The CSB issues safety recommendations to prevent the recurrence or reduce the likelihood or consequences of similar incidents or hazards in the future. Recommendations are issued to a variety of parties, including government entities, safety organizations, trade unions, trade associations, corporations, emergency response organizations, educational institutions, and public interest groups. Recommendations are published in CSB reports and are closed only by vote of the Board. The CSB tracks all recommendations and communicates regularly with recommendations recipients to ensure that the recommended corrective actions are implemented. For more information, see Frequently Asked Questions about CSB recommendations.
2017-03-I-LA-1
Apply the CSB safety guidance to PCA pulp and paper mills that produce NCG and operate NCG systems, which includes all foul condensate tanks. For these NCG systems: Apply effective process safety management elements using good practice guidance, such as CCPS Guidelines for Risk Based Process Safety, and Guidelines for Implementing Process Safety Management; Consider further expanding process safety management program boundaries beyond the minimum legal requirements to provide heightened coverage of process safety hazards; Apply NFPA 69, Standard on Explosion Prevention Systems, to provide effective explosion prevention; Where explosions cannot be prevented in accordance with NFPA 69, apply NFPA 68, Standard on Explosion Protection by Deflagration Venting, to provide explosion protection; Ensure safety instrumented systems (safety interlocks) achieve desired risk reduction by applying the life-cycle approach provided in ISA-84, Functional Safety: Safety Instrumented Systems for the Process Industry Sector; Apply TIP 0416-09, Collection and burning of concentrated noncondensible gases: regulations, design and operation, for effective NCG system design and operation; Provide workers with periodic training to ensure they have an understanding of all process safety hazards applicable to areas of their responsibility and job tasks, including the safety conditions needed to permit hot work. Status: Closed - Acceptable Action
Apply the CSB safety guidance to PCA pulp and paper mills that produce NCG and operate NCG systems, which includes all foul condensate tanks. For these NCG systems:
2006-7-I-MS-3
Establish a program to identify and refer to the federal Occupational Safety and Health Administration (OSHA) potentially unsafe health and safety conditions observed during board field inspections of well sites and drilling operations. Ensure that the program includes: -Written procedures that define how the referrals will be implemented; and, -Training of field inspectors so that they are able to recognize the potentially unsafe health and safety conditions that should be referred to OSHA. Status: Closed - Reconsidered/Superseded
Establish a program to identify and refer to the federal Occupational Safety and Health Administration (OSHA) potentially unsafe health and safety conditions observed during board field inspections of well sites and drilling operations. Ensure that the program includes: -Written procedures that define how the referrals will be implemented; and, -Training of field inspectors so that they are able to recognize the potentially unsafe health and safety conditions that should be referred to OSHA.
2006-7-I-MS-4
Implement a Local Emphasis Program (LEP) to inspect companies in the oil and gas production and extraction sector. Status: Closed - Acceptable Alternative Action
Implement a Local Emphasis Program (LEP) to inspect companies in the oil and gas production and extraction sector.
2006-7-I-MS-2
Establish written health and safety performance standards and performance metrics such as those found in Recommended Practice for Occupational Safety for Onshore Oil and Gas Production, API RP-74. Status: Closed - No Longer Applicable
Establish written health and safety performance standards and performance metrics such as those found in Recommended Practice for Occupational Safety for Onshore Oil and Gas Production, API RP-74.
2006-7-I-MS-1
Develop and implement written procedures to ensure safe work practices during hot work, tank cleaning, and work at elevated locations. Status: Closed - Acceptable Action
Develop and implement written procedures to ensure safe work practices during hot work, tank cleaning, and work at elevated locations.
2005-5-I-MO-1
Communicate with your members who operate gas repackaging facilities the details of this incident and the best practices for handling and storing cylinders. Status: Closed - Acceptable Action
Communicate with your members who operate gas repackaging facilities the details of this incident and the best practices for handling and storing cylinders.
2005-5-I-MO-2
Revise CGA standards for the CG-7 relief valves used in propylene service to require: 1) a greater margin between vapor pressure and relief valve set point (similar to propane); and 2) that valves be capable of multiple operations within the specified setpoint tolerance or be furnished with an indicator that alerts users that the valve has operated. Status: Closed - Acceptable Action
Revise CGA standards for the CG-7 relief valves used in propylene service to require: 1) a greater margin between vapor pressure and relief valve set point (similar to propane); and 2) that valves be capable of multiple operations within the specified setpoint tolerance or be furnished with an indicator that alerts users that the valve has operated.
