stack occurs.

Purpose of guideline
This guideline gives examples of additional ignition sources that are acceptable during drill stem testing.

Ignition sources
During drill stem testing, it is acceptable to use a lit tiger torch, diesel soaked bag of sawdust, or a burning pail of fuel, as a continuous ignition source, prior to flowing to the flare.

G23.10 Fire extinguishers – Fracturing

Issued August 1999; Editorial Revision June 14, 2013

Regulatory excerpt
Section 23.10(1) of the OHS Regulation ("Regulation") states:

Non-freezing fire extinguishers, other firefighting equipment and firefighting personnel must be provided as required by subsections (2), (3) and (4) and Table 23-1.

Table 23-1 of the Regulation states, in part, that:

Work activity Number of extinguishers required Type of extinguisher
1 fracturing tank 1 Twin agent unit
2, 3 or 4 fracturing tanks 1 Continuous foam unit with 100 barrel water truck
5 or more fracturing tanks or greater than 40% methanol water fracturing The fire hazard must be evaluated in accordance with current industry standards, and firefighting equipment and personnel must be provided as determined necessary by the evaluation.

Purpose of guideline
This guideline explains the firefighting equipment requirements for fracturing using hydrocarbon-based fluids.

Fracturing using hydrocarbon-based fluids
The firefighting equipment specified for fracturing jobs in Table 23-1 is required when fracturing using hydrocarbon-based fluids is done. The current industry standards for fire protection equipment can be found in Enform IRP Volume #8 Pumping of Flammable Fluids. IRP Volume #8 is available at

http://www.enform.ca/resources/detail/22/dacc-irp-volume-08-pumping-of-flammable-fluids.

G23.14(5) Pressure control measures at pumping wellheads

Issued January 1, 2007

Regulatory excerpt
Section 23.14(5) of the OHS Regulation ("Regulation") states:

For a wellhead utilizing a down-hole positive displacement pump, the employer must implement measures to prevent the pump from causing pressures exceeding the pressure rating of the system.

Purpose of guideline
This guideline describes what is meant by the "measures" referenced in section 23.14(5) and outlines an example of an acceptable set of measures. The measures deal with the parts of the system that can be over-pressurized as a direct result of a down-hole positive displacement pump not being shut down when necessary, and with the associated pressure sensors.

Control measures
Appropriate control measures will ensure that a down-hole positive displacement pump does not cause pressure exceeding the design pressure of the system. They will typically include a combination of equipment, procedures and training.

The measures are to be effective. That is, they will provide at least the same level of safety and reliability as the applicable design codes for pressure safety valves if such valves were used to ensure that the design pressure was not exceeded.

An appropriate set of measures will address the following four matters:

  1. Keyed locks or seals to physically prevent tampering with the settings of the pressure sensor switch that is part of the well shut-in safety system and any valve that may interfere with the correct operation of the sensor.
  2. Procedures to ensure that locks or seals that restrict access to the pressure sensing and emergency shutdown system may only be removed with the prior permission of a supervisor.
  3. Procedures to ensure that access to the emergency shutdown overpressure system is only permitted for purposes of maintenance or testing of that system, while using accurate gauges to monitor pressures.
  4. Procedures and training to ensure the safety of field service workers and to prevent unauthorized changes to the pressure sensor and overpressure emergency shutdown system.

To be effective, the measures must be fully implemented and maintained, and workers must receive appropriate training on the control measures.

G23.15(1)(a) Power Engineers and Boiler and Pressure Vessel Safety Act repealed

Issued August 13, 2008; Retired consequential to February 1, 2012 Regulatory Amendment

G23.22 Driver training

Issued August 1999; Reissued on January 1, 2009; Revised March 31, 2015

Regulatory excerpt
Section 23.22 of the OHS Regulation ("Regulation") states:

A vehicle driver in the oil and gas industry must, before operating a vehicle with a gross vehicle weight rating greater than 5 500 kg (12 000 lbs.),

(a) be certified in the applicable Enform Canada driver training course acceptable to the Board, or

(b) have completed driver training providing skills and knowledge for safe driving equivalent to or better than those required by paragraph (a).

