OSHA Oil and Gas REP Overview

Megan Meagher

Compliance Assistance Specialist

(303) 844-5285 x105

What we will cover

• Region VIII Oil and Gas REP– History– Statistics– Most Common Violations– How it Works

• Focused Inspection Directive

• Cooperative Programs

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

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 SIC’s:– 1381 – Oil and Gas Well Drilling Services– 1382 – Exploration – 1389 – Field Support Services

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

Statistics – since beginning of LEP/REP

# of Inspections

*With Citations

# of Accidents(since 5/04)

# of Accidents(5/98 – 5/04)

Total 332 148 24 19

Colorado 279 115 14 15

Montana 25 13 3 1

North Dakota

28 20 7 3

South Dakota

0 0 0 0

*Includes open inspections for which citations may not yet be determined

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)

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

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)

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

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

Inspection Focus

• Limited to employers with more than 10 employees

• Comprehensive safety inspection, any observed health hazards also included

New CPL 02-00-146

• Focused Inspection Directive

• Effective Date 3/6/08• NAICS codes

213111/213112 included in directive

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)

DART/DAFWII Rates

Industry SIC/NAICS 2006 DART 2006 DAFWII

Oil and Gas Well Drilling and Services

Drilling Oil and Gas Wells

1381/213111 2.8 1.6

Support Activities for Oil and Gas Operations

1382 & 1389/213112

1.9 1.3

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.

Inspection Focus

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

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

QUESTIONS??

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 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.