osha and houston update oil and gas focus

Jim SheltonHouston North Area Office

[email protected]

FY 2015 OSHA and Houston Update

• Occupational Injury and Illness Recording and Reporting Requirements – NAICS Update and Reporting Revisions• Two parts:

• Requires the reporting of any in-patient hospitalizations, amputations, and loss of an eye…• Updates the list of industries partially exempt

from the requirement to keep work related injury and illness records due to lower rates…

• Effective January 1, 2015

New Updated ‘1904’ Regulation

• Fatalities, hospitalizations, amputations, and loss of an eye will get triaged into three categories (1, 2, or 3)• Category 1 that will be inspected. Examples:• Fatalities, hospitalization of 2 or more, underage workers, history of

multiple injuries, Repeat offenders, SVEP/NEP/LEP, imminent danger• Category 2* will be evaluated. Examples:• Current hazard exposure, safety program failures, serious hazards,

temporary/vulnerable workers, OSHA history, health issues• Area Director evaluates and determines inspect or handle as a

Category 3 Rapid Response Investigation (RRI)

Updated ‘1904’ Regulation

• 41 Incidents Investigated HS• 15 Construction• 13 Hospitalizations• 2 Amputations

• 26 Manufacturing• 19 Hospitalizations• 7 Amputations

• 26 Incidents Investigated HN• 6 Construction• 6 Hospitalizations

• 20 Manufacturing• 9 Hospitalizations• 11 Amputations

About 284 incidents reported and 67 Incidents investigated Jan 1st through June 30th, 2015

Updated 1904 Reporting Requirements

If two or more employees are covered from same employer it was counted as one caseIf two or more employees are covered for different companies a case was counted for each company

• An updated NEP on Amputations was issued effective Aug 13, 2105• Updated NAICS and industries• There will be outreach to the

affected industries and inspections will then be conducted


• Temporary workers are entitled to the SAME protections under the OSH Act as all other covered workers• Staffing agency should evaluate the host employer’s worksite &

have staff trained to recognize safety and health hazards • Both employers must communicate, coordinate, and collaborate

in their efforts • Although the host, generally, has primary responsibility for

identifying hazards and complying with worksite specific health and safety requirements, the staffing agency also has a duty to ensure a safe workplace

Temporary Employees

• A temporary worker requested a safety harness and not provided with it fell 12 feet through the roof resulting in his hospitalization with fractured arms and severe contusions. • $362,500 penalty for seven violations (including one willful and

four willful egregious) for failing to provide fall protection and not promptly reporting the hospitalization. Cited also for not training employees in the use of fall protection and ladders• The staffing agency also received a serious citation

Temporary Employees

Temporary Employees

• Final Rule published May 4, 2015• Effective date August 3, 2015• Full enforcement postponed until

October 2, 2015• Full enforcement for residential

construction postponed until January 8, 2016• Requires a good faith effort….

Subpart AAConfined Spaces in Construction

• Detailed provisions requiring coordination of activities on a multi-employer worksite

Differences Between Cnst and GI

• A competent person must evaluate the worksite and identify confined spaces including permit spaces• Requiring continuous atmospheric monitoring whenever

possible• Requiring continuous monitoring of engulfment hazards• Allowing suspension of a permit instead of cancelation under

certain circumstances

Differences Between Cnst and GI

• Employers who direct workers to enter without using a complete permit system must prevent worker exposure to physical hazards through elimination of the hazard or isolation such as LOTO• Employers resulting on local emergency services for emergency

services must arrange for the responders to give the employer advanced notice if they will be unable to respond• Training must be in a language and vocabulary the worker

understands

Clarifications to the GI Standard

GHS

• The major changes to the HCS include:• Hazard Classification• Labels• Safety Data Sheets• Information and Training

• December 1, 2013 workers were to be trained on the new labels and Safety Data Sheets• CPL 02-02-079 Inspection Procedures for the

Hazard Communication Standard (HCS 2012)• Effective July 9, 2015

• Silica• Primary Metals Industries• Process Safety Management• Shipbreaking• Trenching and Excavation

• Combustible Dust• Federal Agencies• Hazardous Machinery• Hexavalent Chromium• Isocyanates• Lead

National Emphasis Programs (NEP):

