Here is an editorial from Pete Sandel (AESC Safety and Membership) regarding the new OSHA guidelines for the use or non-use of fire retardant or flame-resistant clothing.
The opinion piece can be found here.
Now that OSHA has issued their clarification regarding citing employers for the use or non-use of fire retardant or flame-resistant clothing (for the purpose of this article the acronym “FRC” will be used for both) there are several issues we need to be aware of or to review as the enforcement moves forward. Let me first say that I view this issue very much like I do the recent health care reform bill. I fully support the need for, and use of, FRC in appropriate situations just as I support the need for and implementation of health care reform. However, in both cases we got far more than was needed with expensive mandates that don’t necessarily fix or address the real problems. That said, FRC is officially required by OSHA in every situation where the potential for a flash-fire hazard exists.
Due to the nature of oil and gas servicing operations, we perform the majority of our work in a potentially hazardous flash-fire environment. Typically as noted by OSHA, “there is lower potential for flash-fires during rig up procedures and during drilling operations that have not reached gas and hydro-producing zones.” In our work it can be assumed that almost everything between rig up and rig down would have the crew in a potentially hazardous flash-fire environment. For most trucking operations, rig up and rig down would be included as the operators are making up connections (and the like), prior to starting the job. The point I am making is that, in my opinion, a well servicing, oilfield trucking or wireline company will be required by OSHA’s standard to have the majority of their well site employees suited up in FRC for some part of all work performed at the well site.
In actuality, compliance of providing and requiring employees to wear FRC is the simplest part of this standard. You simply buy the product and require them to wear it at the appropriate times during a job. What I see as the difficult parts to comply with, involve the additional citation guidance listed below:
• 29 CFR 1910.132(b) – a failure to assure that employee-owned FRC is properly maintained and sanitary.
• 29 CFR 1910.132(c) – employer fails to provide FRC that is of safe design and construction for work being performed.
• 29 CFR 1910.1329(d) – employer fails to conduct a hazard assessment to identify the potential for burn hazards where employees have occupational exposure to flash-fires. Compliance with this or any other safety standard, while certainly an important issue, is really secondary to what we as employers are trying to achieve with safety programs and providing personal protective equipment (PPE) to our employees. We want to give them a safe work environment with the most protection available to ensure they remain safe during the course of a job. At the same time, we need to be aware of any additional hazards that may be created when we offer a solution to minimize any hazard — in this case FRC.
From personal experience, as well as talking with other contractors, I see valid areas of concern with requiring the use of FRC during some phase of most of the work we perform and for employers that are embarking on their first FRC required use programs. Some of the primary concerns are:
1. FRC getting oil/produced water soaked, as in pulling wet strings
2. FRC being worn too long (before changing out), which allows an accumulation oil products
3. FRC of the best fabric for the type of flash-fires employees are subject to encounter
4. Care and maintenance of the FRC and durability of the fabric after being exposed to oil and gas products
5. FRC being worn in high temperature environment
I have had personal experience with flash-fires and the resulting injuries. I had FRC in use at the time and it saved one individuals life, but he still had long-term facial and hand burns. After that incident I required full-hooded face protection as well. I mention this simply to let readers know I believe in and support the proper use of appropriately manufactured and maintained FRC. I also wore a Nomex flight suit for a number of years, so I am keenly familiar with the personal use of FRC.
All employers who undertake FRC programs need to be very aware that successful implementation goes far beyond just buying FRC, giving it to your employees to wear and then assume that all is well. To sum up your responsibilities (in my words):
1. Perform an assessment for the potential of a flash-fire hazard for each job.
2. Ensure you purchase the correct FRC for the type of work being performed
3. Establish a method to inspect all FRC (employee-owned as well) on a regular basis to ensure it is not worn, frayed, torn or oil soaked, etc.
4. Regularly replace and dispose of damaged and worn FRC.
5. Enforce the use of the FRC in all appropriate situations.
6. Be aware that during the summer, there is a tendency for employees to not wear FRC due to high temperatures.
One other note — there will be more to come from OSHA regarding enforcement of the hazard assessment issue — they are in the process of doing a comprehensive enforcement directive to assist them in their citation guidance in this area.
Think safe, work safe, be safe!