Purpose of guideline
The purpose of this guideline is to list the Enform Canada driver training courses that have been evaluated and are acceptable to WorkSafeBC, and to provide information on driver training providing equivalent or better skills and knowledge.

Acceptable Enform courses
The following two Enform Canada courses currently are acceptable to WorkSafeBC for oilfield truck drivers operating vehicles with a gross vehicle weight rating greater than 5,500 kg:

  1. Oilfield Driver Awareness (ODA) course
  2. Oilfield Haulers course

Course descriptions and information about enrollment is available on the Enform Canada website. The ODA course has replaced the General Oilfield Driver Improvement (GODI) course. It is a one-day course intended for oilfield truck drivers operating vehicles with a gross vehicle weight rating of 5,500 kg or greater. Current GODI certificates will continue to be accepted while they are still valid. Upon expiration of the GODI certificate, the worker will take the ODA course.

The Oilfield Haulers course (formerly called the Heavy Haulers course) targets heavy haulers in the upstream petroleum service industry (e.g., oilfield bed trucks, tractor-trailer units, truck-mounted cranes, and gin pole trucks). These vehicles usually have their loads winched or hoisted, then chained down. The Oilfield Haulers course does not extend to other vehicles over 15,000 kg, such as water haulers, oil/condensate haulers, cement/fracturing trucks (pumpers), and service rig carriers.

For areas not covered by these courses, the ODA course will be accepted under section 23.22 of the Regulation until an acceptable program covering each area has been developed.

Equivalent driver training
Section 23.22(b) of the Regulation allows for alternative driver training providing skills and knowledge for safe driving are equivalent to or better than those required by training courses of Enform Canada. The Certification Services Department of WorkSafeBC (604-276-3090) can provide assistance to employers in evaluating whether another driver training course provides skills and knowledge equivalent to or better than the acceptable Enform Canada courses.

G23.26 Gauging – Safe access

Issued August 1999; Editorial Revision June 14, 2013

Regulatory excerpt
Section 23.26 of the OHS Regulation ("Regulation") states:

A tank which contains or may contain a fluid with hydrogen sulfide as a component must have an external means of gauging its contents, or if manual gauging or sampling is required, the worker doing the gauging or sampling must use a supplied air respirator meeting the requirements of Part 8 (Personal Protective Clothing and Equipment) for use in an IDLH atmosphere, and must be visually monitored by another worker equipped with an equivalent respirator and capable of effecting a rescue of the worker doing the gauging or sampling.

Section 4.32 of the Regulation states:

There must be a safe way of entering and leaving each place where work is performed and a worker must not use another way, if the other way is hazardous.

Purpose of guideline
This guideline explains the need for a safe way to access the top of the tank if manual gauging is used.

Manual gauging
Some external gauges do not provide the accuracy of manual gauging. When manual gauging is used, access to the top of the tank and stability of the worker may be a problem. In order to provide a safe means of gauging, an effective external gauge should be provided. If manual gauging is used, in addition to the requirements of section 23.26 the employer must provide a safe way of accessing the top of the tank. This should either be a stairway with a platform or a ladder safety device that provides work positioning and effective rescue capacity.

Guidelines Part 23 - Drilling and servicing rigs

G23.39.1 Emergency escape systems for snubbing units

Issued April 9, 2009

Regulatory excerpt
Section 23.39.1 of the OHS Regulation ("Regulation") states:

A drilling or service derrick must have an emergency means of escape from the racking board that complies with section 23.39.2 or 23.39.3.

Purpose of guideline
The purpose of this guideline is to provide guidance with respect to emergency escape systems on snubbing units.

Section 23.39 does not apply to snubbing units
Regulation sections 23.39.1, 23.39.2, and 23.39.3 do not apply specifically to snubbing units in the oil and gas industry. A snubbing unit is not considered to be a drilling or service derrick for the purposes of this section.

