Mid Continent Exploration and Production Safety Network (MCEPS) & FRC Update

MCEPS

Alliance between the oil and gas industry and OSHA

Formed in 2008 Purpose is to promote safety, health

and environmental improvement in the exploration and production of oil and gas in Oklahoma, Kansas, and the Texas Panhandle.

MCEPS

The alliance with OSHA has the goal of reducing fatalities and serious injuries in the energy industry

A significant decline has been documented in Oklahoma’s injuries and fatalities in the oil and gas industry

Alliance has been renewed and will be signed next week

OSHA Inspection Activity Oklahoma Area Office conducted 70

inspections in the oil and gas industry through October 1, 2009 to August 19, 2010.

The MCEPS meetings are one of the formats used by OSHA to share the information with industry to prevent recurring citation within the industry.

OSHA Inspection Activity Most frequently cited standard by

OKC’s Area Office:5(a)(1) General Duty Clause of the OSHActOperation of a drilling rig with derrick of

unknown manufacturer and load rating capacity.

Operation of a drilling rig without developing an inspection and repair procedures program.

OSHA Inspection Activity5(a)(1) General Duty Clause of the

OSHActAbsence of emergency escape device

(Geronimo)Access to Geronimo blocked by wind

tarp.Unsafe/Improper rigging:○ Missing structural pin keepers○ Improperly rigged guy wires○ Living quarters located within the fall

radius of rig mast.

OSHA Inspection Activity5(a)(1) General Duty Clause of the

OSHActEmergency escape device not installed

according to manufacturer instructionsImproper use of fall protectionNotification of crane operator of rig

component weights and attachment points prior to lifting operation

OSHA Inspection Activity1910.305 Electrical: Wiring methods,

components and equipment for general use305(g) Flexible cords and cables305(a) Temporary wiring305(d) Switchboards and panelboards305(e) Cabinets or cutout boxes in wet

locations305(b) Protection of conductors entering

boxes

OSHA Inspection Activity1910.184 Material Handling and

Storage: Slings184(e) Sling Identification: alloy steel

chain slings184(f) Wire rope slings: load rating

1910.23 Waling and Working Surfaces23(a) Protection for floor openings23(c) Protection for open sided floors23(e) Railing and toe boards

OSHA Inspection Activity1910.1200 Hazard Communication

1200(f) Labeling of containers of hazardous chemicals

1200(g) Material Safety Data Sheet preparation

1910.307 Electrical: Hazardous locations307(b) Equipment & wiring requirements307(c) Conduit requirements

OSHA Inspection Activity1910.181 Material Handling & Storage:

Derricks181(c) Load ratings and markings181(d) Derrick inspection181(g) Rope inspection181(j) Load handling: size of load

1910.178 Powered Industrial Trucks178(a) General requirements178(j) Operator training

OSHA Inspection ActivitySince the issuance of the FRC

Memorandum, there have been no citations for violations of 1910.132 related to FRC during this time period.There may be pending citations yet to be

issued.

Fatality/Catastrophic InvestigationsTotal 15

SIC 07 Agriculture 01

SIC 13 Oil & Gas 03

SIC 15 & 16 Construction 04

SIC 20-39 Manufacturing 04

SIC 42 Transportation 01

SIC 50 Wholesale trade 01

SIC 73 Services 01

Fatality/Catastrophic Investigations 1389 Oil & Gas

Struck by rear dome lid from exploding tank truck (propane torch used to heat butterfly valve on back of tank truck)

Cigarette lit while employee was draining a tank resulting in an explosion

1611 Highway ConstructionStruck by exploding tire debrisStruck by car in work zone

Fatality/Catastrophic Investigations 1771 Concrete Work

Fall from silo after stepping on a loose section of form

1791 Structural Steel ErectionStruck by piece of steel

1381 Drilling Oil & Gas WellsStruck by load from crane

2499 Wood ProductsFall through skylight on roof

Fatality/Catastrophic Investigations 0782 Lawn & Garden Services

Worker found near tank batteries with mower at bottom of tank (Cause unknown)

3569 Aircraft PartsWhile working on airbrakes of tractor

trailer, truck became engaged dragging the employee under the truck and pinning him between front tire and engine of moving truck

Fatality/Catastrophic Investigations 3321 Gray and Ductile Iron Foundries

Electrical shock resulting in fall from heights

4213 TruckingFall from truck while unstrapping cargo

5093 Scrap & Waste MaterialsCrushed by falling section when working

inside boiler 7389 Business Ser vices

Fall through roof

Program Plan-Inspection ActivityProgram 2010 2011

Total Inspections 791 858

Oil & Gas 45 50

Heat Stress --- 05

Construction 405 435

Points of Interest

OSHA has initiated early stages of rulemaking for Injury & Illness Prevention Program Rule

OSHA revised the Outreach training program requirements- 10 hour course over 2 days and 30 hour course over 4 days

Points of Interest OSHA’s Crane & Derricks in

Construction Final Rule was published August 9, 2010 with effective date of November 8, 2010. Some provisions have delayed effective dates.

April 28, 2010- Memorandum: OSHA training standards to the field requiring safety training in language workers understand.

Points of Interest

April 22, 2010- Memorandum: Administrative Enhancements to OSHA’s Penalty PolicyAddressed changes expected in OSHA’s

penalty structure and calculation procedures

A general increase of overall amount for all penalties

MCEPS Direct Impact to Industry

Frac Tank explosions Crane standard as applicable to

winch trucks Roundtable discussions FRC Issue

Flame Resistant Clothing

FRC issue began 2 years ago with citations issued in North Dakota region

OSHA citation issued to drilling company including operator

Meeting held in Denver with OSHA and industry representatives

Flame Resistant Clothing

FRC Survey from MCEPS, IADC, IPAA, and AESC

Industry discussion groups Request to OSHA:

Industry input to regulation guidanceUpdate the injury and fatality study

Flame Resistant Clothing FRC Memorandum issued March 19,

2010. Culminated in meeting with OSHA in

Washington DC on August 16, 2010. Those included were OSHA, IADC,

IPAA, AESC, API, and STEPS groups including the Permian Basin, National STEPS and MCEPS.

DC Memorandum Meeting The FRC Memorandum will not be

recalled. OSHA took the concerns of industry

seriously and was surprised by the number of responses.

Flash fires in upstream are a low probability but high consequence.

Memorandum is not an official letter of interpretation but a guidance document.

DC Memorandum Meeting Formal rulemaking is a long process. OSHA was not aware of the proactive

organizational approach to working with OSHA and felt that industry was not willing to work with OSHA.

FRC Memorandum can be revised. Perception that hazard assessment

done by industry is inconsistent and inadequate.

DC Memorandum Meeting No phase in period for

implementation was included although is will take considerable time to comply.

Statistics quoted were inaccurate and not applicable.

FRC: Moving Forward

Information presented will be shared with the Assistant Secretary and industry respectfully asked for a timely response.

Industry associations will educate members on hazard assessment and OSHA will provide guidance.

Task force was suggested.

Improving Safety in the Industry

SafeLandUSA Shared Audit OSHA/Industry Alliances

Working together- industry, including operators and contractors, to improve communication and safety procedures.

Thank you!

Any Questions?