Views
3 years ago

SAFETY ALERT: Open Holes and Hole Guarding 7-12-2012

SAFETY ALERT: Open Holes and Hole Guarding 7-12-2012

SAFETY ALERT: Open Holes and Hole Guarding

Gulf of MexicoSAFETY ALERTGuidance on Open Holes and Open Hole GuardingNo. 2012-07-12Date: Thursday, July 12, 2012Issued By:Subject:John Garber, EH&S CoordinatorGuidance on Open Holes and Open Hole GuardingThis EH&S Compliance Alert is being published to provide guidance on Apache’s practices and policies regarding open holes.It is well known that open holes have been responsible for injuries and INC citations from BSEE in the Gulf of Mexico. Apacheis fully committed to providing a safe workplace for its employees and contractors and the elimination of open hole hazardsis of utmost importance.THE LAWOccupational health and safety regulations define an open hole as “a gap or void 2 inches...or more in its least dimension,in a floor, roof, or other walking/working surface." The standard mandates that workers must be protected from fallingthrough holes by fall arrest systems, guardrails or covers.Apache’s approach to openings in decks is that they must be covered, guarded, or otherwise made inaccessible when not inuse. The manner of guarding shall prevent a person’s foot or body from inadvertently passing through the opening. Anyopen hole that is created must be barricaded with hard pipe, cable or construction fencing in conjunction with cable toprevent personnel from falling through.Open holes are a prevalent hazard in offshore operations and emanate from a variety of sources including construction,production, P & A, drilling and work over operations where the working/walking surfaces are being built or repaired,holes designed or created for access to lower decks, missing grating due to maintenance lapses and others. The key is toimmediately identify their presence and eliminate the hazard.COVERSCovers of sufficient integrity with a “sure fit” are thepreferred method of correcting open holes. The coversshould be capable of supporting at least twice theweight of employees, materials or equipment that maybe imposed on the cover at any one time. Covers shallnot protrude more than 1” above the plane of thewalking surface and contain beveled edges. The covershould be secured to prevent accidental displacementby wind, equipment or employees. Finally, the holecover should be distinguishable by color coding(different color than surroundings) or be labeled as“Hole” or “Cover”.BARRIERSThe use of covers is often times not possible due to thenature of the planned work or the lack of suitable orsufficient materials to construct a cover. Constructing abarrier is the preferred method of mitigating the hazardin such cases. First, workers should be outfitted withproper fall protection if the open hole is present duringbarrier construction. Second, the barrier must beconstructed of sufficient strength and integrity toprevent workers from entering the area. The preferreddesign is standard railing that consists of top rail,intermediate rail and posts, and has a vertical height of42 inches. It should also be able to withstand a load ofat least 200 pounds applied in any direction at any pointon the top rail. The law also requires that a toe board orbottom rail be used if falling object hazards are presentfor individuals that might be working below. Toe boardsare a prudent measure in any case and their use isrecommended for all barriers, regardless of whether ornot work is being done below.1

Flotilla 12 7 - US Coast Guard Auxiliary, First District Southern Region
EH&S Compliance Alert - Gulf of Mexico Safety and Environmental ...