Safe means of egress from a snubbing unit
Although Regulation section 23.39 does not apply to snubbing units, there are other requirements for emergency egress, including the following two sections.

Regulation section 4.13 specifies that employers need to conduct a risk assessment in any workplace in which a need to rescue or evacuate workers may arise, and then develop and implement appropriate written procedures as necessary.

Regulation section 4.14(1) specifies that an emergency means of escape be provided from any work area in which the malfunctioning of equipment or a work process could create an immediate danger to workers and the regular means of exit could become dangerous or unusable.

IRP-15-2007 Snubbing Operations (published by Enform Canada) section 15.3.1.6 references slide poles on either side of the working platform for emergency escape. The IRP also calls for implementation of safer means of escape where the pole is not a viable egress option (e.g. high wellhead configurations). A Petroleum Services Association of Canada snubbing committee is researching emergency egress systems that provide quick deployment, are mobile, and are adaptable for rig in/out in the variety of environments in which rig assist snubbing units are used. Employers need to keep current with these developments and with the technological advancements for emergency egress from snubbing baskets, and employ more advanced and safer means of escape as they become available.

G23.39.2 Auxiliary escape

Issued August 1999; Editorial Revision January 1, 2009

Regulatory excerpt
Section 23.39.2(1)(d) of the OHS Regulation ("Regulation") states:

(1) A drilling or service derrick must have a specially rigged and securely anchored line as an emergency means of escape that

(d) is effectively anchored and able to withstand a load of 13.3 kN (3,000 lbs)

Purpose of guideline
The purpose of this guideline is to clarify what is meant by effectively anchored under section 23.39.2(1)(d) of the Regulation.

Effectively anchored
An anchor is effective if it will prevent the line from failing unless the load applied exceeds the anchor capacity. The employer must take measures to ensure the anchor is effective (see section 4.2). Measures to ensure the effectiveness of an anchor include:

  • Pull testing the anchor and documenting the test results
  • Using an auger/screw anchor set to a given depth and torque
  • Using a manufactured or engineer designed anchor system

In the case of the latter two items, standard drawings from the manufacturer or an engineer should be available.

G23.43 Ventilation openings

Issued August 1999; Revised February 11, 2004

Section 23.43(1) of the OHS Regulation states:

Before commencing drill stem tests, swabbing, bailing, or displacement with gas or oil

(a) derrick enclosures must be altered to provide openings at least 1.8 m (6 ft) high and 2.4 m (8 ft) wide on opposite sides above, and on 2 sides below, the derrick floor, or

(b) adequate mechanical ventilation or monitoring must be provided.

For the purpose of this section, "displacement with gas or oil" includes underbalanced drilling when temperatures are within 10 degrees of the flash point.

Monitoring

Section 23.43(1)(b) of the Regulation allows the option of "monitoring". If this option is used, safe work procedures (section 23.5) must be in place before commencing drill stem tests, swabbing, bailing, or displacement with gas or oil. The Board accepts the following procedures as complying with section 23.43(1)(b):

A. In addition to routine monitoring, instantaneous stationary detectors will normally be installed:

  • at the flow nipple in the substructure for LEL detection,
  • at floor level in the substructure for H2S detection, and
  • at the designated entrance to the substructure for LEL and H2S detection.

All alarms are clearly audible exterior to the substructure.