2018-01-I-OK-2
Establish and convene a group of experts with drilling, engineering, and instrumentation expertise to discuss methods to achieve widespread implementation of automatic safety instrumented systems that could bring a well to a safe state in the event other operational barriers fail. Publish a technical bulletin discussing the strategies to implementing Blowout Preventer (BOP) safety instrumented systems. Status: Closed - Acceptable Action
Establish and convene a group of experts with drilling, engineering, and instrumentation expertise to discuss methods to achieve widespread implementation of automatic safety instrumented systems that could bring a well to a safe state in the event other operational barriers fail. Publish a technical bulletin discussing the strategies to implementing Blowout Preventer (BOP) safety instrumented systems.
2018-01-I-OK-3
For onshore drilling operations, develop and publish a recommended practice providing guidance on safely tripping drill pipe during (1) overbalanced drilling operations, (2) managed pressure drilling operations, and (3) underbalanced drilling operations. At a minimum, include information on: (a) Required equipment for tripping operations, (b) Techniques and procedures for controlling or preventing formation fluid influx, and (c) Methods to monitor the well and replace the drill pipe displacement volume with drilling fluid (e.g., mud). Status: Open - Awaiting Response or Evaluation/Approval of Response
For onshore drilling operations, develop and publish a recommended practice providing guidance on safely tripping drill pipe during (1) overbalanced drilling operations, (2) managed pressure drilling operations, and (3) underbalanced drilling operations. At a minimum, include information on:
(a) Required equipment for tripping operations,
(b) Techniques and procedures for controlling or preventing formation fluid influx, and
(c) Methods to monitor the well and replace the drill pipe displacement volume with drilling fluid (e.g., mud).
2018-01-I-OK-4
Develop a recommended practice on alarm management specifically for the drilling industry based on guidance in ANSI/ISA 18.2 Management of Alarm Systems for the Process Industries. The recommended practice will address the unique dynamic environment of the drilling industry and provide guidance on implementing a state-based alarm system for different operating modes (e.g., drilling, circulating, tripping, etc.). Include International Association of Drilling Contractors (IADC) in the development of this recommended practice. Status: Open - Awaiting Response or Evaluation/Approval of Response
Develop a recommended practice on alarm management specifically for the drilling industry based on guidance in ANSI/ISA 18.2 Management of Alarm Systems for the Process Industries. The recommended practice will address the unique dynamic environment of the drilling industry and provide guidance on implementing a state-based alarm system for different operating modes (e.g., drilling, circulating, tripping, etc.). Include International Association of Drilling Contractors (IADC) in the development of this recommended practice.
2018-01-I-OK-5
Develop a new recommended practice or modify an existing recommended practice (e.g. API RP 54 Recommended Practice for Occupational Safety for Oil and Gas Well Drilling and Servicing Operations) addressing the protection of rig workers on onshore drilling rigs from fire and explosion hazards in the event of a blowout. The recommended practice will specifically address: (a) Protecting drilling cabin occupants from blowout hazards including heat, blast overpressure, and projectiles, such as requiring an increased fire rating for the driller’s cabin that would allow enough time for occupants to evacuate during a blowout and fire; (b) Minimum required evacuation methods from the drilling cabin, rig floor, and mast or derrick in the event of a blowout so that personnel can quickly escape in variable hazard location conditions. For example, floor exit hatches and exits on the driller’s cabin wall opposite the rig floor could provide safe evacuation routes during a blowout and fire; and (c) Proximity of the Blow Out Preventer (BOP) activation controls with the driller. The above options could be retrofitted on existing drilling rigs. Additionally, formally evaluate alternative locations for the drilling cabin that establishes a safe distance from fire and explosion hazards (e.g., ground level). Status: Closed - Acceptable Action
Develop a new recommended practice or modify an existing recommended practice (e.g. API RP 54 Recommended Practice for Occupational Safety for Oil and Gas Well Drilling and Servicing Operations) addressing the protection of rig workers on onshore drilling rigs from fire and explosion hazards in the event of a blowout. The recommended practice will specifically address:
(a) Protecting drilling cabin occupants from blowout hazards including heat, blast overpressure, and projectiles, such as requiring an increased fire rating for the driller’s cabin that would allow enough time for occupants to evacuate during a blowout and fire;
(b) Minimum required evacuation methods from the drilling cabin, rig floor, and mast or derrick in the event of a blowout so that personnel can quickly escape in variable hazard location conditions. For example, floor exit hatches and exits on the driller’s cabin wall opposite the rig floor could provide safe evacuation routes during a blowout and fire; and
(c) Proximity of the Blow Out Preventer (BOP) activation controls with the driller.
