Does your drilling contractor hold the required drillers licence?

In recent times I have invested a lot of time during the last few months interviewing potential rig operators, many with geotechnical and contaminated land drilling experience. To my surprise many of them do not possess a national water-well licence. Consistently they claim that someone else in the organisation was "acting" as the licenced driller and subsequently signing off on all the bore completion reports.

It's certainly concerning from an industry standpoint that this is occurring and frustrating for the companies that invest heavily to meeting regulatory requirements. Certainly, the individual driller holds legal accountability for the breach however at a high level the primary contractor/consultant is complicit in the arrangement in that they have failed a duty of care to engage a qualified contractor.

Earlier in 2020 there was an updated release of the Minimum Construction Requirements for Water Bores in Australia Ed 4. (MCR4)

MCR4 states “The bore shall be constructed by a suitably qualified driller who possess the appropriate experience and the relevant class of licence that the state or territory deem necessary.” Section 2.2 states “An appropriately licenced driller shall be on site at all times during bore construction and decommissioning activities.”

Note that "appropriate license" is referencing not just the class of drillers licence (1, 2 or 3) but the drilling method endorsement: Auger, Rotary Air, Rotary Mud and Sonic.

There is not a lot of wriggle room there to suggest that someone back in the office can be acting as the licenced driller and signing off on bore completion reports.

I am currently working on a more detailed review of the water-well licencening requirements across the states and how they are interpreted by the contaminated land and geotechnical industries. I am keen to hear from anyone who has encountered issues or anomalies in this space that we could look for clarification.

Matthew Hansen