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PPE Hazard Assessment For US Onshore E&P
Rick Ingram, S.G.E.OSHA VPP Advisor
BP North America [email protected]
Permian Basin STEPS Network Meeting October 11, 2011
Fatality Rate in South Texas has dropped from 8 to 1Fatality Rate in South Texas has dropped from 8 to 1
• Collaborate• Research• Standardize• Simplify• Educate
• >1000 companies >1000 companies • > 4000 members> 4000 members• growinggrowing
KO: KO: 2012?2012?
National STEPS NetworkNational STEPS NetworkCreating the Safest Industry in IndustryCreating the Safest Industry in Industry
KO:2011
WOGISAWOGISA
4 Corners May 5, 2011
• OSHA Factsheet: www.OSHA.gov
• PPE Standard; 1910.132.d
• Training Requirements; 1910.132.f
• FRC and the Oil patch – The Memorandum
• How To: ABC’s of PPE Hazard Assessment
• Examples of a PPE Hazard Assessment
• A NIOSH Study: Unseen Hazards
• Back-up slides: NFPA
AESC, IADC, National Steps Network, API and Attended a meeting with OSHA in Washington, D.C. on August 16, 2010 and followed up on September 21, 2011
OSHA is Joining a work team in Houston to develop a Recommended Practice
Updated information will be shared upon request.
OSHA, The US Oil patch & FRC
OSHA, The US Oil patch & FRC
Enforcement Policy for Flame-Resistant Clothing in Oil and Gas Drilling, Well Servicing and Production-Related Operations
A Memorandum was issued on March 19, 2010 by Richard Fairfax, Director of Enforcement Programs
The Memorandum was intended to clarify OSHA’s policy for citing the general industry standard for personal protective equipment (29 CFR 1910.132(a)) for failure to provide and use FRC
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Standard Interpretations - Table of Contents
• Standard Number: 1910.132; 1910.132(a); 1910.132(d)
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the
requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information.
To keep apprised of such developments, you can consult OSHA's website at http:/ / www.osha.gov.
March 19, 2010
MEMORANDUM FOR: REGIONAL ADMINSTRATORS STATE PLAN DESIGNEES
FROM: RICHARD E. FAIRFAX, Director Directorate of Enforcement Programs
STEVEN WITT, Director
Directorate of Cooperative and State Programs
SUBJECT: Enforcement Policy for Flame-Resistant Clothing in Oil and Gas Drilling, Well Servicing, and Production-Related Operations
This memorandum is intended to clarify OSHA's policy for citing the general industry standard for personal protective equipment (PPE), 29 CFR 1910.132(a), for the failure to provide and use flame-resistant clothing (FRC) in oil and gas well drilling, servicing, and
production-related operations. For the purpose of this memo, FRC includes both flame-resistant and fire retardant treated clothing. Clarification of the need to provide and use FRC during certain drilling, servicing, and production-related operations is necessary to
resolve its inconsistent use among drilling contractors, well servicing contractors, and oil and gas companies that employ thousands of workers in these operations. OSHA inspection history and current information, including consensus standards, scientific evidence, and accident and injury data, indicate a potential for flash fires during certain well drilling, servicing, and production-related operations.
Where FRC is not being used by workers in these operations, a citation under 29 CFR 1910.132(a) requires evidence that the employer had actual notice of a need for protective equipment, or that a reasonable person familiar with the circumstances, such as facts unique
to the industry, would have recognized a hazardous condition warranting the use of that equipment.
Subject: Follow Up to August 16th Meeting
To All OSHA Attendees to Industry/OSHA Meeting of 8/16/2010
Gentlemen,
We want to first thank each of you for allowing industry to comment concerning the memorandum
issued concerning FRC in March of this year. In summary, we wanted to make sure we were all in
agreement on our notes and what we believe the next actions are concerning the FRC issue.
