OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
October 26, 1983
President Fitz
Equipment Company
P.O. Box 6071
Odessa, Texas 79760
Dear Sir:
Recent investigations by this agency indicate that a serious safety problem is related to drilling equipment manufactured by your company. The problem concerns the driller's control console panel configuration on equipment previously delivered to Verna Drilling Company and operated by Offshore Casing Crews, Incorporated.
At this time, it appears that your equipment may have contributed to three serious injuries and a fatality. On December 27, 1981, an accident seriously injured two persons on a rig operated by Offshore Casing Crews, and on January 4, 1982, one of the injured persons died. Previously, a similar accident resulted in serious injuries to two persons at the Verna Corporation.
The specific nature of the problem seems to stem from the location, on the control panel, of two powered functions. Your drilling rig is provided with a control console on which two adjacent controls of identical shape and form perform two completely different functions. One control activates the breakout cathead, while the adjacent control operates the hoisting equipment. We believe that, due to the close proximity of the controls and the manner in which they are manipulated, a serious hazard exists.
It is our understanding that, while drilling operations progress, drillers who are responsible assuring the safe clearance of workers from operating equipment frequently rely upon their skill to manipulate the controls without glancing at the panel for each function desired. Unfortunately in such an environment, and due to the control console configuration, the breakout cathead control may be accidentally activated in place of the hoisting control. When such an error occurs, the breakout tongs become a giant club swinging with great force across the work platform area where employees are working.
Various solutions to the condition have been suggested by our field personnel, including:
1. Relocating the breakout cathead control.
2. Providing a latch lock on the breakout cathead control to prevent unintentional activation.
The American Petroleum Institute (API) has developed and published several documents which address the design and operation of Drilling Machinery. The API has suggested the use of standardized control consoles and control knobs unique to the functions they perform. Perhaps you are unaware of these documents and did not participate in their development.
The API documents are:
API Recommended Practice for Drilling Machinery, API RP 7H, Second Edition, January 1981.
Supplement 1 to API RP 7H (Second Edition), issued December 1981.
API Specification for Rotary Drilling Equipment, API Spec. 7, Thirty-Second Edition, May 1979.
These documents can be obtained from:
American Petroleum Institute Production Department 211 North Ervay, Suite 1700 Dallas, Texas 75201
This office is considering the publication of a safety alert notice to inform our field staff and others of the above-mentioned hazard relating to the use of your equipment. Please provide us with information regarding any corrective action(s) conducted by your company to eliminate the recurring hazardous operation of this drilling equipment. While awaiting your timely response, and alert will not be issued to our field staff at this time.
If I may be of further assistance, please contact me.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations