Pryor Trust Well
Industry Address to Lessons Learned &
the Process Safety Push Into Land Oil
& Gas Operations
The Scenario
On January 22, 2018, a blowout and fire occurred killing five
people at Pryor Trust 0718 gas well number 1H-9, located in
Pittsburg County, Oklahoma
Red Mountain Energy, LLC was the lease holder, and Red
Mountain Operating, LLC (RMO) was the operator of the well.
Patterson-UTI Drilling Company, LLC (Patterson) was
the drilling contractor, hired by RMO.
What Happened?
Well 1H-9 was a lateral
well with a planned true
vertical depth (TVD) of
7,615 feet and a planned
measured depth (MD) of
17,799 feet.
Well 1H-9 targeted and
was drilled through the
Woodford formation.
Timeline
At 3:36 pm on January 21, 2018, the Patterson drilling crew
stopped drilling (drill bit depth at 13,435 feet MD) so that
they could remove the drill pipe from the wellbore to change
the drill bit.
Removing drill pipe from a wellbore is called “tripping.”
The tripping operation began at 6:48 pm.
Timeline
At 8:36 am, after the bottom hole assembly was removed
from the wellbore, mud blew upwards out of the well.
The motor man and a floor hand, who were on the rig
floor, entered the driller’s shack.
The gas and oil-based mud from the well subsequently
ignited creating a large fire.
Timeline
It is unknown at this point if the driller attempted to activate
the controls to close the blowout preventer after the blowout
began.
Shortly after the blowout began, at least two personnel
reportedly attempted to operate the accumulator that
functions the blowout preventer.
The blowout preventer blind rams did not fully close.
Timeline
A team of Boots & Coots
responders (a well control
services company) and RMO
personnel manually closed the
blowout preventer blind rams to
shut in the well at about 4:00
pm on January 22, 2018.
Shutting in the well stopped the
fire.
Outcome
All five personnel who were in the driller’s
shack or ran into the driller’s shack during
the blowout and fire were killed.
Those personnel included the Company
Man (contracted by RMO), directional
driller (Skyline Directional Drilling), driller
(Patterson), floorhand (Patterson), and
motor man (Patterson).
CSB Key Issues
Poor Barrier Management Flow Checks Not Conducted
Underbalanced Operations Gaps in Safety Management System
Performed Without Proper Planning,
Procedures, or Needed Equipment
Driller’s Cabin Design
Signs of Influx Either Not Identified
or Inadequately Responded To BOP Could Not Close Due to
Burned Hydraulic Hoses
Alarm System Off
CSB Key Issues
“Lack of
Safety
Requirements
by Regulation”
CSB Regulatory Analysis
Lack of Federal Oversight of Onshore Drilling
CSB determined that there are minimal regulations governing the
safety of onshore oil and gas drilling operations.
The OSHA PSM standard does not apply to drilling, no separate
OSHA standard covers drilling, and no other federal regulatory
body oversees the safety of onshore drilling operations.
CSB Regulatory Analysis
Lack of Federal Oversight of Onshore Drilling
Historically, OSHA has long been interested in regulating oil and gas
drilling and servicing operations. OSHA recognized the industry as
having the potential need for specialized regulation because the oil
and gas drilling and servicing industry “has some safety problems
which are unique, and some which are common to all workplaces.”
CSB Regulatory Analysis
Lack of Federal Oversight of Onshore Drilling
Specifically, OSHA observed the unique and numerous dangers
presented by oil and gas drilling operations to workers.
These dangers are self-evident and include hazards related to
blowouts based on the pressures at which hydrocarbon reserves are
sometimes found, fires and explosions, dropped objects, crush
injuries, falls from heights,
CSB Regulatory Analysis
Lack of Federal Oversight of Onshore Drilling
dangers associated with rotary equipment, transportation-
related accidents, slip and trip injuries, and myriad other
hazards present at a typical drilling site.
