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OCS Report 

MMS 2007-058

Investigation of Fatality 

West Cameron Block 240 

OCS-G 27008 

December 1, 2006 

Gulf of Mexico 

Off the Louisiana Coast 

U.S. Department of the Interior

Minerals Management Service 

Gulf of Mexico OCS Regional Office
OCS Report 

MMS 2007-058

Investigation of Fatality 

West Cameron Block 240 

OCS-G 27008 

December 1, 2006 

Gulf of Mexico 

Off the Louisiana Coast 

Frank Pausina – Chairman 

Jason Mathews 

Eric Fontenot 

Marty Rinaudo 

U.S. Department of the Interior

Minerals Management Service New Orleans 

Gulf of Mexico OCS Regional Office September 2007
ii

Conte nts 

 

Executive Summary, 1 

Introduction 

Authority, 2 

Background, 2 

Procedures, 2 

Findings 

The Accident, 4 

 Post-accident, 8 

 Employee Training, 9 

Badger Safety Management, 13 

TODCO Safety Management, 15 

Conclusions 

The Accident, 17 

 Causes, 17 

Recommendations, 23 

Appendix 

Attachment 1 - Location of Lease OCS-G 27008, West Cameron Area, Block 240. 

 Attachment 2 - Photo of Mid-Section of Nylon Strap used during the WC 240 Fatality 

 Attachment 3 - Photo of Nylon Strap used during the WC 240 Fatality 

 Attachment 4 - Photo of Nylon Strap Eye 

Attachment 5 - Photo of Nylon Strap with Eye 

Attachment 6 - Photo of Shackle at end of Nylon Strap 

Attachment 7 - Layout of the TODCO Rig at Time of Fatality 

Attachment 8 - Photo of Depiction of Single Choker Hitch 

Attachment 9 - Photo of Lifting Sub that Replaced the Nylon Strap 
iii

Glossary of Acronyms 

 

B-CR – Badger Company Representative 

 B-OM – Badger Operations Manager 

 T-CO – TODCO Crane Operator 

 T-D – TODCO Driller 

 T-D/HO – TODCO Derrickhand/Hoist Operator 

 T-F1 – TODCO Floorhand 1 

T-F2 – TODCO Floorhand 2 

 T-F3 (D) – TODCO Floorhand 3 - Deceased 

 T-OIM – TODCO Offshore Installation Manager 

 T-R1 – TODCO Roustabout 1 

 T-R2 – TODCO Roustabout 2 

 T-R3 – TODCO Roustabout 3 

 T-VPHSE – TODCO Vice President of Health, Safety, and Environmental Matters 
1

Executive Summary 

On the evening of December 1, 2006, TODCO rig personnel were engaged in the task of laying 

down 5-1/2 inch drill pipe from the rig floor to TODCO 207’s pipe rack.. The task of laying down 

5-1/2 inch drill pipe involved the use of the rig floor’s air hoist and a nylon strap attached to the 

air hoist cable. After laying down 30 to 50 joints of drill pipe during the night shift (1200 hours – 

2400 hours), a single joint of drill pipe weighing approximately 600 lbs. was lifted from the 

mousehole and swung towards the V-door. Just before reaching the V-door, the drill pipe was 

unexpectedly lowered onto the rig floor and inadvertently released from the nylon strap. The drill 

pipe fell towards the draw works, striking a TODCO floor hand in the head and shoulder. The 

resulting injuries were fatal. 

The causes of the accident were an improperly cinched strap, the inexperience of the roustabout 

cinching the strap, supervisory misjudgment in allowing the inexperienced employee to cinch the 

strap, lack of training, the operator’s over-reliance on the drilling contractor’s safety plan, the 

lack of specific safety responsibilities of the operator’s representative, and the ineffectiveness of 

the contractor’s safety program and its HSE department. Recommendations made by the panel 

were (1) a Safety Alert to Lessees and Operators to address those items and (2) a modification of 

30 CFR 250.108 to include all lifting operations associated with oil and gas operations on the 

OCS. 
2

Introduction 

Authority 

 

An accident that resulted in one fatality occurred on The Offshore Drilling Company’s (TODCO) 

THE 207 (TODCO 207) drilling rig on Badger’s West Cameron Block 240, Lease OCS-G 27008, 

in the Gulf of Mexico, offshore the State of Louisiana, on December 1, 2006, at approximately 

1300 hours. Pursuant to Section 208, Subsection 22 (d), (e), and (f), of the Outer Continental 

Shelf (OCS) Lands Act, as amended in 1978, and Department of the Interior Regulations 30 CFR 

250, Minerals Management Service (MMS) is required to investigate and prepare a public report 

of this accident. By memorandum dated December 14, 2006, the following personnel were 

named to the investigative panel: 

Frank Pausina, Chairman – Office of Safety Management, GOM OCS Region 

Jason Mathews – Accident Investigation Branch, MMS Headquarters Herndon 

Eric Fontenot – Lake Charles District, Field Operations, GOM OCS Region 

Marty Rinaudo – Lafayette District, Field Operations, GOM OCS Region 

Background 

 

Lease OCS-G 27008 covers approximately 5,000 acres and is located in West Cameron Block 

240, Gulf of Mexico, off the Louisiana Coast. For lease location, see Attachment 1. The lease 

was issued effective July 1, 2005. Badger became Designated Operator of the lease on 

September 19, 2005.

Procedures 

Two MMS representatives, including a member of the panel, visited the accident scene on 

December 4, 2006.

