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Enforcement Policy for Flame- Resistant Clothing in Oil and Gas Drilling, Well Servicing, and Production-Related Operations Sheila Schulmeyer Compliance Assistance Specialist Permian Basin STEPS

Clarification of OSHA’s Policy for citing general industry standard for PPE, 29 CFR (a) Memorandum issued on March 19, 2010 from Director of Enforcement Programs, Richard Fairfax. Clarification necessary to resolve inconsistent use of FRC during certain drilling, servicing, and production-related operations. Basis derived from OSHA inspection history, current information, consensus standards, scientific evidence, and accident and injury data which indicate a potential for flash fires during above-mentioned operations.

Flash Fires FRC greatly improves the chances of a worker surviving a flash fire and can significantly reduce both the extent and severity of burns to the body. NFPA 2112 on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, 2007 Edition and NFPA 2113 Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, 2007 Edition apply to general industry workplaces.

OSHA Ignition sources are present in drilling, well servicing, and production-related operations in several forms, including, but not limited to: electrical systems, handheld electrically powered tools, motors, generators, hot work and static electricity.

Potential of Flash Fires Memo states that potential for flash fires during rig-up operations and during drilling where formations or zones of hydrocarbons and gas have not yet been reached. When active gas or hydrocarbon zones are accessed, pressure from underground gas or hydrocarbon could “kick” bringing well fluids up the hole to the rig floor.

Uncontained or Uncontrolled If the “kick” is not controlled or contained by the BOP or rig engineering controls, a high potential of flash fire due to the presence of ignition on or in the vicinity of the drilling platform exits.

Well Servicing & Production Service operations on oil and gas wells have the same potential of flash fires. Production-related operations have the potential for flash fire despite the use of both engineering and administrative controls. ( Further explanations are given which we all already know).

Citation Guidance for 29 CFR (a) which reads as follows: Protective equipment, including personal protective equipment for eye, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.

Drilling Operations FRC not usually needed during initial rig up and normal drilling operations prior to reaching active hydrocarbon zones. Other activities might warrant their use. FRC shall be worn by exposed employees prior to drilling into identified gas or hydrocarbon zones. Compliance staff must verify that employees are wearing FRC in advance of reaching such zones. FRC should also be worn when there is a history of fluid or gas kicks from underground producing zones. Once FRC is identified for use, employees should wear appropriate FRC until the final casing is cemented and the well is effectively closed.

Well Servicing Operations Compliance staff must determine whether FRC is provided and worn during well servicing or workover operations, such as: Pulling wet string tubing Snubbing tubing Swabbing operations Fracturing or perforating the well Using bridge plugs or packers Open hole work Flow testing, blowing down or venting the well Plugging an abandoned well Flowback operations Cementing Stimulation Wireline operations Any operation working with wellhead or wellbore under pressure

Production-Related Operations Compliance staff must determine if FRC is provided and worn during production-related operations such as: Equipment openings (e.g., line breaking or valve changes) Gauging Transfer of hydrocarbons Maintenance operations on production equipment Hot Work operations Tank heating Using open flame Start-up operations

Other portions of may be cited (b) where FRC is not properly maintained and sanitary (c) where the employer fails to provide FRC that is of safety design and construction for work being performed (d) where the employer fails to conduct a hazard assessment. (See (g) for appropriate application.

Other cont (e) where FRC is defective or damaged (h) when an employer fails to provide, at not cost to employees, FRC that is used to comply with the standard. (A comprehensive personal protective equipment enforcement directive is being developed that will provide further citation guidance.

Common Sense Approach The Area Director for El Paso and Lubbock (West Texas) has stated that his compliance staff will utilize a common sense approach and he plans to attend the May STEPS network meeting to give you further guidance.

Drilling Compliance staff must find out a lot of information that will validate their citations: They will have to find out and document when hydrocarbon zones have been or are expected to be reached. What type of well is being worked – (new or a previously drilled well. What underground producing zones they are in and if a history of fluid or gas kicks exists.

Well Servicing and Production Compliance staff will have to find out and document just what job is being performed to ensure that lack of FRC can be cited. A lot of fact gathering and documentation will have to be done to justify a citation.

Regional Coordinator Each regional administrator has been tasked to select a regional coordinator to assist area offices with guidance by the national office. Our coordinator is knowledgeable and very active in his own STEPS group and understands the concerns from industry.

Please note: OSHA is offering the materials developed by the state regions, state agencies and the consultation projects as part of an effort to provide workplace safety and health information. However, these materials have not been reviewed or approved according to formal Agency clearance procedures. Thus, they are not official OSHA statements and cannot be used to ascertain rights or obligations under the OSH Act. In addition, while the materials contain valuable information for enhancing occupational safety and health, the Agency is not representing that all of the information in these materials is accurate or complete.