CSB Regulatory Analysis
OSHA Timeline of Addressing Oilfield Safety
1973 - OSHA attempted to regulate the industry under its
Construction Safety Standard, found at Title 29 Code of
Federal Regulations Part 1926
Late 1970~Early 1980 - through the Occupational Safety and
Health Review Commission (OSHRC) found that Construction
Standards did not apply, and OSHA shifted to the General
Industry Standards of 29 CFR 1910
CSB Regulatory Analysis
OSHA Timeline of Addressing Oilfield Safety
Based on BLS data, OSHA discovered that the industry had a
number of special safety and health problems demonstrated
by a higher-than-average injury and illness incidence rate
compared to employers covered by the general industry
standards.
CSB Regulatory Analysis
OSHA Timeline of Addressing Oilfield Safety
OSHA then determined that the general industry standards
inadequately addressed unique hazards related to drilling and
servicing
CSB Regulatory Analysis
OSHA Timeline of Addressing Oilfield Safety
Significantly, the agency also claimed that applying the
general industry standards possibly even contributed to the
higher injury and illness incidence rates in the absence of
specific regulatory coverage to guide the industry in a safer
direction.
CSB Regulatory Analysis
OSHA Timeline of Addressing Oilfield Safety
At this point, OSHA resigned itself for a time to issuing
Section 5(a)(1) citations for general duty clause violations of
the OSH Act, which requires employers to provide a place of
employment “free from recognized hazards that are causing
or are likely to cause death or serious physical harm to his
employees.”
CSB Regulatory Analysis
OSHA Timeline of Addressing Oilfield Safety
Throughout the 1980’s to Present, OSHA and Industry has
attempted to develop an Oilfield Drilling Standar (and by
extension an Oilfield Services Standard) with input from
organizations like the IADC and AOSC (now the AESC) to
develop real and meaningful regulations that make sense for
the unique needs of this industry.
It didn’t work out…
CSB Regulatory Analysis
OSHA Timeline of Addressing Oilfield Safety
As of this date, there is no OSHA Drilling-specific Standard.
Now what?
Exemption from OSHA’s Process
Safety Management Standard
In 1992, OSHA enacted a new regulatory standard called
Process Safety Management of Highly Hazardous Chemicals
(PSM). OSHA expressed about the standard:
Unexpected releases of toxic, reactive, or flammable liquids and
gases in processes involving highly hazardous chemicals have been
reported for many years.
Incidents continue to occur in various industries that use highly
hazardous chemicals which may be toxic, reactive, flammable,
or explosive, or may exhibit a combination of these properties
Exemption from OSHA’s Process
Safety Management Standard
In 1992, OSHA enacted a new regulatory standard called
Process Safety Management of Highly Hazardous Chemicals
(PSM). OSHA expressed about the standard:
Regardless of the industry that uses these highly hazardous
chemicals, there is a potential for an accidental release any time
they are not properly controlled…
Exemption from OSHA’s Process
Safety Management Standard
In 1992, OSHA enacted a new regulatory standard called
Process Safety Management of Highly Hazardous Chemicals
(PSM). OSHA expressed about the standard:
…Hazardous chemical releases continue to pose a significant threat to
employees and provide impetus, internationally and nationally, for
authorities to develop or consider developing legislation and
regulations to eliminate or minimize the potential for such events.
Exemption from OSHA’s Process
Safety Management Standard
At the end of the day, even
with the passage of PSM,
and the opportunity PSM
presented to cover the
industry, there remained
no specific OSHA regulation
that governed onshore
drilling.
What is Coming?
The Final CSB Report Released On June 12, 2019 makes clear
that there is a definitive lack of regulatory control for what
they believe, in my opinion, is clearly a PSM fix to the problem
We have seen Industry apply PSM activities as a “fix” to the
offshore safety environment following incidents and when
followed diligently, appear to work fairly well.
Midstream and Downstream use PSM, why not Upstream?
My Conclusions…
Nonetheless, an Oilfield Standard, on the order of a
Construction or General Industry Standard will eventually be
developed.
Using PSM techniques with cooperative efforts with our
Regulators, in my opinion, looks like Industry’s best future
to develop regulations and processes that can work in our
industry, in the “real” world and can become our “New
Normal”
Finally…
As an industry, we need to embrace the inevitable evolution
of safety, the management of risk in business and personal
responsibility to our co-workers and family.
We all are involved, and we all benefit by giving our best
efforts.
Let’s continue the work and…
Remember…