• The Severe Violator Enforcement Program (SVEP) is outlined in Compliance Directive 02-00-149• Applies to NAICS…• 211111 Oil and Gas Extraction• 213111 Drilling Oil and Gas Wells• 213112 Support Activities for Oil and Gas

Oil and Gas E & P

• Two or more Willful or Repeated violations or Failure-To-Abate notices or any combination of these violations/notices based on high gravity serious violations related to upstream oil and gas activities will now be considered a severe violator enforcement case

Oil and Gas E & P

• First R-VI EEP case June 2015 based on two Willful, seven Serious, and one Repeat citations with $221,200 in proposed penalties issued related to a multiple fatality inspection• The Willful citations: Use of a open flame

potable heater on the rig floor and failure to provide and use FRCs for protection from flash fires had been previously cited• Repeat was for egress from the derrick not

properly installed

Oil and Gas E & P

• Clarification of Employer's Continuing Obligation to Make and Maintain Accurate Records of Each Recordable Injury and Illness 1218-AC84• Improve Tracking of Workplace Injuries and

Illnesses 1218-AC49 at OMB• Walking Working Surfaces and Personal Fall

Protection Systems (Slips, Trips, and Fall Prevention) at OMB

Current Rules On the Radar

• OSHA penalties could increase in 2016• Federal Civil Penalties Inflation Adjustment Act

Improvements Act of 2015• Penalties could be adjusted for inflation from

1990• Maximum for a Willful citation from $70,000 to

possibly about $124,000• Maximum for a Serious citation from $7,000 to

possibly about $12,000• Would probably occur no later than August

2016

Items of Interest

• Whistleblower protections• 1099 ‘workers’• Darden Factors and WHD

‘Economic Realities’• WHD task force in wages

• Citation format pilot program• New ‘Enforcement Weighting

System’

Items of Interest

• Safety and Health Program Management Guidelines open for comments• Update of the 1989

Guidelines• Voluntary not a mandatory

standard • Comments accepted until

February 15, 2016

Items of Interest

Region VI

• Upstream Oil & Gas• High Noise in Manufacturing• Fabricated Metal• Falls in Non-Construction• Healthcare*

• Construction• Heat Illnesses• Cranes in Construction• Grain Handling• Poultry Processing*

Regional Emphasis Programs (REP)

* New for FY 16

Inspection information was taken from the OSHA public website and is not meant to be an exact or official count of inspections. ‘No

Inspection’ entries were not included. ‘Accidents’ which would be from New Mexico, a State-Planned State, were included into the

OSHA fatalities/catastrophies aka ‘Fat/Cat’ category. Incidents were edited to removed cases that appeared to be outside OSHA

jurisdiction such as vehicle accidents on public roadways and natural causes. Narratives were edited and may not reflect the final findings or a later determination that they were non-work related etc. hence they are not an exact or official count of incidents. The data is meant to give an overall picture of activity for accident prevention purposes

Data Disclaimer

NAICS 211111Oil and Gas Extraction

FY 13 FY 14 FY 150

5

10

15

20

25

30

35

40

45

50

OSHA Website Inspection Search

Planned UnPgm Related Pgm Related Fat/CatReferral Complaint UnPgm Other Employer Referral

Inspections R-VI NAICS 211111

Standard Cited Narrative

1910.151(c) 3 Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use

1910.106(b)(6) 2 "Sources of ignition." In locations where flammable vapors may be present, precautions shall be taken to prevent ignition by eliminating or controlling sources of ignition. Sources of ignition may include open flames, lightning, smoking, cutting and welding, hot surfaces, frictional heat, sparks (static, electrical, and mechanical), spontaneous ignition, chemical and physical-chemical reactions, and radiant heat

1910.134(d)(1)(iii) 2 The employer shall identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH

Top 5 MFC FY15 (Fed OSHA R-VI)NAICS 211111


1910.151(b) 2 In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available

1910.307(c)(3) 2 Safe for the hazardous (classified) location. Equipment that is safe for the location shall be of a type and design that the employer demonstrates will provide protection from the hazards arising from the combustibility and flammability of vapors, liquids, gases, dusts, or fibers involved

Top 5 MFC FY15 (Fed OSHA R-VI) NAICS 211111

• Employee at a team building event fell off a ""Segway"" personal transporter vehicle she was riding as part of a sightseeing tour. The Segway hit a uneven patch of roadway and the employee's head made contact with the concrete surface