B. Procedures for gas alarm response as follows:

  1. The employer, prime contractor or owner if there is no prime contractor, must ensure appropriate personnel are able to:
    • install, inspect, maintain and operate personal protective equipment and air monitoring systems,
    • provide safety orientation,
    • conduct safety briefings,
    • conduct emergency drills, and
    • maintain rig location personnel count.
  2. Personal protective equipment and air monitoring systems are installed and function tested prior to doing drill stem tests, swabbing, bailing or displacement with oil or gas.
  3. Fire resistant clothing (coveralls, wet suits) are worn throughout the course of testing, from tool opening through initial circulation following testing, and during swabbing, bailing or displacement with oil or gas. Appropriate underclothing (for example, 100% tight weave cotton) is worn and hard hat liners are fire resistant.
  4. Continuous gas monitoring is in effect prior to commencing drill stem tests, swabbing, bailing or displacement with oil or gas. Alarms will activate when H2S exceeds 10 PPM and explosive gas exceeds 10% of LEL. Portable 3-way monitors, which measure oxygen, H2S and LEL, are acceptable. Alarms will be perceptible throughout the rig and clearly audible by personnel in the vicinity.

    Workers will not enter or remain in areas of the rig where harmful substances exceed limits listed in the Table of Exposure Limits for Chemical and Biological Substances (see OHS Guideline G5.48-1). In particular, sections 5.31 and 5.56 must be considered.

  5. Emergency procedures will be developed and followed in the event of an alarm situation (H2S gas concentration exceeds 10 ppm and LEL concentration exceeds 20%.) The following is an example of a minimum acceptable procedure:
    • ALL PERSONNEL WILL DON BREATHING APPARATUS and evacuate immediately upwind to the designated safe briefing area. All personnel on location will be notified and accounted for. A head count will be completed and rescue teams dispatched as warranted.
    • The site supervisor in consultation with the rig manager will determine to what extent rig power can safely be de-energized in the areas of the cellar, substructure, rig floor, derrick and doghouse.
    • Trained personnel (equipped with a portable/personal three way gas detector complete with probe) will proceed to remotely de-energize and lockout electrical components for areas where prefabs are to be removed. Electrical cords or switches will not be de-energized at source; rather, main breakers and locks will be used.
    • When non-essential rig power has been de-energized, trained personnel will remove prefabs in the affected areas if safe to do so.
    • Trained personnel equipped with portable/personnel three-way gas detector, complete with hose and probe, will provide emergency/rescue support.
    • Workers will not enter into or remain in an area containing 20% of LEL or greater except as permitted under section 5.31(d).
  6. Following drill stem testing, the pipe contents will be reverse circulated to flare in accordance with CAPP Drill Stem Testing Safety Guidelines (1984). Continuous monitoring will be in place until the drill string is circulated bottoms up at least twice.
  7. If tests indicate that the substructure or derrick enclosures have to be removed for adequate ventilation all crewmembers will wear:
    • fire resistant clothing,
    • pressure demand SCBA, and
    • portable monitors to ensure the LEL remains below 20%.
  8. Workers will be trained in:
    • use of air monitoring equipment and testing procedures,
    • use of personal protective equipment, and
    • safe removal of the substructure or derrick enclosure for adequate ventilation.
G23.60 Rotary tongs

Issued August 1999

Section 23.60 of the OHS Regulation states: "Rotary tongs must have
(a) a primary safety device to prevent uncontrolled movement of the tongs, and
(b) a secondary safety device that will activate if the primary device fails."

Safety devices are normally two wire rope safety lines. Single stand rigs should use two wire rope safety lines, not less than 1/2 inch (13 mm) in diameter. Larger rigs should use two wire rope safety lines, not less than 5/8 inch (16 mm) in diameter.

G23.61 23.5, and 12.3 Safeguarding at the rotary table area of drilling and service rigs

Issued October 26, 2005

Regulatory excerpt
Section 23.61 (Rotary table) of the OHS Regulation ("Regulation") states:

(1) If visibility on the rig floor is obscured, workers must not work there while the rotary table is in motion.

(2) Hoses, lines or chains must not be operated or handled near a rotary table while it is in motion.

(3) The rotary table must not be engaged until all workers are clear of the rotary table.

Section 23.5 (Safe work procedures) of the Regulation outlines the employer's obligations to identify and analyze risks at operations in the oil and gas sector, and to develop appropriate safe work procedures to address hazards.