The above options could be retrofitted on existing drilling rigs. Additionally, formally evaluate alternative locations for the drilling cabin that establishes a safe distance from fire and explosion hazards (e.g., ground level).
2018-01-I-OK-6
Update API Bulletin 97 Well Construction Interface Document Guidelines to specify that it applies to both onshore and offshore drilling operations. Status: Closed - Acceptable Alternative Action
Update API Bulletin 97 Well Construction Interface Document Guidelines to specify that it applies to both onshore and offshore drilling operations.
2018-01-I-OK-14
Participate in development of the recommended practice describe in recommendation 2018-01-OK-R4 to [American Petroleum Institute] API. Status: Open - Awaiting Response or Evaluation/Approval of Response
Participate in development of the recommended practice describe in recommendation 2018-01-OK-R4 to [American Petroleum Institute] API.
2018-01-I-OK-17
Design the M/D Totco user interface to allow drilling contractors to pre-set different alarms for different operations (e.g., different alarm configurations for drilling, tripping, circulating, and surface operations in a “state-based” alarm system). Status: Closed - Acceptable Action
Design the M/D Totco user interface to allow drilling contractors to pre-set different alarms for different operations (e.g., different alarm configurations for drilling, tripping, circulating, and surface operations in a “state-based” alarm system).
2018-01-I-OK-18
Design the M/D Totco electronic drilling data system so that alarm information, including alarm set points, alarm activation log, alarm horn status (on or off), and alarm system status (on or off) is provided to customers. Status: Closed - Acceptable Action
Design the M/D Totco electronic drilling data system so that alarm information, including alarm set points, alarm activation log, alarm horn status (on or off), and alarm system status (on or off) is provided to customers.
2018-01-I-OK-1
Implement one of the three following options regarding regulatory changes: (a) OPTION 1: Apply the Process Safety Management (PSM) standard (29 CFR 1910.119) to the drilling of oil and gas wells; or (b) OPTION 2: Apply the Process Safety Management (PSM) standard (29 CFR 1910.119) to the drilling of oil and gas wells as in OPTION 1, and make the necessary modifications to customize it to oil and gas drilling operations; or (c) OPTION 3: Develop a new standard with a safety management system framework similar to PSM that applies only to the drilling of onshore oil and gas wells that includes but is not limited to the following: Detailed written operating procedures with specified steps and equipment alignment for all operations; Written procedures for the management of changes (except replacements in kind) in procedures, the well plan, and equipment; A risk assessment of hazards associated with the drilling plan; A requirement to follow Recognized and Generally Accepted Good Engineering Practices (RAGAGEP); Development of a Well Construction Interface Document between the operator and the drilling contractor prior to the commencement of drilling activities which at a minimum includes a bridging document and well plan specifying barriers and how to manage them; The performance and documentation of flow checks using acceptable methods at defined points during the operation for a specified duration; and A requirement for employee participation, similar to the Employee Participation requirement in the OSHA PSM standard. Status: Closed - Reconsidered/Superseded
Implement one of the three following options regarding regulatory changes:
(a) OPTION 1: Apply the Process Safety Management (PSM) standard (29 CFR 1910.119) to the drilling of oil and gas wells; or
(b) OPTION 2: Apply the Process Safety Management (PSM) standard (29 CFR 1910.119) to the drilling of oil and gas wells as in OPTION 1, and make the necessary modifications to customize it to oil and gas drilling operations; or
(c) OPTION 3: Develop a new standard with a safety management system framework similar to PSM that applies only to the drilling of onshore oil and gas wells that includes but is not limited to the following:
Detailed written operating procedures with specified steps and equipment alignment for all operations;
Written procedures for the management of changes (except replacements in kind) in procedures, the well plan, and equipment;
A risk assessment of hazards associated with the drilling plan;
A requirement to follow Recognized and Generally Accepted Good Engineering Practices (RAGAGEP);
Development of a Well Construction Interface Document between the operator and the drilling contractor prior to the commencement of drilling activities which at a minimum includes a bridging document and well plan specifying barriers and how to manage them;
The performance and documentation of flow checks using acceptable methods at defined points during the operation for a specified duration; and
A requirement for employee participation, similar to the Employee Participation requirement in the OSHA PSM standard.