Fatalities R-VI NAICS 211111

NAICS 213111Drilling Oil and Gas Wells

FY 13 FY 14 FY 150

20

40

60

80

100

120

140


Planned Fat/Cat Pgm Related Complaint UnPgm RelatedReferral F-Up Pgm Other ER Referral



OSH ACT of 1970 Section (5)(a)(1)

16 Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees

1910.23(c)(1) 14 Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a toeboard wherever, beneath the open sides…

1910.151(c) 9 Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use



1910.305(g)(2)(iii) 9 Flexible cords and cables shall be connected to devices and fittings so that strain relief is provided that will prevent pull from being directly transmitted to joints or terminal screws

1910.304(g)(5) 7 Grounding path. The path to ground from circuits, equipment, and enclosures shall be permanent, continuous, and effective


• Worker was found dead atop a drilling rig• Employees suffered serious burn injuries when the vapors from an open frac

tank were ignited. The crew had been tasked to replace the existing wellbore pipe to a smaller diameter in order to increase pressure to force well water and other chemicals to pour out of the well faster and be routed to a frac tank. A potential ignition source was a portable generator with light pole 12’ feet from the frac tank• Two employees were traveling from a work site in a personal vehicle. The two

employees reached a highway construction zone and were directed to stop their vehicle by highway flaggers. While stopped, the vehicle occupied by the two employees was struck from behind by an 18-wheeler at full speed. One employee passed away at the scene while the second employee passed away while being transported to the hospital


• Worker was working as the motorman with an 8 inch coupler and tubular pipe, pushing it towards the V Door located on the rig floor. The pipe came unthreaded from the collar, falling and striking the worker on the back • An employee was assisting a backhoe operator to move a frack tank.

The employee walked between the frack tank and the backhoe and was crushed between the frack tank and the bucket of the backhoe • Employee was struck in his chest area and knocked backwards.

Employee struck his head on metal tongs lying on the rig floor of a drilling rig


• Worker was working on derrick and fell• Four of a five man drilling rig crew were on the drilling rig floor preparing to

make a connection (insert a length of drilling pipe into the drilling string) when a flash fire occurred on the floor work area. All four employees clothing caught fire along with all the combustible debris and floor materials. Two of the employees expired on the well site and two were hospitalized in critical condition. The fifth employee was on the mud pits and received severe burn to the hands when aiding the other members; the employee was treated and released. The ignition source appears to be a forced air diesel heater with the oil based drilling mud the initial and main fuel• Employee was in the process of tripping pipe. He had leaned over to pull slips,

he grabbed the iron roughneck (extended the handle of the roughneck) catching his head between the roughneck and the pipe


• Three workers died from an explosion on a work over rig • Employee was struck by casing and was thrown off the drilling

platform approximately fifty feet and was dragged along the ground by the casing• Employee was working on the derrick and complained about feeling

hot and around 10am, he came down and drank water, went back up, and complained about not feeling well and told operator he was getting too old around 12pm. He came down off the derrick and then asked for a lighter to smoke in the shade. Around 1:30 pm he was pale and breathing became labored, the operator called 9-1-1 from the gate on the highway


• Employees were fishing. Bringing in fish and the fish got stuck. Service rig tipped over killing the derrick hand and severely injuring the rig supervisor


NAICS 213112Support Activities for Oil and Gas

FY 13 FY 14 FY 150

20

40

60

80

100

120

140

160


Planned Pgm Related Fat/Cat Complaint UnPgm RelatedReferral F-Up Other ER Referral



OSH ACT of 1970 Section (5)(a)(1)

21 Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees

1910.23(c)(1) 12 Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a toeboard wherever, beneath the open sides…

1910.106(b)(6) 7 "Sources of ignition." In locations where flammable vapors may be present, precautions shall be taken to prevent ignition by eliminating or controlling sources of ignition. Sources of ignition may include open flames, lightning, smoking, cutting and welding, hot surfaces, frictional heat, sparks (static, electrical, and mechanical), spontaneous ignition, chemical and physical-chemical reactions, and radiant heat



1910.151(b) 7 In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available

1910.303(b)(2) 6 Installation and use. Listed or labeled equipment shall be installed and used in accordance with any instructions included in the listing or labeling