Section 12.3 (Standards) of the Regulation states:

The application, design, construction and use of safeguards, including an opening in a guard and the reach distance to a hazardous part, must meet the requirements of CSA Standard Z432-94, Safeguarding of Machinery.

Purpose of guideline
The provisions of section 23.61 are straightforward. However, there are difficulties with installing physical guards in the rotary table area of drilling and service rigs under some of the guarding provisions of the CSA Standard referenced in section 12.3. This guideline provides information on other measures to consider for safeguarding in the rotary table area, pursuant to the CSA Standard and the employer's obligation to conduct a risk analysis and adopt safe work procedures as required under section 23.5 of the Regulation.

The CSA Standard and safeguards at the rotary table area
Machines, including drilling rigs, are required to comply with the safeguarding requirements of section 12.3 of the Regulation. Generally, the first choice for safeguarding a hazard is a physical barrier, but it is recognized that it is not usually possible to completely guard rotary tables in that manner.

The definition of a safeguard in the Regulation includes awareness barriers, warning signs and other appropriate means. In addition, the CSA Standard recognizes that physical barriers are not practicable in all situations. For example, section 4.2.2.7 of CSA Standard Z432-94 states:

It is necessary to inform and warn the users about residual hazards against which risk reduction by design and safeguarding techniques are not, or not totally, effective. The instructions and warnings shall describe the procedures and operating modes intended to overcome those hazards; indicate if a particular type of training is required; and, if it is necessary, specify personal protective equipment.

The following measures are provided as procedures and methods to overcome and safeguard against hazards in the area of the rotary table. They are in addition to the requirements of section 23.61 and other applicable provisions of the Regulation. For convenience, the mandatory requirements of section 23.61 are noted at locations where related issues are addressed in the list of measures for safeguarding.

Measures for safeguarding in the rotary table area

  1. All drilling and service rigs will clearly establish the rotary table area as a Danger Zone, which will include as much of the area around the rotary table as is practicable, according to the style and layout of each individual rig.
  2. The Danger Zone will be clearly identified to personnel by signs, visible markings or other similar means in a manner that reinforces the location of the Danger Zone.
  3. Personnel are permitted in the Danger Zone only during non-drilling operations and only after a hazard assessment has been conducted and communicated to all personnel.
  4. Entry into the Danger Zone will be limited only to workers and other personnel essential to the operations.
  5. All personnel will be clear of the Danger Zone while the rotary table is engaged and the driller's controls are unattended. In addition, during drilling operations, personnel will not enter the elevated section of the rotary table Danger Zone (area covered by safety matting) while the table is in motion.

    Also note that sections 23.61 (1) & (3) of the Regulation state: (1) If visibility on the rig floor is obscured, workers must not work there while the rotary table is in motion. (3) The rotary table must not be engaged until all workers are clear of the rotary table.

  6. When there are personnel within the Danger Zone, the rotary table will be restricted to a slow rate of speed and will be under the continuous direction of a designated driller positioned at the control console.
  7. There will be no equipment, hoses, tools, cables or other items that could potentially become entangled within the Danger Zone while the rotary table is engaged and the driller's controls are unattended. This may include steam hoses, water hoses, wash guns, air hoses and other such equipment.

    Also note that section 23.61(2) of the Regulation states: Hoses, lines or chains must not be operated or handled near a rotary table while it is in motion.

  8. Proper procedures will be followed for the donning, wearing, removing and storing of fall protection and related equipment. Procedures will include:
    • All harnesses and fall protection/arrest equipment will be donned and removed in a safe area away from the drilling floor. The Doghouse is recommended as such an area.
    • All lanyards, slings, carabineers and any other fall protection/arrest equipment used for work in the derrick will be stored in the Doghouse or another safe location. This equipment will not be carried or worn around the rig when no longer required for work operations.
    • No personnel may enter any designated Danger Zone while wearing a derrick harness or any additional fall protection or fall arrest equipment.
    • Workers' clothing or personal protective equipment (PPE) will be maintained in good working condition and worn so that it does not increase the risk of entanglement on or around any rotating equipment. Any loose, torn, damaged or otherwise hazardous PPE is prohibited in the Danger Zone and will be replaced.
  9. Prior to working in the area of the rotary table, personnel will be instructed in and understand the Danger Zone hazards and safe work procedures at the particular site.

