GCS_newsletter

THE PIPELINEVOL.1 I JUNE 2015

Copyright © 2002-2015 Safety Services Company. All Rights Reserved. safetyservicescompany.com

INITIAL EPA VERDICT OUT: FRACTURING AND WATEROn June 4, at the request of Congress, the United States Environmental Protection Agency (EPA) released a draft assessment which examined the impacts of hydraulic fracturing activities on drinking water resources. According to the results, the study shows “hydraulic fracturing activities have not led to widespread, systemic impacts to drinking water resources,” but “identifies important vulnerabilities.” The draft assessment “is the most complete compilation of scientific data to date, including over 950 sources of information, published papers, numerous technical reports, information from stakeholders, and peer-reviewed EPA scientific reports,” says Dr. Thomas Burke, the EPA’s Science Advisor and Deputy Assistant Administrator of the EPA’s Office of Research and Development.

In order to make as thorough an evaluation as possible, the draft assessment looked at the potential impact of hydraulic fracturing at every stage of the hydraulic fracturing water cycle, to include water acquisition, chemical mixing, well injection, flowback, and wastewater treatment and waste disposal. The study also focused on both water sources currently designated for drinking water and other water sources that could one day be used for drinking water.

According to the EPA, the goal of the study was to “assess the potential impacts of hydraulic fracturing on drinking water resource, if any, and to identify the driving factors that may affect the severity and frequency of such impacts.” It “provides a review and synthesis of available scientific literature and data to assess the potential for hydraulic fracturing for oil and gas to impact the quantity of drinking water resources, and identifies factors affecting the frequency or severity of any potential impacts.”

“...hydraulic fracturing activities have not lead to widespread, systemic impacts to drinking water resources, but...”

Dr. Thomas BurkeEPA Office of Research & Development

continued on next page

WHY IS AN INSURANCE CERTIFICATE IMPORTANT?.................................... pg.2

OSHA FORMS.................................... pg.3

PROTECTION BREATHES DEEP.................................... pg.4

BENEFITS OF LMS.................................... pg.4


Although the overall conclusion of the report is that hydraulic fracturing as a pro-cess does not systemically affect drinking water resources, it did identify incidents in which activities did present an impact. These incidents are uncommon compared to the large number of hydraulically fractured wells in the United States, and not all unique to hydraulic fracturing. The draft assessment contends that these are potential vulnerabilities and not intrinsic results of the fracturing process. While the report includes information about potential vulnerabilities, it was not intended to list all documented cases.

Potential vulnerabilities include:

● Water withdrawals in areas with low water availability

● Hydraulic fracturing conducted directly into formations containing drinking water resources

● Inadequately cased or cement wells resulting in below ground migration of gases and liquids

● Inadequately treated wastewater discharged into drinking water resources

● Spills of hydraulic fluids and hydraulic fracturing wastewater, including flow-back and produced water

Supporters and opponents of hydraulic fracturing are polarized on the issue. The evidence confirms hydraulic fracturing, according to supporters, where under state regulations and best practices it remains a safe gas and oil extraction technique. Opponents maintain the practice puts safe drinking water at risk of contamination.

Natural gas and oil activities are primarily under state-level jurisdiction. States often have the authority to regulate unconventional gas and oil extraction practices under individual state laws due to EPA exemptions. The EPA’s authority extends only so far as the statutory or regulatory exemptions under the Clean Water Act, Safe Drinking Water Act, the Comprehensive Environmental Response, Compensation and Liability Act, and the Resource Conservation and Recovery Act.

Burke believes that “once final, this assessment will give state regulators, tribes, and local communities and industry around the country a critical resource to identify how best to protect public health and their drinking water resources.” Finalization is expected once the draft assessment has been reviewed by the Science Advisory Board (SAB), public review and comment.

SOURCES: http://www.ogj.com/articles/2015/06/epa-draft-assessment-finds-no-widespread-harm http://www.natlawreview.com/article/draft-epa-study-finds-fracking http://yosemite.epa.gov/opa/admpress.nsf/

When a contracting company bid services to an operator, meeting their insurance requirements often stands between you and conducting business. While an insurance certificate is an informal document and not a contract, it provides documented evidence that your company is properly covered against given health and safety risks. Think of it as similar to the proof of insurance document for an automobile; it is not legally binding in the way the full written policy is, but it is vital to show you’ve obtained appropriate coverage.

An online contractor management database serves as a “middleman” between a contractor and their prospective owner clients. Operators may use it to determine whether a contractor has all of its affairs in order. The database establishes whether a contractor has provided an acceptable insurance certificate. An automated system scrutinizes submitted certificates to determine errors: unorganized information, verbiage, and punctuation. The system will reject certificates, requiring resubmission based on an error as trivial as a misplaced comma.

While submission requirements may be strict, it emphasizes the importance of ensuring clear communication between you and a prospective operator regarding insurance requirements. Insurance certificates lacking information or not meeting operational standards could lead to halted work or even complete bid rejection.

Safety Services Company can help ensure insurance certificates are accepted the first time, every time.

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OSHA FORMS – WHAT IS RECORDABLE AND WHAT IS NOT?

The Occupational Safety and Health Administration (OSHA) requires all employers to record all work-related injuries and illnesses that meet certain criteria. Because work-place safety and best practices are extremely important to owner clients, companies with fewer numbers of work-related incidents are often more desirable. This is why it’s important to know what injuries are not recordable, as you may have a longer OSHA 300 log than necessary.