This is what we understood in outlining the OSHA position:
· FRC Memorandum will not be recalled
· OSHA takes the concerns communicated in the many responses seriously and was
surprised by the number of responses received
· Flash fires in upstream are a low probability, but high consequence
· Memorandum is not an official Letter of Interpretation or Directive, but an enforcement
policy
· Memorandum is an attempt to speed the regulatory update process by Asst. Secretary
Michaels
· Formal Rulemaking, including public comment periods take too long to execute, as much as
8 years in some cases
· OSHA attempted to sign alliances with API and IADC in 2005 but turned down because
IADC and API have worked with governmental agencies without signing any type of
agreement. Examples of industry working with OSHA are: Upstream e-Tool, OSHA Fatality
Study, Rig Inspection Form, Cooperation and support of the Steps alliance efforts
· OSHA in DC is largely unaware of the work that the STEPS Networks, AESC, IADC, API,
IPAA have been doing, our positive impact and momentum
· OSHA in DC is not aware of a general shift in industry organizations working with OSHA
proactively
· Consequently, the general perception by OSHA is that industry is unwilling to work together
with OSHA proactively
· OSHA is willing to listen and work with us and this meeting was an attempt to open the door
for comment on FRC use
· FRC Memorandum can be revised or an addendum possibly added
· Perception that most PPE hazard assessments in upstream Oil and Gas are
inconsistent and generally inadequate
· OSHA has not added Oil and Gas upstream to a National Emphasis Program but could
PPE & Worker Protection
Personal Protective Equipment
PPE comes in at third place in OSHA’s Hierarchy of means to protect workers.
“Eliminate Control and Protect”
PPE is the Last Line of Defense
From the OSHA PPE Factsheet
• Engineering controls involve physically changing a machine or work environment.
• Administrative controls involve changing how or when employees do their jobs.
• Work practices involve training workers how to perform tasks in ways that reduce their exposure to workplace hazards.
From the OSHA PPE Factsheet
As an employer, you must:• Assess your workplace to determine if
hazards are present that require the use of PPE.
• If such hazards are present, you must:– Select PPE and require employees to use it– Communicate your PPE selection decisions
to your employees– and select PPE that properly fits your
workers.
1910.132(a) Application. Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.
The OSHA Standard: 1910.132(a) Protective Equipment
• 1910.132(b) Employee-owned equipment. Where employees provide their own protective equipment (i.e. Boots),?? Who is responsible??
the employer shall be responsible to assure its adequacy, including proper maintenance, and sanitation of such equipment.
1910.132(c) Design. All personal protective equipment shall be of safe design and construction for the work to be performed.
The OSHA Standard: 1910.132(b), (c) Employer Responsibility, Design
OSHA Standard: 1910.132(d) Hazard assessment and equipment selection.
1910.132(d)(1) The employer shall assess the
workplace to determine if hazards are present, or are likely to be present, which
necessitate the use of personal protective equipment (PPE).
• If such hazards are present, or likely to be present, the employer shall:
• 1910.132(d)(1)(i) Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
OSHA Standard: 1910.132(d) Hazard assessment and equipment selection.
OSHA Standard: 1910.132(d) Hazard assessment and equipment selection.
1910.132(d)(1)(ii) Communicate selection decisions to each affected employee; and,
1910.132(d)(1)(iii) Select PPE that properly fits each affected employee.
Note: Non-mandatory Appendix B contains an example of procedures that would comply with the requirement for a hazard assessment.
1910.132(d) Hazard assessment and equipment selection
1910.132(d)(2) The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.
What if OSHA Asks? Demonstrate Compliance
How To: PPE Hazard Assessment Basics
Make a list: A Simple Spreadsheet will work• List the different types of tasks:
– Use JSA’s, Incidents, Near Misses, Industry Data• List the potential hazards within the tasks• List the PPE needed to help protect• Research the specific PPE needed• Involve the employees performing the work• Add a certification and date • Most effective are Craft Specific• Make it a living document and Post it
– Use it to develop better JSA’s – Continually Improve the list– Use it for training
Note: Not all Personal Protective Equipment will be required if a hazard assessment was conducted and it identifies that certain hazards are not present. The PPE associated with the non -present hazard may not be utilized.
Hard Hat
Safety Glasses
Steel Toed Boots
Hearing Protection
Rubber Gloves
Cotton Gloves
Leather Gloves
Splash Apron
Face Shield
Goggles Safety Harness
LOTO Equipment
Kevlar Sleeves
Ground Fault Interrupters
Respirator FRC
Bringing On/Shutting In a Well
X X X X X X
Checking Separator Sight Glass
X X X X X X
Repair/Replacing Dump Valve
X X X X X X X
Lighting a Reboiler X X X X X X X X Working on a Chemical Pump
X X X X X X X
Changing Glycol Filters X X X X X X Starting a Compressor X X X X X X X Conducting Compressor Maintenance
X X X X X X X X X
Shutting Electrical Breaker X X X X X X X X Loading/Unloading Chemicals
X X X X X X X X
Transferring Chemicals X X X X X X X X Rigging Slings X X X X X X X Using Electrical/Air Driven Tools
X X X X X X X X X X
Housekeeping X X X X X X Spill Cleanup X X X X X X X Basic Workover Operations X X X X X X X Gauging a Tank X X X X X Meter Testing X X X X Plate Inspection X X X X X X Well Testing X X X X X X Choke Change X X X X X X X Replacing Rupture Disc X X X X X X X X Loading/Unloading Pipe X X X X X X Climbing Ladder X X X X X X X Handling NORM Material X X X X X X X X Chemical Storage Area X X X X X X X X Basic Drilling Operations X X X X X X X X X X X
HAZARD ASSESSMENT/CERTIFICATION FORM FOR PERSONAL PROTECTIVE EQUIPMENT (PPE)
___________________________________________________ ____________ __________________________________________ Installation (Operation Center Facility) Date Signature (Individual certifying evaluation)
Source of Hazard to Employees (Operation)
Assessment of Hazard (Agent)
Head Protection Eye & Face Protection Hand Protection Foot Protection
IMPACT: Grinding, chipping, chiseling, sawing. PENETRATION: Glass, hand tools, metal rods, board road nails, etc. Material/Equipment handling, compression, etc.
