derrick floor versus kelly bushing factory

An adapter that serves to connect the rotary table to the kelly. The kelly bushing has an inside diameter profile that matches that of the kelly, usually square or hexagonal. It is connected to the rotary table by four large steel pins that fit into mating holes in the rotary table. The rotary motion from the rotary table is transmitted to the bushing through the pins, and then to the kelly itself through the square or hexagonal flat surfaces between the kelly and the kelly bushing. The kelly then turns the entire drillstring because it is screwed into the top of the drillstring itself. Depth measurements are commonly referenced to the KB, such as 8327 ft KB, meaning 8327 feet below the kelly bushing.

Fred Wilson Drilling Company appeals a final order of the Occupational Safety and Health Review Commission which sustained the administrative law judge"s ("ALJ") findings.1 The ALJ fined the drilling company $250 for violating standard 29 C.F.R. § 1910.36(b)(1) by failing to provide a "Geronimo" escape line for derrickmen working on the "monkey board" platform of its oil drilling rig number nine, and $100 for violating standard 29 C.F.R. § 1910.212(a)(1) by failing to guard the rig"s Kelly bushing and rotary table. We affirm the finding of liability for violation of the first standard; we vacate the second.

The monkey board is a horizontal platform on the derrick approximately ninety feet above the derrick floor and over 100 feet above ground. Employees work on this platform handling sections of drill pipe during drilling operations. Although there are a number of means of exit from this platform, the ALJ"s finding that no escape route accessible from the platform would allow descent other than straight down was uncontradicted. The Geronimo line, by providing a method of egress at an angle away from the derrick, provides a safe means of escape in the event of a fire or explosion resulting from drilling, and therefore satisfies 29 C.F.R. § 1910.36(b)(1). Because we find substantial evidence on the record as a whole to support the Commission"s factual determinations, 29 U.S.C. § 660(a), we affirm.

The drilling company was found in violation of the standard 29 C.F.R. § 1910.212(a)(1) for failure to guard the Kelly bushing and rotary table. The rotary table, flush with the derrick floor, is approximately three feet in diameter and is constantly rotating during the drilling process. The Kelly bushing rests upon the rotary table surrounding the Kelly, which is a heavy, vertical steel pipe. Power is transmitted from a bank of diesel engines, generators, or power units through a belt system to the rotary table/bushing unit. The rotary table turns the bushing, and together they transmit rotation power to the Kelly while simultaneously permitting vertical movement of the Kelly. The Kelly in turn transmits power to the drill string and cutting bit.

In finding Fred Wilson in violation of this standard, the ALJ acknowledged that use of a Kelly bushing guard would pose serious hazards, but concluded that an unguarded bushing, on balance, presented the more unsafe situation. Because Wilson appeared to have acted under a good faith belief that it might be more hazardous to use such a guard than not to use one, the ALJ reduced the penalty recommended by the Secretary from $250.00 to $100.00.

The ALJ based his finding on the testimony of an OSHA compliance officer whose familiarity with this particular aspect of the drilling industry appears to have been minimal. The inspector had never seen a Kelly bushing guard on any rigs he had inspected, had not visited a factory at which guards were manufactured and had never viewed a Kelly bushing guard other than in brochures published by their manufacturers. The officer admitted that he did not understand how a guard is placed on the rig and that he knew nothing of the maintenance of a Kelly bushing. Finally the officer conceded he did not know what effect a guard would have in the event a "blowout" occurred.

The ALJ also relied on the testimony of the president of the Kelly Bushing Guard Manufacturing Company, who is also the designer of the guard manufactured by his company. Although he had twenty-three years experience as a welder, he was not an engineer, had no formal education beyond the tenth grade, and had not had his guard independently tested. His company, which had been in business for less than a year at the time of the hearing, carried no products liability insurance and had sold only one guard.