Guidelines Part 23 - Drill stem testing, swabbing, cementing, well servicing and stimulation

G23.64.1 Snubbing operations

Issued January 1, 2009

Regulatory excerpt
Section 23.64.1 of the OHS Regulation ("Regulation") states:

A snubbing operation must be carried out in accordance with recognized industry safe work practices.

Purpose of guideline
This guideline describes snubbing operations, and describes one source of recognized industry safe work practices.

What is snubbing?
During the operating life of an oil or gas well, it is occasionally necessary to "rework" the well to enhance, maintain, or continue the production of hydrocarbons. This process frequently requires the removal and cleaning, or replacement, of tubing (piping) or other apparatus in the well bore.

Where practicable, the well will be "temporarily killed" by filling the well bore with high density fluids, doing the necessary reworking, and then removing the high density fluids and bringing the well back into production. However, sometimes the conditions in the well and reservoir do not allow the temporary killing of the well as the high density fluids may damage the hydrocarbon-bearing formation and render the well no longer productive. Snubbing is the petroleum industry operation to control well pressure and the movement of jointed tubulars (pipes) and tools in or out of a well bore using snubbing equipment. Snubbing allows the reworking of a "live well," and may even involve the continued production of hydrocarbon from the well during the reworking process.

Snubbing is being done more frequently in B.C.'s oil and gas production sector. It is a specialized operation due to the potential for the release of hydrocarbons, which means a potential for a fire or explosion, or exposure to an atmosphere which is oxygen deficient or contains toxic gases (such as hydrogen sulfide) making the atmosphere immediately dangerous to life and health.

Recognized industry safe work practices
The intent of Regulation section 23.64.1 is to ensure that proper guidance is available and practiced for snubbing operations, in the form of recognized safe work practices.

One source of recognized industry safe work practices is Industry Recommended Practice Volume 15-2007 Snubbing Operations (IRP-15). It has been developed by the oil and gas industry in western Canada for snubbing operations and is published by Enform Canada.

G23.69 Flow piping

Issued 1999; Revised December 19, 2013; Editorial Revision August 28, 2015

Regulatory excerpt
Section 23.69 of the OHS Regulation ("Regulation") states, in part:

(1) Flow piping systems must be anchored during well testing or stimulation unless there is an effective quality assurance program to ensure integrity of the piping system.

(2) The quality assurance program must include routine inspections, non-destructive testing, pressure testing, identification of piping components, and piping specifications that meet the service application.

(3) If swivel joints or hoses are used in well stimulation and similar operations, the piping system must be secured at the well head and supply vehicle or pumping unit end with wire rope safety lines not less than 11 mm (7/16 in) diameter, or chains of equal strength.

(4) Flowback lines must be anchored and restrained.

Purpose of guideline
The purpose of this guideline is to provide information on anchoring of flow piping systems and flowback lines, and to provide guidance on routine inspections of piping and component parts.

Anchoring and restraining
Section 23.69(1) – anchoring
This section of the Regulation requires that flow piping systems be anchored during well testing or stimulation unless there is an effective quality assurance program to ensure integrity of the piping system.

Anchoring can include weights adequately installed to prevent movement of piping. Generally, there should be one weight for each pipe joint.

An alternative method of anchoring is to drill anchors near to the pipe ends with a restraining cable running the length of the piping. The cable system should be continuous and secured at both ends, and all individual pressure components should be secured. When swivel joints or hoses are involved, restraining cables must not be less than 11 mm (7/16 in) diameter, or should be chains of equal or greater strength. Refer to comments below regarding the adequacy of wire rope safety lines.