On January 16, 2007, at Preis & Roy Law Corporation in Lafayette, Louisiana, the panel 

interviewed two TODCO roustabouts and a TODCO crane operator who were on shift at the time 
3

of the accident. A TODCO floor hand, who participated in the task involving the fatality, was 

also interviewed. 

On January 17, 2007, at Preis & Roy Law Corporation in Lafayette, Louisiana, the panel 

interviewed a TODCO floor hand, a TODCO derrick hand and the TODCO driller, all of whom 

participated in the task involving the fatality. The TODCO Offshore Installation Manager (OIM) 

was also interviewed at that time. 

On February 9, 2007, at Badger’s office in Lafayette, Louisiana, the panel interviewed Badger’s 

Manager of Operations and Badger’s company representative on the rig at the time of the 

accident. 

On February 15, 2007, at Preis & Roy Law Corporation in Houston, Texas, the panel interviewed 

a TODCO roustabout who participated in the task involving the fatality and the TODCO VicePresident for Health, Safety, and Environmental matters (HSE). 

Various documents from Badger and TODCO pertinent to the investigation were collected by the 

panel. 

The panel met numerous times throughout the investigation and, after having considered all of the 

information available, produced this report. 
4

Findings 

The Accident 

On Wednesday, November 29, 2006, the parties involved in the incident began their two-week 

hitch on the TODCO 207, which was operating in the West Cameron area, Block 240. T-R3, who 

was classified as a Roustabout 2 at the time of the incident, arrived at the TODCO 207 

approximately at 2330 hours, which was his first two-week hitch on the TODCO 207 since his 

hire on the date of June 28, 2006. Even though there is distinction between a Roustabout 1 and 

Roustabout 2 in pay, there are no evident personnel descriptions available to define the 

differences, responsibilities, and/or limitations. According to interviews, a Roustabout 2 is a new 

employee to TODCO who may or may not have previous experience, but can be promoted to a 

Roustabout 1 normally after a 90-day evaluation period. T-R3 had no previous experience in the 

oil and gas industry prior to June 2006 and was on the job for over 90 days. T-F2 and T-R3 said 

that T-R3 was wearing a blue hardhat. Yet, T-D/HO said that T-R3 was wearing a red hardhat. In 

testimony, a red hardhat differentiates a Roustabout 1 and Roustabout 2; nevertheless, like the 

personnel descriptions, there was no apparent dissimilarities forwarded to the panel by TODCO 

mentioning the difference between a blue and red hardhat. 

Prior to T-R3’s arrival at the TODCO 207, T-OIM received an e-mail from a TODCO personnel 

manager on November, 29, 2006, at 0740 hours, informing the T-OIM of T-R3’s arrival. The 

e-mail did not include any background or personnel history of T-R3. Once T-R3 arrived at the 

TODCO 207, he signed in and went to bed at the request of the night tool pusher since he was 

apparently ill from the vessel ride to the TODCO 207. 

T-R3 was given an overview of the TODCO 207 on the morning of Thursday, November 30, 

2006, prior to his first shift. TR-3 reported the overview consisted of, “You watch the tape, 

welcome to this rig, yadda-yadda.” Following the rig orientation, TR-3 was shown around the rig 

by other roustabouts following the night shift’s pre-shift safety meeting. During his first shift on 

the TODCO 207, T-R3 performed typical roustabout duties, e.g., cleaning and assisting a 

mechanic making repairs to an engine. Because of high winds during the shift, T-OIM decided to 

pull out of the hole at 1900 hours and cease all operations of laying down drill pipe. 
5

At 0800 hours on Friday, December 1, 2006, the day shift (2400 hours – 1200 hours) resumed 

operations and began pulling 51⁄2-inch drill pipe out of the hole. Before relieving the day shift, 

members of the night shift participated in a pre-shift safety meeting, according to the Pre/Post 

Tour and Weekly Safety Meeting Log; however, B-CR was present even though he did not sign 

in. The B-CR’s presence at the meeting was described by T-F1 as, “He was sitting in the back of 

the room at the computer.....he said a few things, but I couldn’t really hear him.” The pre-shift 

safety meeting was lead by T-OIM. 

Following the commencement of the pre-shift safety meeting, the crane crew (T-R1, T-R2, 

T-R3, and T-CO) performed a verbal THINK drill, led by T-CO. T-CO was supervising T-R1, TR2, and T-R3 receiving the 51⁄2-inch drill pipe from the drill floor and bundling it up for lifting. 

Simultaneously, the drill crew (T-F1, T-F2, T-F3(D), T-D/HO, and T-D) performed a verbal 

THINK drill, led by T-Driller. T-D was supervising T-F1, T-F2, T-F3(D), and T-D/HO in pulling 

the 51⁄2-inch drill pipe and lowering it down the V-door. Both drills were conducted within their

respective work areas where the work was being performed. 

At 1200 hours, the night shift relieved the day shift, which was working with an additional 

roustabout on the rig floor. T-F1 visually inspected the nylon strap and rigging equipment used 

for lifting the drill pipe out of the mousehole before any lifts were made by the night shift. T-D 

notified T-CO that he would like a roustabout to come to the rig floor to assist in attaching the 

nylon straps to the drill pipe and walking it to the V-door once it was lifted by the air hoist 

operated by T-D/HO. Once T-CO was notified by T-driller, he signaled for T-R3, who was the 

least experienced of all roustabouts but claimed he had previous drill floor experience, to come to 

the rig floor at approximately 1230 hours. T-CO had performed no evaluation as to T-R3’s 

previous work experiences. 

