energy symposium - combined session 08/12/2010 roughnecks ... · • as an example let’s use a...

Energy Symposium - Combined Session Roughnecks & Master Drillers

08/12/2010

ATF/DOT/OSHA Regulations Jacqueline Armstrong 1

Regulations Coming to a Field Near you:

OSHADOTATF

Did you know the authorities may be planning a visit to your site?

Will You Be Prepared?

What OSHA & other Agencies want to see at

your Rig and Drilling Site

Course Objectives

• Participants will be able to identify some of the Regulations enforced by Government Agencies that may be involved in oilfield employee safety, transportation of related oilfield supplies and associated operations.


08/12/2010


• Employee Safety ‐ Occupational Safety & Health Administration (OSHA)

• Environment ‐ Environmental Protection Agency (EPA)

• Transportation –Department of Transportation (DOT) Transportation of Explosives and other related oilfield supplies

• Explosive Devices – Alcohol Tobacco & Firearms Bureau (ATF)

• Security ‐ U.S. Department of Homeland Security (DHS)

Government Agencies Have Rules for Each Category

A.T.FThe ATF is the final word

on Storage, Recordkeeping and disposal of any explosive material

Alcohol Tobacco & Firearms

The explosives industry in the United States is, composed of approximately 11,000 ATF explosives licensees and permittees

50%37%

11%

2%Failure to Comply with RecordKeeping Requirements

Storage Violations

Licensing

Other


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CFR’s govern the permit and license process. The rules are different in each state

Storage Quantities:PA = 200 Tons; LA & TX = 50 Pounds

Finger Printing Rules:PA & LA = Yes; TX = NO

Timeframe: IMMEDIATEAn ATF rule change is immediate. NO lead time. If you don’t get the word….too bad.

ATF

US Department of Transportation

US Department of Transportation

•Driver Training•Hazardous Materials Training•Fleet DOT requirements – Hours of Service Log•Loading & Unloading

D.O.T. Post 9-11D.O.T. Post 9-11Unloading Regulations

• Regulation: 49CFR106 and all parts following

• Only came into being after 9-11 in an effort to regulate handling of potentially explosive materials that can be transported in bulk. This has spread to anything flammable; solid or liquid. It is also a way to audit carriers to make sure they are hauling only what they say they are.

• The permit is very specific as to description, hazard class, identification number, and packing group. Any change, no matter how slight, requires a new permit. It is not possible to modify or amend a current permit.


08/12/2010


D.O.T. Post 9-11D.O.T. Post 9-11• The term “bulk” does not necessarily mean a tanker with one

compartment in this case. – It applies to any amount that is going to be unloaded directly from the

deck or trailer of a transport vehicle.• As an example let’s use a gasoline delivery tanker.

– There is a permit somewhere for that vehicle and it can only haul the amount and type designated on the permit.

– Notice at your local gas station, one tanker delivers regular gas, one delivers premium grade and one delivers diesel.

– Mid-grade gasoline is mixed at the pump because less people buy mid-grade.

D.O.T. Post 9-11D.O.T. Post 9-11The way this dilemma is overcome in the Oil Field by hauling bulk materials in vessels (totes, bags) and setting them on the ground before transferring the contents……perfectly legal.

The way this dilemma is overcome in the Oil Field by hauling bulk materials in vessels (totes, bags) and setting them on the ground before transferring the contents……perfectly legal.

CSA 2010Now in Full Effect


08/12/2010


CSA 2010• Measurement

• Evaluation

• Intervention

OSHA

Occupational Safety & Health Administration

OSHA Act• OSH Act charges OSHA with prescribing

Occupational Safety and Health rules for every worker in the nation.

• A regulatory body is granted authority to act, and failure for one regulatory body to act, or failure to exercise authority is cause for another proper authority to assume and intervene to regulate conditions.

• Example: If US Coast Guard (USCG) fails to enforce safety then OSHA can intervene on vessels in US water.(The Chao v.Mallard Bay Decision, January 2002)


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Reference to other Standards & Associations via OSHA

• National Electric Code (NEC) NFPA 70• American Conference of Governmental

Industrial Hygienists (ACGIH)• American Industrial Hygiene Association

(AIHA)• Compressed Gas Association (CGA)• National Institute Occupational Safety Health

(NIOSH) Scientific Research • American National Standards Institute (ANSI)

OSHA Approved State PlansOSHA Approved State PlansKnow Your State Rules

OSHA Approved State PlansOSHA Approved State Plans

• State plans are OSHA-approved job safety and health programs operated by individual states instead of by federal OSHA. – State plans must provide standards and enforcement programs that are

• “at least as effective as” the federal OSHA program. – States with approved plans cover most private sector employees as

well as state and local government workers in the state.

• Twenty-six states operate state plans.

• Also not covered by OSHA:• - Employees whose working conditions are regulated by other federal

agencies. – Mine Workers, certain truckers and rail workers, and atomic energy workers

• - Public employees in state and local governments (except for states with approved plans). These include fire fighters, police, and other public servants.


08/12/2010


General Duty Clause:Each employer "shall furnish . . . a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees.“

This is the clause that allows an OSHA Compliance Office to write a citation for “anything unsafe” when no standard exists for it.

Inspection Priorities:

Inspection Priorities:• Imminent Danger

– Any condition that can be expected to cause death or serious physical harm immediately, or before the danger can be eliminated through normal enforcement procedures.