Flying fragments, objects, large chips, slag, Objects with the potential to penetrate the hands or feet. Objects falling, dropping, or rolling.
Hard-hats meeting ANSI Z89.1 - 1986.
General (blowing dust, loose particles) - Safety glasses w/side shields (Z87.1) Grinding/chipping etc. - Safety glasses with side shields and a full face shield are required.
For light work a cotton or canvas glove. Rough or abrasive material requires leather or leather reinforced metal stitching.
Metatarsal foot guards where compression and material handling may warrant guards. Footwear that provides puncture protection.
CHEMICAL: Acid, caustic, and other chemical handling, contact with chemical handling equipment, etc.
Splash, spray, coating on surface of equipment. Inhalation, ingestion, skin contact, systemic effects, and birth defects.
Hard-hats meeting ANSI Z89.1 - 1986. For spray or overhead chemical handling a slicker with hood is recommended.
Goggles, eyecup and cover type. Use of face shield and goggles is required when handling open containers and/or splash potential exists.
Gloves should be selected based on the type of chemicals used. Refer to MSDS for specific material requirements of gloves that must be used.
Incidental contact - Work shoes or boots that provide a continuous barrier against absorption (no holes/reactive synthetics) Prolonged/significant quantity contact - Rubber boots.
HEAT: Boiler operations steam equipment, hot crude oil/water, production, fired heater equipment, reboilers and piping, welding, etc.
Hot sparks contact with high temperature equipment. Contact with high temperature fluids.
Hard-hats meeting ANSI Z89.1 - 1986.
Safety glasses with side shields at all times. Raised temperature operations - Face shields, goggles/ spectacles with side shields. (Operations involving heat may also involve light radiation)
Insulated gloves, designed for heat.
Non-synthetic material that maintains a continuous barrier against absorption (no holes).
Approver: Duane Allman, President Document owner: Barry Oakley Management Statement: My Company is committed to following the OSHA General Duty Clause, protecting our employees from recognized hazards. The PPE Hazard assessment is designed to not only list recognized hazards in our operations, but to give each
employee an opportunity to provide input as new or potential hazards are recognized. Due to our diverse business, a separate PPE Hazard Analysis worksheet will be completed for separate types
of work we do. My Company JSA program is always to be used for recognizing and mitigating hazards encountered in daily
operations at work sites. The PPE Hazard assessment is similar to JSA, but is a more formal way to capture hazards, and proposed
changes will be reviewed by the HSE committee at regular meetings, with accepted changes formally added as decided by committee with management approval.
PPE identified on the Hazard Assessment will be provided and included in the My Company training program. My Company management encourages employee involvement and participation.
Definitions: PPE: Personal Protective equipment. A device designed to protect a specific body part from a known or
potential hazard. Hazard: Something which if not eliminated or controlled would potentially cause harm to people or damage
to the environment. Energy examples include: Gravity, Chemical, Thermal, Pressure, Biological, Motion, Radiation & Electrical
Type of work:
Job task Hazard Energy Body Part PPE Reviewed by: __________________ Date: __________ Revised: ______________ Approved by: ________________ Signed: _____________ Date:________
Who is Responsible, Operator or Contractor?
1910.132(e) Defective and damaged equipment. Defective or damaged personal protective equipment shall not be used.
OSHA Standard: 1910.132(e) Hazard assessment and equipment selection.
1910.132(f)(1) The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following:
1910.132(f)(1)(i) When PPE is necessary; 1910.132(f)(1)(ii) What PPE is necessary; 1910.132(f)(1)(iii) How to properly don, doff, adjust, and wear PPE; 1910.132(f)(1)(iv) The limitations of the PPE; and, 1910.132(f)(1)(v) The proper care, maintenance, useful life and disposal of the PPE.