When T-R3 went to the rig floor, T-D held an additional verbal THINK drill with the drill crew to 

discuss the safety issues involved with pulling and laying down the drill pipe since T-R3 was new 

to the TODCO 207 rig floor. T-D directed T-F1 and T-F2 to initially demonstrate and then 

observe T-R3 making the hitches since, it was his first time on the rig floor of the TODCO 207. 

T-R3 was given his responsibilities on both the pulling of the drill pipe and well control 

responsibilities if an incident were to occur, even though he had never been trained in well 

control. T-D had performed no evaluation as to T-R3’s previous work experiences. 
6

While T-R3 was on the rig floor, he was solely responsible for attaching the nylon strap below the 

tool joint to allow T-D/HO to make the lift, and then walk the drill pipe to the V-door once it was 

lifted by T-D/HO. TR-3 acknowledged there was evident pipe dope on all of the drill pipe joints 

being lifted, with some having more pipe dope than others. For an indication of the condition of 

the nylon strap, see Attachments 2-6.

Prior to T-R3 making any connections to the drill pipe, T-F1 showed him the proper way to make 

the cinch three to four times according to T-F1. T-F1 said that he watched T-R3 make a few 

connections and then resume pulling the drill pipe. According to T-F1, T-F1 corrected T-R3 for 

attaching the nylon strap too high on the drill pipe tool joint. T-F1 said that he “had to set the 

joint down and explain to T-R3, because if it [the nylon strap] got on the tool joint the pipe would 

slip out.” T-F2 said that on one occasion the drill pipe was set higher than previous tool joints in 

the mousehole, which required T-F1 to cinch the strap below the tool, because T-R3 was having 

difficulties because of the tool joint’s height. Besides monitoring T-R3 make every strap 

connection, T-F1 was also responsible for operating the tongs, breaking drill pipe connections, 

and signaling to T-D/HO to lift the drill pipe. For a depiction of the location of pertinent 

personnel at the time of the accident, see Attachment 7. 

T-R3 said that he had to get assistance from T-F1 two to three times because the cable above the 

nylon strap would get caught up in the derrick. Once it got caught up, T-R3 was not able to move 

the drill pipe to the V-door. T-F1 would then free the cable by pulling and maneuvering the drill 

pipe. Testimony approximated that between the 30 and 50th lift on the drill floor since T-R3 had 

arrived, the drill pipe came free of the strap and fatally struck T-F3(D) in the head/shoulder 

region at 1310 hours. 

Prior to the drill pipe striking T-F3(D), T-R2 witnessed a loose strap connection on the drill pipe 

while it was suspended above the rig floor, prior to its falling, and he thought the strap might 

come off. After T-R2 saw this, he hollered at T-R1 to get off of the catwalk, because “it looked 

like it wasn’t on there real good.” For a depiction of the single choker hitch used during the 

laying down operation and the location of the strap on the pipe as viewed by T-R2 on the fatal 

lift, see Attachment 8.

T-R3 was approximately 6-inches from the V-door when the drill pipe fell to the rig floor. T-R3 

said, “It seemed to me that T-D/HO had let the pipe down, because there was no bang.” No other 
7

rig floor personnel heard a bang or the drill pipe hitting the roll bar in the derrick. Nor did they 

witness the drill pipe falling from the nylon strap; however, TR-3 recalls, “I heard T-D/HO say 

‘Get out of the way!’” 

T-F1, T-F2, and T-F3 (D) were beginning to break another drill pipe connection and were not 

looking in the direction of the suspended drill pipe. T-CO and T-D had obstructed views from 

their standpoints. T-R1 and T-R2 could not see the drill pipe once it was lowered to the V-door. 

T-R3 was looking at the bottom of the suspended drill pipe while pushing the drill pipe to the 

V-door with his right shoulder. T-D/HO was the only member of the rig crew who would have 

seen what happened, but he “just kind of went blank right there.” Yet, T-D/HO managed to tell 

TR-3 to “Get out of the way.” Once the incident took place, no one at the scene looked up at the 

sling or derrick to see exactly what occurred. 

After T-F3(D) was struck by the drill pipe, he was not conscious according to interview 

statements. He was reportedly bleeding from the nose and mouth, but had a pulse. T-F1 was the 

first responder and was with T-F3 (D) up to the time of his evacuation from the TODCO 207. 

T-OIM placed a call for a helicopter; however, the helicopter did not arrive until 1430 hours. 

Prior to his evacuation, T-CO lifted T-F3(D) and T-F1 to right below the helideck area to 

expedite moving T-F3(D) to the helicopter. The helicopter transported him to Lake Charles 

Memorial Hospital, and he was pronounced dead at approximately 1530 hours. 

Following the incident on the TODCO 207, the drill pipe pulling and laying operation was 

subsequently discontinued temporarily. The rig contacted J. Connor Consulting to notify all 

regulatory agencies at 1605 hours. TODCO legal counsel and the rig manager arrived at the rig at 

1930 hours to conduct interviews. All personnel who were involved in the incident were 

questioned by TODCO’s legal counsel and given the opportunity to go home. Employees 

indirectly involved were given the chance to go home as well. The drill pipe that struck the victim 

and the nylon strap used to lift the drill pipe were sent to Houma. 
8

Post-Accident 

 

The following are taken from the interview responses given to panel members by B-OM and TVPHSE. 

Badger: 

As to questions regarding Badger performing an investigation into the fatality following the 

incident, B-OM stated that on the weekend following the incident, “We discussed it with senior 

people, Jody Conner, in terms of our compliance with our SEMP. At the time we had to make an 

operating decision whether or not it was worthwhile to take the step of sending people offshore 

and conducting what looked like was going to be a fruitless investigation. People were removed 

from the rig and not going to be available for eyewitness accounts. I think we had a reasonable 

expectation that we would be going through an investigation like that just for drill, counterbalanced against safety aspect of putting people on helicopter in fairly high winds in December 

and just making a day trip to say we did it. We elected not to do that at that time.” 