• Fatalities and Catastrophes – Resulting in hospitalization of 3 or more employees

• Employee Complaints/Referrals• Programmed High-Hazard Inspections• Follow-ups to previous inspections


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MOST COSTLY OSHA VIOLATIONS

$723,694

$744,344

$864,373

$928,603

$946,711

$978,156

$1,194,743

$1,786,858

$2,583,616

$3,027,450

.303

.217

.305

.219

.23

.178

.307

.119

.147

.212

29

CFR

19

10

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General Requirements for all Machines

Hazardous (classified) locations

Mechanical Power Presses

Powered Industrial Trucks

Guarding Floor & Wall Openings

Wiring Methods, Components, & Equipment for General Use

(October, 2005 – September, 2006)

Process Safety Management of Highly Hazardous Chemicals

Lockout/Tagout

Mechanical Power-Transmission Apparatus

General Requirements

MOST FREQUENTLY CITED OSHA VIOLATIONS

1091

1527

1529

1792

2029

2133

2282

2628

944

3268

.132

.215

.303

.219

.178

.305

.134

.212

.1200

.147


29

CFR

19

10

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Hazard Communication

Lockout/Tagout

Respiratory Protection

Machines, General Requirements


Transmission Apparatus



Electrical Wiring Methods

Woodworking Machinery

MOST COSTLY OSHA VIOLATIONS

Hazardous (Classified) Locations

Process Safety Management

Mechanical Power Transmission Apparatus

General Requirements-Walking-Working Surfaces


Wiring Methods, Components, and Equipment for General Use

$1,013,382

$1,031,020

$1,249,340

$1,273,753

$1,395,762

$2,131,839

$2,145,082

$3,027,026

$3,380,443

$5,659,569

.303

.219

.305

5A0001

.178

.22

.119

.212

.147

.307

29

CFR

19

10

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General Requirements-All Machines

Lockout\Tagout

General Duty Clause

General Requirements-Electrical


08/12/2010


Slips, Trips, and Falls:Keep Grating in Good Condition, Prevent

Trip Hazard

Slips, Trips, and Falls:Keep Grating in Good Condition, Prevent

Trip Hazard

Grating in Good Condition, Clean, Well Marked, Good Lighting, PPEGrating in Good Condition, Clean, Well Marked, Good Lighting, PPE

Lock Out Tag Out (LOTO)Remove from Service


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General Industries Topics Included in Drilling/ Rig Work

• Hydrogen Sulfide Gas• Release of H2S• Metal Fatigue• Accumulation of H2• American Petroleum Institute

– API Condition I-III – Range of Low-High Hazard

General Industries Topics Included in Drilling/Rig Work

H2S ControlsConfined SpacesPressure Vessels

Compressed Gases &EquipmentControl of Hazardous Energy (LOTO)VentilationRespiratory Protection

Secure Pressure Lines, Flare Lines


08/12/2010



Motor Vehicle SafetyPowered Industrial Trucks

Personal Protective Equipment (PPE)29 CFR 1910 Subpart I

Eye and FaceNoise and Hearing ConservationRespiratory ProtectionPPE 29 CFR 1910.132

PPE – Goggles, Respirator, Gloves Eyewash, Chemical Apron

PPE – Goggles, Respirator, Gloves Eyewash, Chemical Apron

Unobstructed Stairwells,Handrails


08/12/2010


What are the Common OSHA Violations

Common OSHA Violations

• Slips, Trips, and Falls– Handrails, stairs secure &

– No missing steps– Walkways clean, free of tripping hazards

– Floor and Wall openings (1910.22)

• Fall Protection - Inspection program,• Documentation of inspection,

• Training and documentation

JArmstrong BMB Risk 2010 36


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Fall Protection Harness-Inspection?

Fall Protection

• Fall Protection Code• ANSI Z359• Personal Fall Arrest

Systems• Comprehensive

Program• Assisted, Self Rescue• Construction – Body

Harness

• Inspection prior to EACH use, document inspections, document training

• Rescue plan each day, review, communicate

• Conduct Drills to simulate the safe retrieval, document it


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Strains and Sprains

Proper Lifting, proper lifting technique

Buddy- get your buddy for a lift

Slips have 3-4 handles and should be lifted by more than one person

Use of pullback (tail) ropes

Use mechanical lifting aids

Tongs- training to avoid being hit

General Industries TopicsGeneral Industries TopicsCrane, Derrick, and Hoist safetyTrainingOperators, Workers near cranesInspection of all equipment, documents of inspection


08/12/2010


General Industries TopicsEmergency Action PlanEmergency Action Plan

Annual Drills, DocumentedMedical Evacuation, hospital information,

contacts, routes, life flight plans,

Annual Drills, DocumentedMedical Evacuation, hospital information,

contacts, routes, life flight plans,

Review• Many state and federal agencies issue regulations and have enforcement authority over the Oil Rig Field and the affiliated employees.

• Each has a unique set of regulations

• The complexity of the regulations requires many companies to enlist the aid of consultants.

Conclusion• Oil field regulations apply to a specific aspect of the operations to protect the worker, the environment and the oilrig.

• It requires a broad understanding of many disciplines to include each of these layers of protection in a safety plan for an oilfield.


08/12/2010


QuestionsKeep the Environment

Clean & the People Safe.

energy symposium - combined session 08/12/2010 roughnecks ... · • as an example let’s use a...

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