The Health and Safety Executive (HSE) requires industry bodies, such as the Association of Geotechnical and Geoenvironmental Specialists (AGS) and British Drilling Association (BDA) (who represent the majority of the land drilling sector), to provide guidance to their own sectors through documented standards of good practice and guidance to help ensure legal compliance and encourage safety improvements.

The relationship between drilling machines and the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER) has been regularly contested as the primary use of a drilling machine is not to lift, thus precluding a drilling machine from the scope of LOLER. However, the components forming, and added to the mechanism in order to create a borehole, are the same as those used by machines for lifting. It is therefore prudent that the drilling industry implements robust examination and certification requirements to ensure the safe operation of the drilling machine.

Current AGS and BDA guidance documents, combined with the BDA audit, require that the maintenance and inspection requirements of drilling machines should be undertaken to the same standard, with regards to competence, thoroughness, and recording, as that required for components legislated for by LOLER.

Following consultation with the Health and Safety Executive (HSE), and subsequently underpinned by the release of L113 Safe use of lifting Equipment, (HSE 2014), the land drilling sector represented by the AGS and BDA:

• mirrored the requirements of LOLER, where it could be applied,
• reinforced the Provision and Use of Work Equipment Regulations 1998 (PUWER) in its

Why has the drilling industry chosen to mirror elements of LOLER?

The mechanism for progressing a borehole is either, rotational, resonance or percussion, or a combination. It is reasonable to conclude that a drilling machine is not designed “for” lifting or lowering loads but for creating boreholes; confirming that a drilling machine cannot be tested against LOLER as it fails at the first hurdle.

To explain why aspects of LOLER 1998 are adopted; an understanding of the failure modes that are aligned between machines designed for lifting and machines designed for drilling must be considered. Both types primarily use either or a combination of steel wire ropes, sheaves, and winches. Additional components are used on both types, to connect auxiliary items to enable the activity to take place. Therefore, both types of machines will have similar failure characteristics caused by overloading, under rating, damage and deterioration due to use or working environment. Where failure modes are aligned it is obvious that mitigation of failure should also be aligned.

Which elements of LOLER 1998 are applied to drilling machines?

LOLER prescribes (regulation 9, 10 & 11), and the AGS and BDA supports, a regime of inspection with two significant, prerequisites which are:

1. A specific regime for inspection; annual thorough examination of the drilling machines and six- monthly thorough examination of accessories, and
2. A legal onus emphasising that the competent person (for examination), “must be sufficiently independent and impartial to allow objective decisions to be made”.

Where specific tooling, used by drilling machines, to enable the lifting process does not currently conform to LOLER inspection or examination, the manufacturer should be consulted to obtain the Safe Working Load (SWL) in order that the equipment can be added to an inspection regime.

Examination certification shall mirror Schedule 1 of LOLER and contain the following particulars:

• Name and address of the company for whom the examination was made,
• Address of the premises at which the thorough examination was made,
• Sufficient identification of the drilling machine, its winches, ropes and lifting accessories including, where known, their date of manufacture,
• The date of the last thorough examination,
• The safe working load (SWL) of the drilling machine, its winches, its accessories, and the Factor of Safety (FOS) applied to each,
• The type of examination e., six monthly inspection or annual examination or if after the occurrence of exceptional circumstances,
• Identification of any part that had a defect which is or could become a danger to persons, detailing the description of the defect,
• Any repair, renewal or alteration required to remedy a defect found to be a danger to persons,
• Any defect which is not yet but could become a danger to persons, the time by which it could become such a danger, along with details of any repair, renewal or alteration required to remedy it,
• The latest date by which the next thorough examination must be carried out,
• Where the thorough examination included testing; the particulars of any test undertaken,
• Name and competency qualifications of the person making the report,
• Name and address of the examiner’s company / employer,
• Name and address of the person signing or authenticating the report on behalf of its author,
• Date of the thorough

What is the legal standing of AGS & BDA guidance?

Following good practice is not a legal requirement in itself, but should an organisation choose not to follow good practice, and something goes wrong, that organisation may well be found liable of a tort of negligence under the Health and Safety at Work Act, 1974 and face a financial penalty and or a custodial sentence for it’s Directors.

Essentially, the AGS and BDA has combined the constant application of PUWER and the two elements of LOLER to provide further documented good practice to follow for the drilling industry and thereby continue to improve drilling machine safety.

More information regarding the Application of PUWER and LOLER to Land Drilling can be obtained from the AGS website.

Article provided by the AGS Safety Working Group and BDA Safety Sub-Committee