From weather reports in the Sabine area near the TODCO 207 on Saturday, December 2, it was 

confirmed from data acquired from a weather buoy that the highest winds of the day were 

recorded at 0900 hours at 12 kts, or 13.8 mph. 

At the time of the interview, approximately three months after the incident, Badger had not 

conducted a formal investigation of the fatality, although the Badger Safety and Environment 

Management Program (SEMP) requires that investigations begin no later than 48 hours following 

the incident. 

In response to questions regarding why the incident was not investigated, it was stated that 

Badger’s SEMP is production oriented. It is noted within section 1.0 of the Badger SEMP 

document that SEMP is a management tool that applies to all Badger facilities for “drilling,” 

production, and construction operations. 

Further, the operating decision was made that an investigation would be “fruitless” because 

eyewitnesses were removed from the rig, and B-CR’s comments led Badger to believe that 

TODCO had “pretty much closed ranks.” It was further stated that the safety aspects of flying 
9

offshore outweighed a reasonable expectation that an onsite investigation would be more of a 

drill. 

With respect as to whether Badger has required TODCO to perform an investigation, it was stated 

that Badger knows that TODCO has completed the initial phase of the facts gathering. It was also 

stated that Badger has not formally requested an investigation report. 

TODCO: 

It was stated that Badger did not prompt TODCO to investigate. TODCO had informed the panel 

that they were in the process of performing an investigation, but the MMS has not received a 

report on the investigation as of the date of this report. 

After the incident, TODCO replaced the nylon straps for similar operations by requiring the 

pulling of drill pipe on every TODCO rig worldwide to be performed with a threaded lifting sub. 

T-VPHSE said that the decision to replace the strap “wasn’t recognizing that use of the nylon

strap was in anyway unsafe.” He stated that the decision represents a desire to take action 

immediately to prevent the likelihood of reoccurrence. For photo of the lifting sub, see 

Attachment 9.

Other than replacing the nylon strap with the threaded lifting sub, no other operational changes 

were made in regard to the WC 240 fatality. A letter was sent to the entire TODCO fleet 

worldwide to inform them of the change from the nylon strap to the lifting sub.

Employee Training 

Badger Training Policies 

In accordance with Badger’s SEMP document dated July 2005, operating location supervisors, 

similar to the role of B-CR, must verify that all who work on Badger leases are trained in the 

work practices necessary to perform their jobs safely. Further, contractors must ensure that their 

employees receive appropriate training and are informed of potential hazards. 
10

There was no record of any review performed by B-CR or Badger on the training of TODCO 

personnel. The following is a result of the panel’s review of TODCO personnel training records 

within personnel files at the time of the incident. (Note – these records do not include T-F3[D] 

and were supplied to the MMS shortly after the incident). It is noted that Badger supplied the 

MMS with well control data for personnel that contradicts what is presented below during a 

Subpart O audit, and the MMS is in the process of validating the information presented to them. 

Employee

Experience w/ 

TODCO (yrs) 

at time of 

incident

Performance 

Evaluation*

Rigger 

Training . 

Certification

Crane 

Operator 

Certification Well Control

TODCO 

Orientation 

Rig

T-D/HO 3 No Yes - Expired No Yes Yes

T-CO 2 Yes Yes Yes No No**

T-OIM 15 Yes Yes - Expired No Yes No

T-R1 12

Yes-Demotion 

Reccomended Yes Yes Yes-Expired No

T-F1 1 No No No No Yes

T-R3 <1 No No No No Yes

T-R2 3 Yes Yes - Expired No No Yes

T-F2 1 Yes No No No Yes

T-Driller <1 No No No Yes Yes

* - According to testimony, every TODCO employee is required to be evaluated once every 12 

months, 90 days for Roustabout 2. 

** - No record in personnel file; however, in testimony he claimed he participated. 

The above table reveals the following: 

1. Four employees out of nine from the night shift of the TODCO 207 had not been 

evaluated in accordance with TODCO personnel policy on performance evaluations 

noted within testimony. 

2. Seven employees out of nine from the night crew of the TODCO 207 had not received 

Rigger or Crane Operator certification, or the certification had expired. 

3. Although the incident was not related to well control, three of the five employees on the 

rig floor did not have well control certification. TR-3 had specific well control 

responsibilities but never had any prior training. 

4. Three of the nine employees had no record of participating in the TODCO orientation rig 

within their personnel files.
11

TODCO Training Policies 

According to T-VPHSE, all new, not necessarily inexperienced, employees are required to 

participate in training at the TODCO training rig. T-VPHSE referred to the training rig as an 

“orientation” rig and the setting is not truly reflective of what new employees would see in the 

field. TODCO utilizes the rig “to introduce folks to the culture that they’re trying to build inside 

the company....how they should conduct themselves.....and to give them an overview of the kind 

of life and working environment they’re likely to find.” The orientation rig is “not designed to 

take someone who’s been maybe flipping burgers for the last couple of years into a fully qualified 

floor hand or roustabout.” All personnel interviewed during the investigation mentioned the 

“orientation” rig to be their only formal training experience while at TODCO. 

During the training at the “orientation” rig, new employees are given multiple documents, such as 

an HSE manual and a Riggers Training Handbook. These documents contain a large of amount of 

data that the employees are tested on daily, along with field tests. A passing grade is required to 

move onto a field rig. T-R3 referred to the “orientation” rig as a “boot camp.” 

