OSHA Oil and Gas REP Overview

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OSHA Oil and Gas REP Overview

• Megan Meagher
• Compliance Assistance Specialist
• [phone] x105

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What we will cover

• Region VIII Oil and Gas REP
• History
• Statistics
• Most Common Violations
• How it Works
• Focused Inspection Directive
• Cooperative Programs

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Local Emphasis Program

• Initiated in response to previous OSHA Strategic
  Management Plan which identified oil and gas
  field servicing operations (SIC 138) as one of 7
  high hazard industries.
• Denver Area Office began Local Emphasis Program
  (LEP) in spring of 2004.
• Program covered only northern Colorado
  jurisdiction

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Regional Emphasis Program

• Targeting program adopted as region-wide
  enforcement program in FY 2005
• Expanded to cover all of Colorado, Montana, North
  and South Dakota
• Includes the following SICs
• 1381 Oil and Gas Well Drilling Services
• 1382 Exploration
• 1389 Field Support Services

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Why Oil and Gas?

• Standard Industrial Classification (SIC) Code -
  138
• 2006 BLS Fatality Rate for All Industries 4.2
• 2006 BLS Fatality Rate for SIC 138 30.1
• Oil and Gas industry fatality rate is roughly 7.2
  times the national average

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Statistics since beginning of LEP/REP
Includes open inspections for which citations
may not yet be determined
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Most Common Violations(Region VIII)

• 5(a)(1)
• 1910.23(c)(1)
• 1910.151(c)
• 1910.212(a)(1)
• 1910.132(a)
• 1910.23(a)(8)
• 1910.132(d)91)
• 1910.184(e)(1)

• 1910.133(a)(1)
• 1910.134(d)(1)(iii)
• 1910.134(e)(1)
• 1910.151(b)
• 1910.184(d)
• 1910.219(d)(1)
• 1910.219(e)(3)(i)
• 1910.303(f)

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5(a)(1) General Duty Clause

• Consensus Standards
• API (RP 54) Occupational Safety for Oil and Gas
  Well Drilling and Servicing
• API (RP 4G) Use and Procedures for Inspecting,
  Maintenance and Repair of Drilling and Well
  Servicing Structures
• AESC
• OSHA PUB 8-1.8 Guidelines on the Stability of
  Well Servicing Derricks

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Most Common Violations (Colorado)

• 5(a)(1)
• 1910.23(c)(1)
• 1910.151(c)
• 1910.212(a)(1)
• 1910.23(a)(8)

• 1910.132(a)
• 1910.184(e)(1)
• 1910.184(e)(3)
• 1910.219(d)(1)1910.133(a)91)

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Oil and Gas REP

• Targeting Offices using different methods
• 1381 - DAO use database to target drilling
  activity in selected county Garfield, Mesa or
  Weld (rotate selected county)
• Also may stop at any observed work site
• 1381 1389 - EAO focus on zones A (San Miguel,
  Dolores, Montezuma, La Plata counties), B (Las
  Animas county), C (Baca Cheyenne, Kiowa and
  Prowers counties)
• May inspect any observed work in targeted zone
  rotated periodically

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Oil and Gas REP

• 1382 1389 DAO will use database to identify
  any establishments in these SIC codes
• Randomized inspection list created
• Opening conference held at office and inspection
  site selected based on active work locations
• Will also be included in any inspection of
  employer in SIC 1381 if onsite

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Inspection Focus

• Limited to employers with more than 10 employees
• Comprehensive safety inspection, any observed
  health hazards also included

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New CPL 02-00-146

• Focused Inspection Directive
• Effective Date 3/6/08
• NAICS codes 213111/213112 included in directive

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Focused Inspection Directive

• Sites can qualify for focused inspection based on
  having lower DART and DAFWII rates than national
  average
• Records must be readily available for review (3
  year review)

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DART/DAFWII Rates
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5 Inspections falling within Category 2 only
qualify for focused status if two or more of the
DART rates are at or below the national average
AND the two most recent complete year DAFWII
rates show a declining trend.
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Inspection Focus
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Cooperative Programs

• Alliances
• Usually association based agreements to work
  together to make improvements in safety and
  health for an industry
• Local Alliances
• OSHA and Mountain States Energy Alliance
• Proposed alliance with Western Slope Safety
  Council

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Resources

• Industry Standards
• Colorado Newsletter
• www.osha.gov
• Oil and Gas e-Tool
• OSHA Technical Manual Section IV, Chapter 1
• OSHA Offices
• 800-321-OSHA

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QUESTIONS??
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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, 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 employers 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 OSHAs
  website at www.osha.gov.

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