Wilson, by contrast, presented the testimony of an oil well drilling expert who was familiar with a variety of Kelly bushing guards, and found that they created hazards by obstructing passageways on the limited space of the rig floor, by confining the drilling operator"s view of the Kelly, and by potentially acting as deflecting shields in the event of a blowout, thereby increasing the likelihood of a fire. Wilson"s Director of Safety and Personnel also testified and stated that the company had investigated the feasibility of using Kelly bushing guards, but had decided against their use because of the additional hazards created. He also testified that the company had no record of any accidents caused by a Kelly bushing in operation without a guard.

The administrative law judge in the case at bar did not, in his finding of fact, indicate that the bushing contained any j-bolts or other protuberances. In both Secretary of Labor v. Grey Wolf Drilling Co., OSHRC Docket No. 77-2328, 1978 (CCH) OSHD P 22,961 and Secretary of Labor v. Grey Wolf Drilling Co., OSHRC No. 77-3803, 1978 (CCH) OSHD P 23,183, the ALJ specifically found that an unguarded Kelly bushing which had no j-bolts or other protuberances constituted less of a hazard than one equipped with a guard. Although the ALJ in Secretary of Labor v. Signal Oilfield Service, Inc., OSHRC Docket No. 77-0226, 1978 (CCH) OSHD P 22,758 upheld the Secretary"s citation for failure to guard the Kelly, the ALJ specifically found that the Kelly bushing had at least four protrusions exposed around its outer perimeter. The court emphasized, however, that its holding did not apply to the new type Kelly bushing installed after the inspection which had a smooth exterior, a caveat noted and approved by the ALJ in the Grey Wolf decisions.

At oral argument in the case at bar, the assertion of Wilson"s counsel that its Kelly bushing was of the same nature and construction as that used in Grey Wolf was unrebutted. While noting that the OSHA compliance officer had testified that the Kelly bushing had protruding bolts, Wilson"s counsel explained that the officer, who, as noted, evinced no real knowledge of the drilling industry, must have been referring to the bevelled and rounded pins which fit into the rotary table. Complainant"s exhibit 10, a picture of the Kelly bushing, supports Wilson"s argument and reveals no j-bolts or other protrusions. Thus, every other administrative law judge that has considered this question has found that, given the present state of development, a Kelly bushing like Wilson"s constitutes more of a hazard guarded than unguarded. We believe the present record requires the same finding.

The kelly is a primary link between the drilling rig’s surface equipment and the bit, and is therefore a critical component of the rotary system. Although top drive systems have replaced kelly/rotary table combinations on many rigs, some knowledge of their manufacture and operation is useful.

Their angled surfaces, or drive flats, are designed to fit into a drive roller assembly on the kelly bushing, so that as the rotary table turns to the right, the kelly turns with it. To allow for normal right-hand rotation of the drill string, kellys have right-hand threads on their bottom connections and left-hand threads on their top connections.

The American Petroleum Institute has established manufacturing and design standards for kellys, and has included them in the follwoing publications:API RP 7G, Recommended Practice for Drill Stem Design and Operating Limits.

For a kelly to be efficient in turning the drill string, the clearance between its drive flat surfaces and the rollers in the kelly bushing must be kept to a minimum. Kellys most often wear out due to a rounding-off of the drive corners, as shown in Figure 1 (new kelly with new drive assembly) and Figure 2 (worn kelly with worn drive assembly).

For minimal rounding, there must be a close fit between the kelly and the roller assembly, with the rollers fitting the largest spot on the kelly flats. Manufacturing techniques and rig operating practices play important roles in determining this fit.

Both square and hexagonal kellys are manufactured either from bars with an “as-forged” drive section, or from bars with fully-machined drive sections. Forged kellys are cheaper to manufacture. But machined kellys tend to last longer because:Unlike forged kellys, machined kellys are not subject to the metallurgical process of decarburization, which leaves a relatively soft layer of material on the drive surface that can accelerate the rounding process and increase the potential for fatigue cracks;

To minimize rounding, rig personnel should follow these guidelines (Brinegar, 1977):Always use new drive-bushing roller assemblies to break in a new kelly.