T-VPHSE is not “definitive” with what is taught at the “orientation” rig, but he stated, “it 

wouldn’t surprise” him if the nylon strap used during the incident was part of the curriculum, 

because “it is has been recognized inside the company as a ‘perfectly’ safe way to move drill 

pipe.” However, following the incident, the Senior Vice-President of Operations sent out a 

notification to all rigs worldwide to replace the nylon straps with a threaded lifting sub. Besides 

the change of attitude towards the nylon straps, there is no mention of how to make proper 

cinches with nylon straps within the TODCO Riggers Training Handbook. 

Following new employees’ departure from the “orientation” rig, TODCO relies heavily on their 

receiving hands-on training overseen by supervisors and more experienced hands. T-R1 stated he 

“has given more training than he has received.” T-R1 has been in the industry since 1975, and 

stated that he is responsible for “informally training” new hands. During TR-1’s informal 

training, he focuses on “keeping them out [of] trouble” and instructing them on the “proper way 

to handle certain operations.” Even though it was noted in T-R1’s TODCO evaluation that (1) TR1 had been recommended for demotion since he “was not a leader that can do his job or train his 

men” and (2) was given a disciplinary notice for filing a late accident report, he indicated that he
12

remained the “experienced” hands-on “informal” trainer to personnel like T-R3, who was on his 

night shift on the TODCO 207.

TODCO also requires employees to participate in weekly safety meetings, which are held on the 

weekend during their off-shift time. For participating in these safety meetings, each employee is 

paid overtime. 

With respect to pre-job training and hands-on training that were offered to T-R3 in regard to rig 

floor operations, T-R3 could not recall the names of certain common drill floor equipment, such 

as tongs, spinner hawks, and tugger. According to T-F1, “there is no floor hand training at the 

training rig.” T-D was confident that T-R3 was qualified to perform the attaching of the strap to 

the drill pipe, push the drill pipe to the V-door, and perform any required well control tasks 

discussed with him during a “three to four minute” THINK drill, even though T-R3 had no 

documented experience or training. 

In accordance with Section 4, entitled “Equipment and Inspection of Gear,” within the Riggers 

Training Handbook issued on the TODCO “orientation” rig and dated September 21, 2004, “all 

hoist operators must be qualified to operate or use the specific type of hoist.” The referenced 

handbook also requires all pre-use inspections of crane/hoist equipment, such as a nylon strap, to 

be inspected by a “qualified operator.” 

The Rigger Training Handbook defines a qualified operator as “a person designated by the 

employer who has appropriate offshore experience and training. They must be qualified to safely 

operate the cranes on which they have been trained. They must also be qualified to perform preuse and monthly inspections. This person must also be a qualified rigger.” 

A qualified rigger is defined as, “a person with training and experience who has successfully 

completed an approved riggers training program, crane load rigging will only be performed by a 

qualified rigger, a qualified operator is a qualified rigger.” 

Lastly, a qualified inspector is defined as “in addition to meeting requirements of a qualified 

operator, the person must have successfully completed courses on crane and hoist maintenance 

and troubleshooting; they will be qualified to perform initial, quarterly and annual inspections.” 
13

The panel found no documentation that T-D/HO had received any training in operating air hoists 

similar to the one in operation on the TODCO 207 prior to the incident; however, the panel was 

able to determine that his rigger training certification had expired before December 1, 2006. 

Therefore, by TODCO Riggers’ Training Handbook definition, T-D/HO was not a “qualified 

operator” on the day of the incident. 

The panel also determined that T-F1’s rigger training certification had expired prior to 

December 1, 2006. Consequently, T-F1 was not a “qualified inspector” to perform the pre-use 

inspection of the nylon strap in use on the day of the incident. 

Badger Safety Management 

The following are taken from the interview responses made by B-OM and B-CR to panel 

members. 

B-OM 

With respect to Badger’s drilling contractors, it was stated that Badger, because of the production 

orientation of their SEMP, relies on the contractor’s extensive safety systems in place, Badger’s 

experience with contractors, and reports from ISNetworld. ISNetworld is an online contractor 

database that helps operators satisfy governmental and operator-specific record keeping 

requirements and reduces the cost of managing and prequalifying contractors. However, it was 

also stated that Badger never reviewed or evaluated TODCO’s safety manual, did not require that 

contract employees have written job descriptions, nor did they review the training records of 

TODCO personnel. 

With respect to monitoring a drilling contractor’s performance, Badger does not conduct a safety 

audit “in terms of sitting down with a vendor in their office.” 

Regarding the role and main function of Badger’s company representative (B-CR) on the 

TODCO rig, it was stated that he is Badger’s “eyes and ears” on the rig and is familiar with 

Badger’s safety plan. Regarding the B-CR’s authority to stop anything that he observes on the rig 
14

to be abnormal or a safety concern, it was stated that Badger “expects him to feel” that he has 

shut-down authority. 

When asked how Badger’s company representatives’ duties and responsibilities are 

communicated to “them,” the response centered only on the B-CR at the time of the incident and 

referred only to Badger’s satisfactory experience and comfort level with him. The question was, 

in effect, not answered. With respect to B-CR’s participation in the pre-shift safety meeting, it 

was stated that it is Badger’s expectation that the meeting would be run by the TODCO people 

and that they would welcome the presence of the company man, meaning B-CR. 

 

B-CR 

The main responsibility of the company representative is to ensure that the operation is compliant 

with government regulations and to transmit reports from contractors to Badger. In response to 

inquiries as to the existence of any additional responsibilities, the B-CR stated there were none 

and then added that he is “more or less (an) observer” and makes sure regulations are followed. 