OSHA Standard: 1910.132(f)(1)Training
1910.132(f)(2) Each affected employee shall demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE.
1910.132(f)(2)Training
1910.132(f)(3) When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (f)(2) of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where:
1910.132(f)(3) Training
1910.132(f)(3) Training
1910.132(f)(3)(i) Changes in the workplace render previous training obsolete; or
1910.132(f)(3)(ii) Changes in the types of PPE to be used render previous training obsolete; or
1910.132(f)(3)(iii) Inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill.
1910.132(f)(4) The employer shall verify that each affected employee has received and understood the required training through a written certification that contains the name of each employee trained, the date(s) of training, and that identifies the subject of the certification.
1910.132(3)(f)(4) Training
1910.132(h) Payment for protective equipment.1910.132(h)(1) Except as provided by paragraphs (h)(2) through (h)(6) of this section, the protective equipment, including personal protective equipment (PPE), used to comply with this part, shall be provided by the employer at no cost to employees.
1910.132(h)(2) The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job-site.
Payment for PPE
1910.132(h)(4) The employer is not required to pay for:1910.132(h)(4)(i) The logging boots required by 29 CFR 1910.266(d)(1)(v);1910.132(h)(4)(ii) Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots; or1910.132(h)(4)(iii) Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen.
Payment for PPE
Payment for PPE
1910.132(h)(5) The employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE.
1910.132(h)(6) Where an employee provides adequate protective equipment he or she owns pursuant to paragraph (b) of this section, the employer may allow the employee to use it and is not required to reimburse the employee for that equipment. The employer shall not require an employee to provide or pay for his or her own PPE, unless the PPE is excepted by paragraphs (h)(2) through (h)(5) of this section.
1910.132(h)(7) This paragraph (h) shall become effective on February 13, 2008. Employers must implement the PPE payment requirements no later than May 15, 2008.
Note to § 1910.132(h): When the provisions of another OSHA standard specify whether or not the employer must pay for specific equipment, the payment provisions of that standard shall prevail.
Payment for PPE
What is a Flash Fire?
A flash fire is a fire that spreads rapidly through a diffused fuel, such as hydrocarbon liquids or gas, without the production of damaging pressure.
OSHA, The US Oil patch & FRC
PPE Selection
• Based on the task performed
• Based on hazards present
• Physical state – gas, liquid, solid
• Concentration
Where do I get this information?
• Material Safety Data Sheet?– List of constituents and composition– “Wear gloves.” “Wear respiratory protection.”
• Websites – Ansell Edmont (glove example); 3M respiratory protection
• Take field measurements of concentrations
Example
SOURCE OF EXPOSURE / ACTIVITYCondensate, NGL, Produced Water, Rich Glycol
Tank cleaning, piping replacement, gauging
HAZARD["Skin" denotes hazards that can be absorbed through the skin.]
Benzene [Skin](0.5 ppm BP 8-hr TWA, 2.5 ppm BP STEL; 1 ppm OSHA 8-hr TWA, 5
ppm STEL1910.1028)
CONCENTRATION / ROUTE OF ENTRY Less than 0.5ppm
0.5 - 50.0ppm
Greater than 50.0ppm
Clothing / gloves
CONTROL MEASURES1910.134(d)(3)(i)(A) Assigned Protection Factor: Full facepiece air purifying - 50
No respiratory protection required.
Full-facepiece respirator + organic
vapor cartridge
Supplied air respirator/SCBA
Nitrile, viton, neoprene
gloves
Task: Operating mountain mover (MM), transfer belt (TB) and blender truck (BT)
Mountain mover and transfer belt not operating
Mountain mover and transfer belt moving sand to blender truck. MM and BT truck operators wore N-95 filtering face piece respirators.
Blender truck
operator Transfer belt
Mountain mover
MM oper.
station
Task: refilling mountain mover with frac sand
• Hose connections from sand refill truck are made on both sides of mountain mover (MM); pressurization of MM causes fine dust to escape from MM
As opposite sides of MM are being refilledwith frac sand, fine dust is released from filling nozzles
Mountain mover
Sand truck
fill nozzles
Task: operation of equipment pump trucks
• Diesel engines
Midday: diesel particulatesnot highly visible despite multiple operating engines
Early a.m. diesel emission cloud visible above work area due to Tyndall effect from stationary lighting sources
Task: Chemical truck operator
• Chemicals contained in plastic carboys, direct connections made to blender truck via mixing manifold. Workers well protected, dermal, respiratory protection used appropriately, work operations occur in open area.