2018-01-I-OK-15
Design the Pason user interface to allow drilling contractors to pre-set different alarms for different operations (e.g., different alarm configurations for drilling, tripping, circulating, and surface operations in a “state-based” alarm system). Status: Closed - Acceptable Alternative Action
Design the Pason user interface to allow drilling contractors to pre-set different alarms for different operations (e.g., different alarm configurations for drilling, tripping, circulating, and surface operations in a “state-based” alarm system).
2018-01-I-OK-16
Design the Pason electronic drilling data system so that alarm information, including alarm set points, alarm activation log, alarm horn status (on or off), and alarm system status (on or off) is provided to customers. Status: Closed - Acceptable Action
Design the Pason electronic drilling data system so that alarm information, including alarm set points, alarm activation log, alarm horn status (on or off), and alarm system status (on or off) is provided to customers.
2018-01-I-OK-7
Develop either corporate or rig-specific tripping procedure(s) that detail the required equipment configuration for tripping operations. Require that rig personnel visually verify that equipment is lined up as specified in the procedure before beginning the tripping operation. In the procedure(s), specify well-monitoring requirements for wet versus dry tripping operations. Status: Closed - Acceptable Action
Develop either corporate or rig-specific tripping procedure(s) that detail the required equipment configuration for tripping operations. Require that rig personnel visually verify that equipment is lined up as specified in the procedure before beginning the tripping operation. In the procedure(s), specify well-monitoring requirements for wet versus dry tripping operations.
2018-01-I-OK-8
Develop an alarm philosophy and alarm rationalization for rig operations. Based on the alarm philosophy and alarm rationalization, specify necessary alarms, at a minimum, for (1) drilling, (2) tripping, (3) circulating, and (4) rig floor activities (no drill pipe in well). Additionally, develop a policy implementing the alarm philosophy and rationalization. Status: Closed - Acceptable Alternative Action
Develop an alarm philosophy and alarm rationalization for rig operations. Based on the alarm philosophy and alarm rationalization, specify necessary alarms, at a minimum, for (1) drilling, (2) tripping, (3) circulating, and (4) rig floor activities (no drill pipe in well). Additionally, develop a policy implementing the alarm philosophy and rationalization.
2018-01-I-OK-9
Develop a policy that incorporates recommendations in API RP 59 Recommended Practice for Well Control Operations requiring the regular testing of drillers’ influx detection and response skills through formalized drills, for example by “simulat[ing] a gain in pit drilling fluid volume by raising a float sufficiently to cause an alarm to be activated.” In this policy, require that driller response time is monitored in the spirit of continual improvement. Status: Closed - Acceptable Action
Develop a policy that incorporates recommendations in API RP 59 Recommended Practice for Well Control Operations requiring the regular testing of drillers’ influx detection and response skills through formalized drills, for example by “simulat[ing] a gain in pit drilling fluid volume by raising a float sufficiently to cause an alarm to be activated.” In this policy, require that driller response time is monitored in the spirit of continual improvement.
2018-01-I-OK-10
Develop and implement a policy requiring that flow checks be documented, either electronically or with a paper record. At a minimum the documentation will require the reporting of: Operation during which flow check was performed Method of performing flow check Length of time flow check was performed Result of flow check Require that the proper authorities (e.g., driller, company man, rig manager) sign or approve the flow check documentation after performing the flow check and before resuming operations. Keep the flow check documentation as part of the well file. Status: Closed - Acceptable Action
Develop and implement a policy requiring that flow checks be documented, either electronically or with a paper record. At a minimum the documentation will require the reporting of:
Operation during which flow check was performed
Method of performing flow check
Length of time flow check was performed
Result of flow check
Require that the proper authorities (e.g., driller, company man, rig manager) sign or approve the flow check documentation after performing the flow check and before resuming operations. Keep the flow check documentation as part of the well file.