He then added, “and safety and environmental.” The B-CR walks around the rig twice a day, once 

each shift. 

With respect to his reaction in the event that he observed an unsafe activity, B-CR responded that 

he would notify the contractor and expect them to, in essence, remedy the situation. 

He did not recall any reference to a new roustabout in the pre-shift safety meeting, did not know a 

new hand had arrived, and had no expectation that such information would have been shared with 

him by the contractor. B-CR’s name was not listed on the pre-shift safety meeting list of meeting 

attendees. 

With respect to Roustabout 1 and 2 classifications, B-CR was not aware of such a classification 

and was not aware of any evaluations of any individuals on the rig. He stated that he does review 

the training records of rig personnel with respect to well control and verifies the certification of 

crane operators. 

With respect to laying down pipe, B-CR considers the use of the strap as the “safest way” with 

which to perform the task. He continued that the use of a lifting sub is “probably equal” in safety. 
15

B-CR stated that he was familiar with Badger’s safety plan. 

B-CR stated that the reports from the contractor that he submits to Badger do not include any 

documentation regarding the pre-shift safety meeting. 

 

TODCO Safety Management 

The following are taken from the interview responses made by T-VPHSE to panel members: 

The T-VPHSE stated he did not have a “detailed working knowledge” of the TODCO HSE 

Manual and stated it is difficult to define what an HSE issue is. It was established by the panel 

during the interviews that the HSE Manual is a principal, official working safety document of 

TODCO. When asked if there was any communication between HSE and HR regarding specific 

requirements he would like to see in all TODCO employees, T-VPHSE responded, “Yes. But it's 

-- it's not related to knowledge and skills. It's related to the softer issues of attitude and morale 

and making -- making safety personal. So I'll get directly involved in those softer issues.” 

The current HSE document, dated 2004, was prepared by the Operations group with technical 

support from HSE, Purchasing, and Accounting.

The T-VPHSE didn’t know if TODCO has any written job descriptions for its roustabouts. 

However, job descriptions for TODCO roustabout positions do exist and were made available to 

the panel after the interviews.

The TODCO Training Rig, which all TODCO field personnel must attend, is considered to be 

“more of an orientation rig to introduce people to the company” and its culture and is “certainly 

not designed” to produce a “fully qualified floor hand or roustabout.” Additionally, the training 

rig is not designed to expose people to the kind of work environment that they will likely face. 

The T-VPHSE was not aware of the training curriculum or how testing is performed on the 

training rig. 

Training is an HR (Human Resources) function and not an HSE function. HSE relies solely on 

HR to set forth policy to require specific training. HR oversees the training rig and also anything 

related to the skills, competency, and knowledge of its employees. HR personnel determine the 
16

competency for field placement determinations. Despite the extensive HR responsibilities that are 

safety related according to the T-VPHSE, he did not know who those personnel are. 

HR has discussions with OIM’s on the competency of persons boarding the rig. The panel found 

no evidence indicating that any such communication took place in the case of T-R3’s boarding. 

Employee evaluations are considered an HR function. Everyone on a rig has a written evaluation 

annually; however, the T-VPHSE does not know where they are kept. 

The OIM is responsible for the safety of everyone on the rig. 

In a response to a question raised by the panel if T-VPHSE set forth any training requirements for 

TODCO employees or if he solely relies upon HR, he responded, “It's very difficult to say, you 

know, what is an HSE related issue? If you looked at the -- the skills for well control or 

prevented maintenance that mechanical and electrical supervisors go through, then indirectly you 

can say it's all safety related. You know, if someone doesn't adequately service a top drive, then 

they...” 

When asked is if T-VPHSE knew if there was an HSE manual on every rig, T-VPHSE responded, 

“Well, to the best of my knowledge, each rig has three copies.” 
17

Conclusions 

The Accident 

It is concluded by the panel that, as a joint of 5-1/2 inch drill pipe was being moved to the V-door 

as part of a laying down operation, the pipe slipped out of a supporting cinched strap, resulting in 

the drill pipe falling and fatally striking a floorhand. 

Causes 

Mechanical/Actions: 

1. It is the conclusion of the panel that, as the last joint of pipe was being pushed to the V-door, 

the necessary slackening of the hoist cable and an improperly cinched strap caused the eye of the 

cinched strap to ride up onto the pipe’s tool joint and slip off the drill pipe. 

The exact manner in which the strap was improperly cinched is not known. It is concluded that 

the strap was placed either 1) too high on the joint with the eye of the strap either on the bevel of 

the tool joint or on the joint itself or 2) too low on the joint, thereby allowing the momentum of 

the strap, as the pipe was being lifted, eventually to slip over the bevel and eventually off the drill 

pipe’s tool joint. Therefore, the improper cinching of the strap onto the pipe is concluded to 

be a cause of the incident.

In either of the two cinching possibilities, it is concluded that, to some degree, the mud on both 

pipe and the strap lessened the friction between the two and thereby aided the pipe sliding out the 

strap. No conclusion could be drawn as to the degree the amount of mud on the pipe would have 

affected the integrity of the strap/pipe connection had the strap been properly cinched with no 

other negative mechanical influences being present. 

2. It is the conclusion of the panel that it is also possible that, as the pipe was very close to the Vdoor, T-D/HO lowered the pipe excessively, i.e., to the extent that the too much slack developed 

in the cable, thereby allowing the improperly cinched strap to loosen further and eventually 

separate from the pipe. Statements made by T-R3 concerning the lowering of the pipe 

immediately prior to the pipe falling leads the panel to conclude that this could reasonably have 
18

occurred. Therefore, excessive lowering of the pipe near the V-door is concluded to be a 

possible cause of the incident. 