Section 23.69(4) – anchoring and restraining
Flowback lines that are part of temporary processes like well testing and proving operations must be both anchored and restrained – there is no exception clause such as there is for section 23.69(1). The employer must assess the potential pressures that these lines could be experiencing during flowback operations and ensure that the system used is of adequate strength to restrain the forces that can occur during a line or fitting failure. The system needs to be of adequate strength to prevent these lines from undue lateral movement i.e., whipping back and forth. Common practice has been for employers to purchase and assemble separate component parts of their restraint systems: e.g., 11 mm (7/16 in) or ½ inch cable chokers attached by fall protection double acting clips attached to metal bridal clamps installed around the pipe line at each union and on the ends of the flow line. The flow lines are often anchored on one end to the well head and the other end to the vessel or flare stack.

Use of these component parts needs to include consideration of the lateral forces they could experience and the load limits the component manufacturers assign these parts when used in a manner outside their intended design e.g., many of these parts are designed by their manufacturers for a vertical load; not a lateral side load. The employer needs to ensure that the anchoring and restraint system being used will withstand the lateral forces that could be imposed in the event of a failure. Refer also to section 4.3(1) and (2) of the Regulation.

Quality assurance program
Program elements
Section 23.69(2) requires that the quality assurance program (commonly known in the oil and gas industry as an Operations and Maintenance Program (O&M Program) referred to in section 23.69(1) include routine inspections of piping and component parts, non-destructive testing, pressure testing, identification of piping components, and the use of piping components that are suitable for the service application.

The quality assurance program should include a list of the components to be inspected. The inspection process should define, for each item, what needs to be inspected, the frequency of inspection, how this frequency was determined, the inspection procedures, rejection criteria, and how the frequency of replacement of component parts is determined, including the basis for determining replacement.

Inspection and testing frequency
Well testing and stimulation work can subject equipment to exceptional short term corrosion and erosion. The frequency of inspections and testing required in a quality assurance program (O&M Program) will depend on the nature and frequency of the work. The frequency of the testing and inspection should be based on ongoing monitoring of the conditions in which the piping is exposed, rather than relying upon set intervals of inspection and testing.

Determination of the necessary inspection frequency should include consideration of the severity of service and fluctuating/high pressures and temperatures (note: severe service includes flowback of acids, solvents, a substance with a large amount of chloride, C02, or H2S, fracturing sand, or other well debris). As the service severity increases, the frequency of testing and inspection needs to increase. The quality assurance program (O&M Program) needs to respond to these types of changes in the dynamic nature of well stimulation operations to ensure that these flow piping systems do not fail in a catastrophic manner.

Record keeping
Records of testing and inspection should include the following information:

  • Item identification (e.g., part number, model, and manufacturer)
  • Date of inspection
  • Testing procedure used
  • Acceptance and rejection criteria
  • Inspection results (e.g., item is accepted for continued service or is rejected and removed from service)
  • Date of the next inspection or testing
  • Projected date of the next replacement
  • Signature of the inspector and inspecting service or agency
G23.69(3) Restraint of piping systems

Issued August 28, 2015

Regulatory excerpt
Section 23.69(3) of the OHS Regulation ("Regulation") states:

If swivel joints or hoses are used in well stimulation and similar operations, the piping system must be secured at the well head and supply vehicle or pumping unit end with wire rope safety lines not less than 11 mm (7/16 in) diameter, or chains of equal strength.

Section 4.3(1) of the Regulation states:

The employer must ensure that each tool, machine and piece of equipment in the workplace is

(a) capable of safely performing the functions for which it is used, and

(b) selected, used and operated in accordance with

(i) the manufacturer's instructions, if available,

(ii) safe work practices, and

(iii) the requirements of this Regulation.

Purpose of guideline
The purpose of this guideline is to explain that section 23.69(3) of the Regulation is not adequate on its own to address anticipated hazards. The guideline also provides information on safely securing piping systems or hoses used in well stimulation or similar operations.