• Two vehicles were operating on a private lease road. A truck collided with a semi-truck and trailer causing extensive damage to the driver's side of the oilfield services truck and fatal injuries to the driver• Employee died when he was potentially exposed to H2S at an oil &

gas site. He was wearing an H2S monitor but it was on test mode. Decedent was found in middle of the road about a mile away from his truck which was parked near a well site• Air mixed with gas and there was a spark in the well. violent

explosion on the surface. Large debris was dislodged. Four employees were struck by the debris, one died


• Employee was driving a tractor trailer on a private ranch road leaving the fuel tanks and as he went around a curve the vehicle turned over onto the operators side• Decedent fell from height while working on heater treater• An employee was struck-by a pressurized pipeline enclosure door

during gas line servicing operations• An employee was assigned to an oil tank battery to gauge and

monitor oil production. The employee was found by a delivery driver, at the bottom of stairs next to the tank battery• Servicing rig derrick collapsed


• The victim was working on fixing a piece of equipment (changing a steel line bump unit) when a wrench struck the employee in the head• Decedent was found lying under a transport truck with a

detached arm and clothing was found wrapped around the drive shaft from the PTO to the pump mounted on the truck• Employee was struck by tubing pipe that fell from the elevators• Front end loader equipped with forks was off loading drill pipe

from a semi trailer and was backing up and struck the truck driver


• Worker was grinding on a tank pipe and there was a fire and explosion that blew the tank lid off and he fell in the tank• Employees were attempting to disengage the drivetrain of a disabled

truck to put it on a trailer for towing. The truck began to roll and rolled over the decedent, causing fatal injuries• Primping a perforation gun when it unexpectedly exploded• The drill line broke/split and the block and elevator fell and struck the

employee• Truck driver was found dead in the pipe yard. Two 9 5/8" pipes had

rolled off the rack on top of him


• A crew was working on pressuring a 10 inch pipeline when a plumbers plug blew out of the line striking one employee and two other employees were struck by the released pressure. Two employees were treated and the other worker died • A worker was at the site to treat the well by injecting treatment

chemicals from a truck. He was working alone and was found with blunt force trauma to his head. The well has approx. 450 lbs of pressure and it appears the victim opened a valve that released well pressure causing a pipe to dislodge at the well and struck him in his head• Employee on an oil and gas well drilling rig remove the pin on the A leg

and was struck in the head resulting in fatal injuries


• The employee was standing on top of the draw works of a work-over rig. The employee victim fell into the point of operation of the drill cable line when the employee victim attempted to exit the draw works area. The employee victim's left leg was wrapped by the drill cable line as it lifted a rig block. The drill line cables force pulled the employee victim into the spool drum during rotation. The employee victim sustained head injuries as the drill line cable pulled the employee victim out from the rotating spool drum• "The victim was part of a four man crew tasked with replacing filters on a

separator vessel for a contractor. The employee passed out; he came to and felt dizzy, disoriented and then sat in the truck trying to cool off. He was driven two and half hours home where he was dropped off and he passed away a short time after his arrival


• Worker was raising a oil/gas separator with a rough terrain forklift when the upper boom contacted a 7.2kv powerline. Others made three attempts to rescue him. The first two attempts a worker tried to knock him away from the forklift but the electrical energy threw him back. On the 3rd attempt the employee tried to lift his legs and his boots melted in his hands. An employee approached to put out the fire with a metal fire extinguisher and as he approached an electrical arc struck the fire extinguisher knocking him back approximately 20 feet resulting in his hospitalization. The forklift operator died at the scene• Three employees were lifting a pipe handler off a flat bed truck using a gin pole

truck. The decedent and a second employee had hooked the chain slings up to the pipe handler. The chain slings were connected to part of the support structure of the equipment. When lifting, one of the support structures broke at the weld and the pipe handler fell to the ground striking one of the employees in the back and he died


• Truck driver for company was in process of picking up a load of produce water for energy company. He exited the truck while backing up for unknown reason and was struck-by the truck and ran over.• The employee had just left a fracking site and had pulled his truck over along a

leased road. The truck operator had called the dispatch and stated he was hot and needed to cool off and was going to get something to drink. The truck operator was subsequently found dead. Potential heat stress • Employee was caught in a pumping unit• Employee was operating a bulldozer to move coke debris to load into a hopper

when the dozer entered a drainage pit for water to enter the processing area opposite the dividing wall/drains. Employee backed the dozer into the pit, completely submerging it. The temperature of the water was approximated by the emergency response crew to be 200 degrees