3. It is the conclusion of the panel that it is also possible that, as the drill pipe was being lifted 

from the mousehole either the drill pipe or the hoist cable became momentarily hung up in the 

derrick. The manner in which that occurred would have determined the amount of jarring 

experienced in the lift, which in turn would have influenced the amount of movement of the strap 

over the pipe’s tool joint. While this has been concluded to be a very reasonable possibility, any 

conclusion as to the probability of such a hang-up in the derrick on the fatal lift is made difficult 

by conflicting interview statements regarding the witnessing or the hearing of such hang-ups. 

Therefore, the hanging up of the pipe or cable in the derrick is concluded to be a possible 

cause of the incident. 

It is concluded that if such a hang-up did occur (1) a properly cinched strap would have withstood 

the resultant jarring reaction, and (2) an improperly cinched strap would have reacted to the 

resultant jarring by moving further up onto the pipe tool joint, thereby increasing the likelihood of 

a strap/pipe separation. 

Inexperience: 

It is the conclusion of the panel that T-R3’s lack of experience in performing the task of 

securing the drill pipe with a strap was a cause of the accident, as was his general lack of 

experience with drill floor activities. During the interviews, T-R3 stated at one point that he 

didn’t remember if he had ever used nylon straps in that type of lifting activity. Further, his tenure 

on the rig implies unfamiliarity with the rig, as well as the drill floor activities and the TODCO 

hands with whom he would be working. T-R3 was also expected to perform at the same pace of 

the experienced hands while working on the rig floor. 

Supervision: 

The decision by T-CO to send T-R3 to the rig floor is considered a possible cause of the 

accident. However, T-CO did not violate any policy set forth by TODCO management that 
19

would have prohibited such a decision. In choosing T-R3 to work the rig floor, T-CO chose the 

least experienced of the three roustabouts available, one whom he had not officially evaluated, 

one for whom he was unaware of evaluations from previous supervisors, and one over whom he 

had very limited supervision and observation experience. T-CO chose T-R3 on the basis of his 

willingness to work the rig floor, his saying that he had had experience relieving roughnecks, and 

his having attended the training rig. It is the conclusion of the panel that these were not sufficient 

reasons to allow the lowest ranked roustabout and the newest member of the rig to perform a task 

in which he was responsible for the suspension of drill pipe in a occupied work area and 

ultimately a task in which his actions did contribute to the drill pipe, which was approximately 

600-pounds, falling. 

The decision by T-D to allow T-R3 to be responsible for securing the nylon strap to the pipe 

is considered a cause of the accident for some of the same reasons listed immediately above. 

However, T-D did not violate any policy set forth by TODCO management that would have 

prohibited such a decision. Knowing that T-R3 was new to the rig and with no knowledge of his 

experience, T-D allowed T-R3 to be responsible for a task, albeit with some guidance from more 

experienced hands, in which he was responsible for the suspension of drill pipe. 

Training: 

It is the conclusion of the panel that the TODCO training rig does not adequately train employees 

to work on a rig floor. Even though TODCO relied heavily on its hands-on training, TODCO 

failed to have any policy in place to prevent employees like T-R1, who “was not a leader that can 

do his job or train his men,” from providing hands-on training to new employees. TODCO was 

also unsuccessful in capturing instructions on how to make attachments properly to drill pipe 

using nylon straps, the type of strap used within the accident, within the TODCO Rigger Training 

Handbook. The lack of formal training and the quality of hands-on training provided by 

TODCO to its employees is considered a cause of the accident. 
20

Management: 

Badger: 

It is the conclusion of the panel that Badger’s safety management was overly reliant on the safety 

systems of their drilling contractor, TODCO. It is also concluded that the responsibilities of their 

representative on the rig, B-CR, with respect to safety issues were ineffectually nonspecific as BCR monitored each shift once a day by walking around the rig and truly had no authority to stop 

work being performed by TODCO according to testimony. Had Badger been aware that a new 

man had arrived on the rig, was the lowest rated roustabout, within days was going to be assigned 

to the rig floor with the task of securing drill pipe for suspension in a work area, and whose 

supervisors were unaware of any previous evaluations or work experience, it is reasonable to 

conclude that concerns would have been raised on Badger’s part with respect to the prudence of 

such a situation from a safety perspective. It is further reasonable to conclude that such informed 

concerns would have led to at least the questioning of such a decision, and that questioning in 

turn could reasonably be expected to have resulted in either closer supervision of T-R3 or 

replacing him for the given task, thus possibly preventing the accident. 

It is therefore the conclusion of the panel that a lack of specific safety responsibilities of the 

Badger company representative on the rig and Badger’s over-reliance on TODCO’s safety 

systems is a possible cause of the accident and, in effect, represents a serious lack of onsite 

safety responsibility with respect to activities on the lease for which they are the designated 

operator. 