2018-01-I-OK-11
Update the Patterson metrics program to track leading and lagging indicators to measure the effectiveness of the overall safety management system. Specifically focus on measuring the effectiveness of the following safety management system components: (a) The effectiveness of the flow check policy, including the frequency that flow checks are performed when required by Patterson policy; (b) The frequency that flow checks are documented and approved as recommended in 2018-01-OK-R10; (c) The effectiveness of the management of change program, for both equipment and procedural changes, including real-time procedure changes; (d) The frequency that alarms are set at the required set points; (e) The frequency that drilling rig alarm horns or the entire alarm system is turned off; and (f) The frequency that trip sheets are filled out properly. Status: Open - Acceptable Response or Alternate Response
Update the Patterson metrics program to track leading and lagging indicators to measure the effectiveness of the overall safety management system. Specifically focus on measuring the effectiveness of the following safety management system components:
(a) The effectiveness of the flow check policy, including the frequency that flow checks are performed when required by Patterson policy;
(b) The frequency that flow checks are documented and approved as recommended in 2018-01-OK-R10;
(c) The effectiveness of the management of change program, for both equipment and procedural changes, including real-time procedure changes;
(d) The frequency that alarms are set at the required set points;
(e) The frequency that drilling rig alarm horns or the entire alarm system is turned off; and
(f) The frequency that trip sheets are filled out properly.
2018-01-I-OK-12
Develop a new policy that a well-specific Well Construction Interface Document be in place before drilling operations begin, as specified in API Bulletin 97 Well Construction Interface Document Guidelines. Ensure the policy requires that the Well Construction Interface Document specifies the technical requirements of the rig equipment and technical qualifications of personnel (e.g., conventional drilling, managed pressure drilling, underbalanced drilling) as well as specifies which barriers must be maintained and the expected response if a barrier is lost. Status: Closed - Unacceptable Action/No Response Received
Develop a new policy that a well-specific Well Construction Interface Document be in place before drilling operations begin, as specified in API Bulletin 97 Well Construction Interface Document Guidelines. Ensure the policy requires that the Well Construction Interface Document specifies the technical requirements of the rig equipment and technical qualifications of personnel (e.g., conventional drilling, managed pressure drilling, underbalanced drilling) as well as specifies which barriers must be maintained and the expected response if a barrier is lost.
2018-01-I-OK-13
Develop a management of change policy governing real-time changes to operations and the drilling plan. As part of this policy, require hazard analysis and consideration of rig equipment, procedures, and personnel training and qualifications. Status: Closed - Unacceptable Action/No Response Received
Develop a management of change policy governing real-time changes to operations and the drilling plan. As part of this policy, require hazard analysis and consideration of rig equipment, procedures, and personnel training and qualifications.
2018-01-I-OK-19
Establish and implement safety regulations requiring entities who design oil and gas well drilling plans for wells in Oklahoma (e.g., operators) and entities who perform the drilling operation (e.g., drilling contractors) to develop and implement the following prior to conducting drilling operations: (a) Detailed written operating procedures with specified steps and equipment alignment for all operations; (b) Written procedures for the management of changes (except replacements in kind) in procedures, the well plan, and equipment; (c) A risk assessment of hazards associated with the drilling plan; (d) A requirement to follow Recognized and Generally Accepted Good Engineering Practices (RAGAGEP); (e) Development of a Well Construction Interface Document between the operator and the drilling contractor prior to the commencement of drilling activities which at a minimum includes a bridging document and well plan specifying barriers and how to manage them; (f) The performance and documentation of flow checks using acceptable methods at defined points during the operation for a specified duration; and (g) A requirement for employee participation, similar to the Employee Participation requirement in the OSHA PSM standard. Status: Open - Unacceptable Response/No Response Received
Establish and implement safety regulations requiring entities who design oil and gas well drilling plans for wells in Oklahoma (e.g., operators) and entities who perform the drilling operation (e.g., drilling contractors) to develop and implement the following prior to conducting drilling operations:
(a) Detailed written operating procedures with specified steps and equipment alignment for all operations;
(b) Written procedures for the management of changes (except replacements in kind) in procedures, the well plan, and equipment;
(c) A risk assessment of hazards associated with the drilling plan;
(d) A requirement to follow Recognized and Generally Accepted Good Engineering Practices (RAGAGEP);
(e) Development of a Well Construction Interface Document between the operator and the drilling contractor prior to the commencement of drilling activities which at a minimum includes a bridging document and well plan specifying barriers and how to manage them;
(f) The performance and documentation of flow checks using acceptable methods at defined points during the operation for a specified duration; and
(g) A requirement for employee participation, similar to the Employee Participation requirement in the OSHA PSM standard.