Recordable injuries and illnesses are those that are work-related (that the injury or illness was a result of an incident or exposure while an employee was working) and resulted in death, unconsciousness, restricted work activities or job transfers, days off work, or medical treatment beyond first aid.

If an employee faints while on the job, even if it did not immediately result in an apparent injury, it is recordable. A job transfer in which an employee leaves one job, as a result of hearing damage, to another in which noise exposure is limited is another example.

Any visit to a doctor or health care professional for observation, testing, diagnosis, or diagnostic decisions which does not lead to medical treatment is not recordable. Injuries or illnesses which do not require medical treatment beyond first aid are also not recordable. Examples include using non-prescription medi-cations at non-prescription strength or using hot or cold therapy.

Safety Services Company can help you review your OSHA 300 log to determine whether there are unnecessarily recorded injuries raising your average total.

In one case, a company had an above- average Total Recordable Incident Rate (TRIR) which was preventing them from continuing work with three of their major owner clients. The owner clients gave them a 14-day grace period to increase their grade score before their job bids would be shut down. The company had seven non-recordable injuries on its OSHA logs within the past three years.

After reviewing all three years and examining each incident individually, Safety Services Company was able to identify and remove the seven non- recordable injuries.

The company’s grade ultimately rose from an F to an A within two days, avoided job loss, and became fully compliant.For more information, visit safetyservicescompany.com

OSHA considers the following additional criteria to render an injury or illness recordable:

● Needlestick cuts or injuries from a sharp object which is contaminated with another person’s blood or potentially infectious material

● Any case in which an employee must be removed under the requirements of an OSHA health standard

● Tuberculosis infections evidenced by testing or diagnosis by a licensed health care professional after exposure to a known case of active tuberculosis

● An employee’s hearing test showing that the employee has experienced a Standard Threshold Shift (STS) in hearing in one or both ears and that the employee’s total hearing level is 25 decibels or more above audiometric zero in the same ear(s) as the STS

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BENEFITS OF LMS TO BUSINESS The tools of the trade have changed over the course of the last decade. While one would be hard-pressed to argue against the merits of “hands-on” training, the way we train to prepare for the worksite has changed—perhaps, for good.

40% of global Fortune 500 companies use online training

The strength of specific regulations and policies, and the manner in which these are understood and successfully implemented is more than a compliance issue: it is life or death. But how can policies fall short? It is seldom the policy at fault; but more likely, the absence of proper training. Thousands of injuries and fatalities happen each year as a result of inadequate training.

The issue is an ongoing concern; so much so, that West Virginia University Safety and Health Extension formulated “The Fatality Map” to increase awareness and further re-search efforts to ease the number of fatalities year-to-year. Awareness is best realized, through training.

During the past 10 years, safety and compliance training have migrated to the online space through Learning Management Systems (LMS). Now hands-on training happens at the point and click of a mouse or a clack of a keystroke. Benefits to both employers and employees are evident where workforce logistics challenges are the norm.

The right training keeps the student focused, entertained and able to use the information in real-life situations. Training content must include quality graphics, engaging and current compliant information, secure instructor resources and quick delivery of associated student certifications and wallet cards.

A comparison of instructor led- versus online training provides an understanding of the differences. Instructor led training ranks low on convenience and price.

With online training, employers are able to review performance metrics, customize and update content, track progress and enable reporting. Individual training programs can be designated to specific job descriptions. New employees are automatically assigned the appropriate training. Courses can also be assigned manually when the reissue of a training course is needed due to a workplace incident. Because the training content is stored digitally the need to hire paid instructors is eliminated. Employees can print materials from the LMS, or download content to their smart device.

Businesses need reliable technology systems to support day-to-day operations, and provide scalable and flexible solutions that can ebb and flow with changing needs, policies and best practices. Online training aligns compliance needs with business-centric solutions. Ask an Account Manager how online training can provide benefits to your business.

High

Online Training

Instructor-led Training

LowPrice

PerformanceEngagement Convenience

Ease of Use Measurement

FIGURE Instructor-led vs. Online Training

PROTECTION BREATHES DEEPSafe practices exercised in compromised environments is tantamount to the health and longevity of your business and livelihood. According to a recent article in “Safety and Health Magazine” the Respiratory Protection Standard 29 CFR 1910.134 holds the number four position on the OSHA Top Ten 2014 list of compliance and safety violations (more than 3,223).

The specific standard requires that employers need to protect their workers against insufficient oxygen environments, harmful dusts, fogs, smokes, mists, gases, vapors and sprays by providing the proper respirators. Without the right respiratory protection in use, workers are at risk as these hazards may cause cancer, lung impairment, other diseases or death. Some of the most common mistakes cited in the violations were failure to:

● Provide a written respiratory protection program

● Perform a medical evaluation on employees who must wear respirators

● Select and provide a respirator appropriate for the activity

● Conduct fit testing

● Train employees

Dr. Jeffrey Birkner states in EHSToday, “One factor that is overlooked is comfort. A respirator that is not comfortable is less likely to be worn. Comfort is affected by material selection, visibility, weight of the respirator, ease of use and breathability. Duration and frequency of use must also be considered when evaluating the comfort factor.”

Consult a Safety Advisor to ensure protection from the risks associated with hazardous respiratory environments.

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