NIOSH Frac Study
• October 20-21, 2009 - field site visit BP location - McAlester, OK
• September, 2010 – field site visit – Encinal, TX
• Chemical/work task observations for development of exposure assessment sampling strategy – Silica – 40/70 frac sand transferred from Mountain Movers via
transfer belt to blender truck – Diesel particulate – generated from use of motive power (14
diesel engines pumper trucks) used to pressurize well fracturing fluids.
– Chemicals – review of MSDS’s, observation of use & handling of chemical products used in well fracturing operations
A.3.3.16 Definition: Flash Fire. A flash fire requires an ignition source and a
hydrocarbon or an atmosphere containing combustible, finely divided particles (e.g., coal dust or grain) having a concentration greater than the lower explosive limit of the chemical.
Both hydrocarbon and dust flash fires generate temperatures from 538°C to 1038°C (1000°F to 1900°F).
NFPA 2113-07-FRC
The intensity of a flash fire depends on the size of the gas or vapor cloud. When ignited, the flame front expands outward in the form of a fireball.
The resulting effect of the fireball’s energy with respect to radiant heat significantly enlarges the hazard areas around the gas released.
Additional information describing flash fires is provided in Assessing Flame-resistant Clothing Use, CMA Manager’s Guide.
NFPA 2113-07-FRC
NFPA 2113-07-FRC
Chapter 4 : Selection4.1 General. The organization’s selection process
for flame resistant garments shall be based on the following:
(1) The conduct of a hazard assessment of the workplace to determine the need for the wearing of flame-resistant garments
(2) An evaluation of flame-resistant garment designs and characteristics to determine the type of flame-resistant garments suitable for protecting workers from flash fire
(3) The development of specifications for purchasing flame resistant garments
NFPA 2113-07-FRC
4.2* Workplace Hazard Assessment.
4.2.1 The organization shall conduct a hazard assessment of the work environment to determine the requirement for wearing flame-resistant garments.
NFPA 2113-07-FRC
4.2.2 The hazard assessment shall be performed based on a review of the facility to determine if flammable materials are present in quantities that will generate a flash fire and endanger a person.(3) The potential for the task being performed to increase the possibility of a flammable release; this could result from a mechanical failure such as a line breaking.(4) Operating conditions of the process — that is, potential for flammable fumes or vapors, and so forth.
(5) The presence of engineering controls designed to reduce exposure to flammable materials present during normal operations
(6) Accident history
(7) Means and duration of egress within potential exposure zone (e.g., location and distance to exits, potential congestion, elevated or restricted areas, connections to lifelines/ fall protection, capability of workers to escape, etc.)
NFPA 2113-07-FRC
NFPA 2113-07-FRC
4.2.3* The general workplace hazard assessment process shall include consideration of the following:(1) Determination of the type of hazard or hazards present in the workplace and the potential magnitude and duration of the hazard(2) Determination of the adverse effects of unprotected exposure to the hazards identified(3) Determination of whether other control options (engineering, administrative, and so forth) can be used instead of flame-resistant garments
(4) Determination of garment performance characteristics needed for protection.
(5) Determination of the need for garment decontamination where applicable.
(6) Determination of ergonomic constraints of work to be performed while wearing the garment.
(7) Comparison of risks and costs of all options.
(8) Implementation of selected option (s)
NFPA 2113-07-FRC
NFPA 2113-07-FRC4.2.4 A specific evaluation of the work environment to determine the requirement for the wearing of flame-resistant garments shall be based on the potential hazards that workers are exposed to as part of their work duties.
4.2.5 Factors in determining if flame-resistant garments are required shall include, but not be limited to, the following:(1) Proximity of the work to be performed to a hazard presenting a flash fire potential(2) The presence of flammable materials in the environment during process operations(3) The potential for the task being performed to increase the possibility of a flammable release; this could resultfrom a mechanical failure such as a line breaking
NFPA 2113-07-FRC
4.2.5 (continued)(4) Operating conditions of the process — that is, potential for flammable fumes or vapors, and so forth(5) The presence of engineering controls designed to reduce exposure to flammable materials present during normal operations(6) Accident history(7) Means and duration of egress within potential exposure zone (e.g., location and distance to exits, potential congestion, elevated or restricted areas, connections to lifelines/ fall protection, capability of workers to escape, etc.)
NFPA 2113-07-FRC
4.2.6* The initial review of a facility shall determine if flammable materials are present in quantities necessary to generate a flash fire and endanger a person.
NFPA 2113-07-FRC
4.3* Selection of Flame-Resistant Garments.
4.3.1 In addition to flame-resistant garments complying with NFPA 2112, Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, the organization shall consider factors in selecting flame-resistant garments