Frequently inspect and periodically replace drive assemblies to ensure that clearance and contact angle between the kelly and the rollers is held to a minimum;

Fatigue failures are seldom a problem with kellys because of the high-quality steels used in their manufacture. Nevertheless, kellys should be regularly inspected for cracks and other signs of wear, particularly within the threaded connections, in the areas where the flats join the upper and lower upsets and in the center of the drive section.

In general, the stress level for a given tensile load is less in the drive section of a hexagonal kelly than in the drive section of a square kelly of comparable size. Hexagonal kellys are thus likely to last longer than square kellys before failing under a given bending load.

Kellys can become crooked or bent due to improper handling. Examples of mishandling include dropping the kelly, misaligning it in the rathole and thereby exerting a side pull, using poor tie-down practices during rig moves, not using the kelly scabbard and improper loading or unloading techniques. Depending on where a bend is located, it may cause fatigue damage not only to the kelly but to the rest of the drill string, and can also result in uneven wear on the kelly bushing.

Unusual side motions or swaying of the swivel are good indicators of a crooked kelly. A good field service shop has equipment for straightening bent kellys, making this an easily-corrected problem.

A kelly saver subshould always be run between the kelly and the top joint of drill pipe. This protects the kelly’s lower connection threads from wear, as joints of drill pipe are continually made up and broken out. A saver sub is much less expensive and much easier to replace than the kelly itself, and it can also be equipped with a rubber protector to help keep the kelly centralized and to protect the top joint of casing against wear.

A kelly cock is a valve installed above or below the kelly, which prevents fluid from escaping through the drill string if the well should begin to flow or “kick.” As an extra well control precaution, an upper kelly cock (having left-hand threads) should be installed directly above the kelly, while a lower kelly cock (having right-hand threads) should be installed below the kelly. Installing two kelly cocks ensures that at least one of them is always accessible, regardless of the kelly’s position.

Automatic check valves, designed to close when the mud pumps are shut off, are also available, and can be installed below the kelly to prevent mud from spilling onto the rig floor during connections.

Fred Wilson Drilling Company appeals a final order of the Occupational Safety and Health Review Commission which sustained the administrative law judge"s ("ALJ") findings.1 The ALJ fined the drilling company $250 for violating standard 29 C.F.R. § 1910.36(b)(1) by failing to provide a "Geronimo" escape line for derrickmen working on the "monkey board" platform of its oil drilling rig number nine, and $100 for violating standard 29 C.F.R. § 1910.212(a)(1) by failing to guard the rig"s Kelly bushing and rotary table. We affirm the finding of liability for violation of the first standard; we vacate the second.

The monkey board is a horizontal platform on the derrick approximately ninety feet above the derrick floor and over 100 feet above ground. Employees work on this platform handling sections of drill pipe during drilling operations. Although there are a number of means of exit from this platform, the ALJ"s finding that no escape route accessible from the platform would allow descent other than straight down was uncontradicted. The Geronimo line, by providing a method of egress at an angle away from the derrick, provides a safe means of escape in the event of a fire or explosion resulting from drilling, and therefore satisfies 29 C.F.R. § 1910.36(b)(1). Because we find substantial evidence on the record as a whole to support the Commission"s factual determinations, 29 U.S.C. § 660(a), we affirm.

The drilling company was found in violation of the standard 29 C.F.R. § 1910.212(a)(1) for failure to guard the Kelly bushing and rotary table. The rotary table, flush with the derrick floor, is approximately three feet in diameter and is constantly rotating during the drilling process. The Kelly bushing rests upon the rotary table surrounding the Kelly, which is a heavy, vertical steel pipe. Power is transmitted from a bank of diesel engines, generators, or power units through a belt system to the rotary table/bushing unit. The rotary table turns the bushing, and together they transmit rotation power to the Kelly while simultaneously permitting vertical movement of the Kelly. The Kelly in turn transmits power to the drill string and cutting bit.