Houston

• From Oct 1st, 2008 to September 31th, 2015 there have been approximately 358 fatalities/catastrophes in the area of the Houston North and Houston South Area Office jurisdictions• The numbers are estimates and are not

meant to be an exact count of incidents inspected or under OSHA’s jurisdiction. The information is for prevention purposes and not a statistical study

Houston Fatalities and Catastrophes

FY 09 FY 10 FY 11 FY 12 FY 13 FY 14 FY 15*0

10

20

30

40

50

60

70

80

27

18

2629

2327 28

40

2723 25 25

20 20

67

4549

54

48 47 48

Hou North Hou South Hou Total• Incidents appear steady with no big change in either the North or the South overall• Fatalities long term

appear to be trending upward on the North side and downward on the South side

Houston Activity Overall

* FY 2015 Data Search Oct 1, 2015

FY 09 FY 10 FY 11 FY 12 FY 13 FY 14 FY 15*0

10

20

30

40

50

60

70

80

31 29 30 2831 33

28

36

1619

26

1714

20

67

4549

54

48 47 48

Hou GI Hou Const Hou Total• General Industry (1910) was lower in FY15 after tapering up for several years• Construction (1926)

which seemed to be trending downward rose sharply in FY15

Houston Activity Overall


FY 09 FY 10 FY 11 FY 12 FY 13 FY 14 FY 15*0

5

10

15

20

25

30

35

1514

19

1416

18

1516

15

11

1415 15

13

3129

3028

3132

28

Hou North GI Hou South GI Hou Total GI• General industry decreased in both the North and the South

Houston General Industry Activity


FY 13 FY 14 FY 150

1

2

3

4

5

6

7

8

9

10

General Industry Focus 4

Struck By Caught Between FallsElectrical Other

• General Industry Focus Four• Electrical, Caught Between,

Struck By, and Falls decreasing with Other increasing• A big factor in the increase in

Other incidents were the four heat related fatalities

Houston General Industry Activity

1910 Standard # Requirement1910.212(a)(1) 44 One or more methods of machine guarding shall be provided to protect the

operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks…

1910.1200(e)(1) 31 Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, safety data sheets, and employee information and training will be met, and which also includes…

1910.212(a)(3)(ii) 26 The point of operation of machines whose operation exposes an employee to injury, shall be guarded. The guarding device shall be in conformity with any appropriate standards therefor, or, in the absence of applicable specific standards, shall be so designed and constructed as to prevent the operator from having any part of his body in the danger zone during the operating cycle…/

Top 10 MFC General Industry Houston*

1910.215(b)(9) 19 Safety guards of the types described in Subparagraphs (3) and (4) of this paragraph, where the operator stands in front of the opening, shall be constructed so that the peripheral protecting member can be adjusted to the constantly decreasing diameter of the wheel. The maximum angular exposure above the horizontal plane of the wheel spindle as specified in paragraphs (b)(3) and (4) of this section shall never be exceeded, and the distance between the wheel periphery and the adjustable tongue or the end of the peripheral member at the top shall never exceed one-fourth inch….

1910.1200(g)(8) 18 The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s)...

1910.215(a)(4) 18 On offhand grinding machines, work rests shall be used to support the work. They shall be of rigid construction and designed to be adjustable to compensate for wheel wear. Work rests shall be kept adjusted closely to the wheel with a maximum opening of one-eighth inch to prevent the work from being jammed between the wheel and the rest, which may cause wheel breakage…


1910.305(b)(1)(ii) 18 Unused openings in cabinets, boxes, and fittings shall be effectively closed.

1910.1200(h)(1) 16 Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area…

1910.147(c)(1) 16 The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative…

1910.147(c)(4)(i) 16 Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.


*Top 10 MFC 1910 Standards does not include Standards such as 5(a)(1) or .1904 which could apply to either industry. Standards such as 1910.1200 which could also

apply to either industry are included under Part 1910

Questions?• Houston North Area Office Joann Figueroa, Area Director

Jim Shelton, CAS690 S. Loop 336 W., Suite 400Conroe, TX 77304

[email protected]

• Keep up to date with the Houston North Area Office email list. Contact Jim Shelton at the above email

mailto:[email protected]

Disclaimer

• This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics [or hazards], it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at www.osha.gov.

osha and houston update oil and gas focus

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