Securing or restraining the piping system
With the significant increases in operating pressures in well testing and fracturing operations in recent years, an 11 mm (7/16 in) cable or a chain of equal strength may not be adequate to restrain piping systems or hoses from undue movement and whipping in the event of a line or union failure. An 11 mm (7/16 in) cable (or chain of equal strength), as specified in section 23.69(3) of the Regulation, may not have the capacity to restrain the piping system at the expected or actual loads, due to the high operating pressures encountered.

Employers need to ensure that the anchoring and restraint system will withstand the forces that could occur in the event of a failure of the piping system. An example of an adequate engineered restraint system is a purpose-built system composed of restraint and anchoring components which have been manufactured and engineered to be adequate for the operating pressures. Installation of the component parts for such a system needs to include consideration of the forces involved and the load limits the manufacturers assign these components. Refer also to section 4.3(1) of the Regulation regarding safe use of equipment.

Restraint systems that use components that are not specifically designed by the manufacturer for the purpose of flow piping restraint can be used for this purpose with detailed engineering instructions. These components (such as round slings) are usually designed by their manufacturers for lifting a vertical load, not the dynamic forces of a whipping pipe.

Examples of required detailed engineering instructions include the following:

  • Installation instructions
  • Engineering specifications and drawings of the restraint system (including a site specific plan, intermediate anchor points, and attachment to the piping system)
  • Precautionary information and limitations (such as the maximum pressure in the system and worker exclusion zones)
  • Testing certification (e.g., of the round slings and anchors)
  • Instructions for component use, maintenance, inspection and removal from service
  • Certification by a professional engineer that the restraint system has been engineered and is adequate for the purpose

Applicable sections of the Regulation and Workers Compensation Act ("Act")
Employers and other workplace parties involved in well stimulation and similar operations are required to use an adequate engineered restraint system to restrain piping systems or hoses. During an inspection, WorkSafeBC prevention officers will assess whether an adequate engineered restraint system meeting the performance criteria outlined in this guideline is in place, and will enforce section 115 of the Act, section 4.3(1) of the Regulation, and all other related provisions under the Act and the Regulation.

Guidelines Part 23 - Production and plant operations

G23.80 Venting of trucks

Issued 1999; Editorial Revision February 25, 2013

Regulatory excerpt
Section 23.80 of the OHS Regulation ("Regulation") states:

Tank trucks or loading facilities must have a system for protecting workers from hydrogen sulfide if it is present.

Purpose of guideline
This guideline gives examples of acceptable systems for protecting workers from hydrogen sulfide.

Systems for protecting workers
The following systems may be used for protecting workers from hydrogen sulfide at tank trucks or loading facilities:

  • Pressurized tank trucks
  • Atmospheric tanks with a suitable vapour gathering system
  • Scrubber system, truck-mounted or fixed
  • An enclosed system
Disclaimer: The Workers' Compensation Board of B.C. ("WorkSafeBC") publishes the online version Occupational Health and Safety Regulation ("OHS Regulation") in accordance with its mandate under the Workers Compensation Act to provide information and promote public awareness of occupational health and safety matters. The online OHS Regulation is not the official version of the OHS Regulation, which may be purchased from Crown Publications. WorkSafeBC endeavours to update the online OHS Regulation as soon as possible following any legislative amendments. However, WorkSafeBC does not warrant the accuracy or the completeness of the online OHS Regulation, and neither WorkSafeBC nor its board of directors, employees or agents shall be liable to any person for any loss or damage of any nature, whether arising out of negligence or otherwise, arising from the use of the online OHS Regulation. Employers are legally obligated to make a copy of the Workers Compensation Act and the OHS Regulation readily available for review by workers. The circumstances under which WorkSafeBC may consider an employer's providing access to electronic versions of the Act and OHS Regulation to have satisfied this obligation are described in Guideline G-D3-115(2)(f).