In finding Fred Wilson in violation of this standard, the ALJ acknowledged that use of a Kelly bushing guard would pose serious hazards, but concluded that an unguarded bushing, on balance, presented the more unsafe situation. Because Wilson appeared to have acted under a good faith belief that it might be more hazardous to use such a guard than not to use one, the ALJ reduced the penalty recommended by the Secretary from $250.00 to $100.00.

The ALJ based his finding on the testimony of an OSHA compliance officer whose familiarity with this particular aspect of the drilling industry appears to have been minimal. The inspector had never seen a Kelly bushing guard on any rigs he had inspected, had not visited a factory at which guards were manufactured and had never viewed a Kelly bushing guard other than in brochures published by their manufacturers. The officer admitted that he did not understand how a guard is placed on the rig and that he knew nothing of the maintenance of a Kelly bushing. Finally the officer conceded he did not know what effect a guard would have in the event a "blowout" occurred.

The ALJ also relied on the testimony of the president of the Kelly Bushing Guard Manufacturing Company, who is also the designer of the guard manufactured by his company. Although he had twenty-three years experience as a welder, he was not an engineer, had no formal education beyond the tenth grade, and had not had his guard independently tested. His company, which had been in business for less than a year at the time of the hearing, carried no products liability insurance and had sold only one guard.

Wilson, by contrast, presented the testimony of an oil well drilling expert who was familiar with a variety of Kelly bushing guards, and found that they created hazards by obstructing passageways on the limited space of the rig floor, by confining the drilling operator"s view of the Kelly, and by potentially acting as deflecting shields in the event of a blowout, thereby increasing the likelihood of a fire. Wilson"s Director of Safety and Personnel also testified and stated that the company had investigated the feasibility of using Kelly bushing guards, but had decided against their use because of the additional hazards created. He also testified that the company had no record of any accidents caused by a Kelly bushing in operation without a guard.

The administrative law judge in the case at bar did not, in his finding of fact, indicate that the bushing contained any j-bolts or other protuberances. In both Secretary of Labor v. Grey Wolf Drilling Co., OSHRC Docket No. 77-2328, 1978 (CCH) OSHD P 22,961 and Secretary of Labor v. Grey Wolf Drilling Co., OSHRC No. 77-3803, 1978 (CCH) OSHD P 23,183, the ALJ specifically found that an unguarded Kelly bushing which had no j-bolts or other protuberances constituted less of a hazard than one equipped with a guard. Although the ALJ in Secretary of Labor v. Signal Oilfield Service, Inc., OSHRC Docket No. 77-0226, 1978 (CCH) OSHD P 22,758 upheld the Secretary"s citation for failure to guard the Kelly, the ALJ specifically found that the Kelly bushing had at least four protrusions exposed around its outer perimeter. The court emphasized, however, that its holding did not apply to the new type Kelly bushing installed after the inspection which had a smooth exterior, a caveat noted and approved by the ALJ in the Grey Wolf decisions.

At oral argument in the case at bar, the assertion of Wilson"s counsel that its Kelly bushing was of the same nature and construction as that used in Grey Wolf was unrebutted. While noting that the OSHA compliance officer had testified that the Kelly bushing had protruding bolts, Wilson"s counsel explained that the officer, who, as noted, evinced no real knowledge of the drilling industry, must have been referring to the bevelled and rounded pins which fit into the rotary table. Complainant"s exhibit 10, a picture of the Kelly bushing, supports Wilson"s argument and reveals no j-bolts or other protrusions. Thus, every other administrative law judge that has considered this question has found that, given the present state of development, a Kelly bushing like Wilson"s constitutes more of a hazard guarded than unguarded. We believe the present record requires the same finding.