TODCO: 

It was concluded by the panel that TODCO’s safety program in general, the one on which Badger 

relied heavily, contributed to the incident in that the panel found no evidence of any prohibition 

in the program regarding the actions taken by T-CO and T-D in allowing T-R3 to perform the 

task of securing the pipe with the nylon strap, actions that themselves were considered to be 

causes of the accident . Therefore, it is concluded by the panel that the ineffectiveness of 

TODCO’s safety program with respect to a lack of such a prohibition and apparently in 

general was a cause of the accident. 
21

In concluding the reasons for the ineffectiveness of TODCO’s safety program with respect to the 

subject accident, the following were considered: 

A. The Vice President of the Health, Safety, and Environment department of TODCO stated: 

1. He was not aware if written job descriptions existed for roustabouts or the difference 

between the classifications of Roustabouts 1 and 2; 

2. He was not familiar with the curriculum of the training rig; 

3. He did not know what the personnel type was or the skill set of those types in the 

Human Resource department, the department responsible for training and 

competency determinations for field placement; 

4. He viewed the “training” rig more of an orientation vehicle than a training vehicle; 

5. He wasn’t sure if the referenced 90-day evaluation period for roustabouts is written 

policy; 

6. He didn’t know why there was a rush to substitute the lifting sub for the straps; 

7. He had difficulty defining what an HSE related issue is; and 

 8. He was uncertain as to the disposition of HSE manuals on rigs. 

B. The panel concluded that the examples that the T-VPHSE offered immediately after stating his 

difficulty in defining an HSE issue, one of which was incomplete, did not constitute a 

satisfactory clarification of the concept of an HSE function and further led the panel to 

conclude that the T-VPHSE did not possess a clear, functional definition of an HSE 

function. 

C. Communication between HR and HSE regarding employees was not related to knowledge and 

skills, but rather to softer issues of attitude, morale, and making safety a personal issue. 

D. The panel concluded from an answer given in response to the question as to the number of 

HSE manuals on each rig that T-VPHSE did not have a convincing knowledge of the 

number and location of HSE documents within TODCO’s fleet. 

Considering all of the above, in addition to the aforementioned lack of the prohibition against the 

decisions of T-CO and T-D, the panel concluded that the general ineffectiveness of 

TODCO’s HSE department was a major contributing factor in the ineffectiveness of 
22

TODCO’s corporate safety program and is therefore concluded to be a cause of the 

accident. 

 

 
23

Recommendations 

Safety Alert 

The MMS should issue a Safety Alert to all lessees and operators containing the following: 

1. A brief description of the accident, 

2. A summary of the causes, and 

3: The following recommendations: 

a) Lessees and Operators should review their policies regarding the selection of 

contractors from a safety perspective and the safety performance monitoring 

of the selected contractors. Policies should include a complete review of the 

contractors’ corporate safety plans. 

b) Lessees and Operators should communicate clearly and in writing what is 

expected of their field representatives, especially with respect to the issues of 

safety enforcement and monitoring. 

c) All personnel involved in rigging/lifting operations, not only crane but all, 

should have formal rigger training prior to participating in such operations. 

Regulation Change 

The MMS should modify 30 CFR 250.108 to include all lifting operations associated with oil and 

gas operations. 

 

 
Western Central

Eastern

LAKE CHARLES

GALVESTON

HOUSTON

CORPUS CHRISTI

BILOXI

MOBILE

PENSACOLA

PANAMA CITY

TAMPA

KEY WEST

LAFAYETTE

BATON ROUGE

NEW ORLEANS

HOUMA

GRAND ISLE

TEXAS

LOUISIANA

MISSISSIPPI

ALABAMA

FLORIDA

SOUTH

PADRE IS.

NORTH

PADRE IS.

MUSTANG

IS.

PORT

ISABEL

EAST BREAKS GARDEN BANKS

KEATHLEY CANYON

NG 15-8 NG 15-9

ALAMINOS CANYON

CORPUS

CHRISTI

MAT.

IS. RAZ B OS

V GAL ESTON

HIG SLAND H I

N WEST CAMERO

EAST CAMERON

V MI ION ER L

GREEN CANYON

ATWATER

MISSISSIPPI CANYON

WALKER RIDGE LUND

SOUTH MARSH IS.

UGEN IS. E E

SHIP HOAL S

SO. TI LIER MBA

.I G .

.D. W

S.P.

KNOLL

MAIN

PASS

B.S.

SO.

PASS

VIOSCA

MO

PENSACOLA BILE

DESTIN DOME

APALACHICOLA

AG INESVILLE

FLORIDA

MIDDLE GROUND

TARPON

SPRINGS

THE ELBOW ST.

PETERSBURG

VERNON

CHARLOTTE

HARBOR

HOWELL HOOK

RANKIN

PULLEY RIDGE

DRY

TORTUGAS

DESOTO CANYON

LLOYD

HENDERSON

NG 16-8

NG 16-7

MM Minerals Management Service Gulf of Mexico OCS Region

U.S. Department of the Interior

STATUTE MILES

KILOMETERS

0

0

50

100

Location of Lease OCS-G 27008, West Cameron Area Block 240.

West Cameron Area

Block 240

OCS-G 27008

MIAMI

MIAMI

100

200

Att

a

c

h

m

ent 1
Photo of Mid-Section of Nylon Strap used during the WC 240 Fatality

Mud

Attachment 2
Photo of Nylon Strap used during the WC 240 Fatality

Shackle End of Strap

Eye for Cinching Pencil for Scale

Attachment 3
Photo of Nylon Strap Eye

Attachment 4
Photo of Nylon Strap with Eye

Attachment 5
Photo of Shackle at End of Nylon Strap

Attachment 6
Drawworks

Driller’s

Console 

TuggerTugger Tugger

Mousehole

Tongs

Tongs

V-door

T-D

T-R3

T-F3-D

T-F1

T-D/HO

T-F2

Layout of the TODCO 207 Rig at Time of Fatality
Photo of Depiction of Single Choker Hitch

Location of Eye as Viewed 

by T-R2 on Fatal Lift

Location of Lower End of Cinch 

as Viewed by T-R2 on Fatal Lift

Attachment 8
Photo of Lifting Sub that Replaced the Nylon Strap

Attachment 9