Fatigue Management Key to Oil and Gas Service Sector’s Hours of Service Exemption

By: Petroleum Services Association of Canada (PSAC)

After several years of negotiations with the federal Department of Transport and provincial transportation regulation agencies in Alberta, British Columbia, Saskatchewan and Manitoba, the Petroleum Services Association of Canada (PSAC ) has gained approval from the federal Minister of Transport for some exemptions from the federal Commercial Vehicle Hours of  Service (HOS) Regulations.

Service sector companies that wish to operate under the exemptions must have a fatigue management program (FMP) in place as part of their health and safety management program, in addition to meeting several other conditions. The FMP will  have to be approved by the provincial HOS Director of the carrier’s base jurisdiction.

The need for these exemptions came about as a result of changes to the federal Commercial Vehicle Drivers’ Hours of  Service Regulations that came into effect on January 1, 2007. The Regulations apply to all commercially registered vehicles  over 4,500 kg owned and operated by extra-provincial undertakings (i.e. federal carriers). Under the changes introduced in 2007, drivers may not drive more than 13 hours in a day and may not drive after 14 hours on-duty. Drivers must have at least 10 hours off-duty before they can drive again and at least eight of those hours must be consecutive. These rules were  developed after years of research on fatigue by transportation safety personnel and based on advice from a panel of sleep  xperts. Drivers need to be rested and alert in order to safely operate their vehicles. Proper sleep is so critical for drivers that  he federal government spent nearly a decade and several million dollars studying the issue and developing the new rules mandating the amount of rest one must have before getting behind the wheel in an occupational capacity.

One of the challenges for the oil and gas service sector in meeting the requirements of the Regulations is the fact that its workers must travel long distances to the more remote areas where industry operates – often where sleep accommodations are not available. Another difficulty for oil and gas service sector personnel is that the length of time a job takes is often  unpredictable. For example, a job estimated to take six hours may end up taking 10 hours. As a result, work crews may be waiting at a lease site for several hours before they are able to start their operations and the Regulations count this “stand-by time” toward a driver’s daily “on-duty time”.

Harold Drok, Operational Compliance Manager for FLINT Oilfield Services, described some of the ways the service industry  has been directly affected by the new HOS Regulations: “The oil and gas drilling industry is a 24/7 business and many of the smaller rigs move 24/7. Under the 2007 Hours of Service Regulations it’s been virtually impossible for the rig mover to be  compliant with the regulations when moving rigs working on projects. In order for the rig mover to be compliant while working on a Fort McMurray oil sands project, for example, the rig moving company would be required to have two crews working 12 hours per day – something that’s impossible with the current driver shortage.”

The exemptions will apply to commercial vehicles over 4,500 kg operated by extra provincial undertakings (i.e. federal  carriers) and their commercial drivers engaged in “rig moving operations” and “specialized service operations”.

The rig moving exemption will apply to extra-provincial undertakings engaged in rig move operations as part of a drilling  project under the provisions of a valid Oil Well Service Vehicle Permit.

The exemption will be valid during the winter season – November 1 to March 31. The exemption for specialized service operations will apply to extra-provincial undertakings and their drivers who are employed or otherwise engaged in these operations under the provisions of a valid Oil Well Service  Vehicle Permit. “Specialized services” are defined in the exemption as including but not limited to: “well testing; mud-filling; cementing; hydraulic fracturing; voltage, logging and resistivity measurements; and cleaning of industrial equipment; as the particular requirement might arise in the normal course of well drilling, completion and maintenance operations.”

The exemption also defines the terms: alternate sleeping accommodations; base jurisdiction; elapsed time; journey  management program; oil well service vehicles; and specialized services.

While operating under the exemption, extra  provincial undertakings and their commercial drivers will be exempt from the off-duty requirements of Sections 13 and 14 of  the Regulations. Another purpose of the exemptions is to allow drivers to meet the mandatory off-duty and daily off-duty requirements by accumulating off-duty time in sleeper berths or in alternative sleep accommodations. Use of the exemption will be optional for carriers with a valid Oil Well Service Vehicle Permit.

“Because the rigs move during both the day and the night, the new alternative sleeper berth HOS Exemption allows the driver to take his required daily  off-duty time in two periods totalling 10 hours in the client camp facilities versus having to take eight consecutive hours off  duty each day,” added Mr. Drok.

Both exemption documents can be viewed and downloaded from the PSAC website at:

http://www.psac.ca/images/pdf/h&s/hours_of_service.pdf

PSAC is currently in the process of working with Alberta Transportation on an information package for industry outlining how the exemption process will be administered. And PSAC is pleased to provide more detail about the exemptions through a presentation at PSAC ’s Spring Conference to be held in Red Deer April 12-13th, 2011. For more details on how to register for the Conference go to: www.psac.ca

*with files contributed by Andrea W. Lorenz