OSHA's Flame-Resistant Clothing Policy - ASSE Members

A TECHNICAL PUBLICATIONOF ASSE’S OIL AND GASPRACTICE SPECIALTYWeIIInformedVOLUME 3 • NUMBER 1DPAGE 8INTERVIEWRick IngramBackgroundon STEPSDPAGE 10ERGONOMICSImportance ofErgonomics inthe Oil & GasIndustryOSHA’sFlame-ResistantClothing PolicyBroader Implications for Safety ProfessionalsDDPAGE 14ASTMSTANDARDSOil SpillCleanup& ToxicityPAGE 26NORAOil & GasExtractionCouncilBY CHRISTOPHER S. CLASEN, CSP, CFI, CEMOn Aug. 12, 2010, OSHApublished a news releaseindicating, “BPProducts North AmericaInc. will pay a fullpenalty of $50.6 million stemmingfrom the 2005 explosion at its TexasCity, TX, refinery that killed 15workers and injured 170 others.”Although the Texas City BritishPetroleum (BP) incident precedes theDeep Water Horizon offshore explosion,considering the demand forThe role of thesafety professionalin guiding employersto a successfuloutcome to preventrisk becomesless clear if theexperts for specificindustry segmentsbecome those whowrite and enforcethe rules.clean energy (Figure 1, p. 20), thereseems to be little doubt that the energyindustry has become a currentevent on the minds of American society(American Petroleum Institute,2011).ENFORCEMENT EMPHASISSafety in particular is no longer inthe backseat of our minds; events of9/11 demonstrated the need forhomeland security, Hurricane Kacontinuedon page 201Well Informed www.asse.org 2011For a completeTable of Contents,see page 3Thanks to our sponsor

C O N T E N T SPAGE 2PAGE 8VOLUME 3 • NUMBER 1THE NEXT 100 YEARSBy George PearsonA message from George Pearson, vice president of ASSE’sCouncil on Practices and Standards.INSIDE LOOK AT STEPS NETWORKRick Ingram, co-founder of the South Texas Exploration andProduction Safety (STEPS) Network and chair of the NationalSTEPS Network ad hoc committee, provides background onSTEPS, discusses the organization’s goals and objectives andexplains STEPS’ current initiatives to reduce injuries and fatalitiesin the oil and gas industry.PAGE 10 IMPORTANCE OF ERGONOMICSIN THE OIL &GAS INDUSTRYBy Cynthia L. Roth & Henry RomeroIn the oil and gas industry, ergonomics can well be the missingpiece in a plant’s safety program that can provide significantreturn on investment.DPAGE 25NEW SAFETY VIDEOON ONE-YEARANNIVERSARY OFKLEEN ENERGYThe U.S. Chemical Safety Board hasreleased a newsafety videodepicting twomajor accidentscaused by theintentional releaseof flammable fuelgas near workareas, one year after the Kleen Energyexplosion.DPAGE 26NORA NATIONALOIL &GASEXTRACTION COUNCILAn outline of the National OccupationalResearch Agenda Oil and Gas ExtractionCouncil’s activities.PAGE 14 MOPPING UPBy Adele BassettThe enduring economic and environmental consequences of theDeepwater Horizon spill in the Gulf of Mexico demonstrated thecrucial significance of the standards developed over the past 35years by ASTM International Committee F20.PAGE 24 LETTER FROM DAVID MICHAELSTO NATURAL GAS POWERPLANT OPERATORSLetter from Assistant Secretary of Labor David Michaels to naturalgas power plant operators.CONNECTION KEYClick on these icons for immediate access or bonus informationV W P L AD DVideo Website PDF Hot Link Ad Link Direct Link3Well Informed www.asse.org 2011

ANNOUNCEMENTSWelcome New Members!We want to thank everyone who has remained a loyal member of the Oil & Gas Practice Specialty (OGPS)and welcome the following members who recently joined. We are currently at 1,180 members and growing.If you have any colleagues who might be interested in joining OGPS, please contact Krista Sonneson torequest an information packet. If you know anyone who might be interested in joining ASSE, please contactcustomer service for an information packet.•Regi Abraham, Sinopec International PetroleumServices Corp.•Magnus Adetula, Nigerian NationalPetroleum Corp. NNPC•Hope Adjenughure•Ebimieowei Alabrah, Shell PetroleumDevelopment Nigeria Ltd.•Mohamed Ammar, Rashid Petroleum Co.•Florante Andrion, Team Sual Corp. TeamEnergy Phils•James Anyanwu, Shell PetroleumDevelopment Company•Rhonda Askew•Itohowo Awak, Delta Afrik Engineering Ltd•Ahmed Ayanleke•Tammy Ballarin•Theophilus Banigo•Cloys Bayless, Catalyst Safety Consulting Inc.•Mohammad Bekhrad•David Bell, BJ Services•Jackoby Bertot•Dennis Bishop•Geoffrey Blansett•Bernadette Bonnivier, Baker Hughes•Thambidurai Bose•Mike Boswell•Jenny Bradshaw•Shawn Brazeal•Albenis Brinez Sima•Scott Britain•Josef Britt, BP America•Seth Brown•Jason Brubaker•Daniel Cain•Charles Campbell, Afterburner Inc.•Jimmy Carlile, Fasken Oil & Ranch Ltd•Juan Chiquillo, Geoespectro SAS•Kingsley Chuckwujindu, Shell PetroleumDevelopment Co.•Steven Clegg•Ujah Clettus, Shell Petroleum DevelopmentCo. Nigeria•Spencer Colbert, Superior Energy Services•David Conklin, El Paso Exploration &Production Corp.•Rey Cordial•Jeremy Cortez, Holloman Corp.•Maria Coruzzi, Linde Process Plants Inc.•Beverly Cox, Conoco Phillips Co.•Craig Crockett•Matt Curran•James Dark•Josepha DeLeon, Chevron Corp. Vacuum FMT•Joseph Dufford, CB&I Inc.•Roland Duldulao, Thomassen Services& Contracting Co. LLC•John Dunn•Ejabena Eric•Kristi Evans•Mallory Faazle•Nosa Falegon•Dimitrios Feggaros•Larry Ferguson, Holloman Corp.•Joseph Fess•Jason Findley, Walter Mortensen Insurance•Antonio Flores, Flores EHS LLC•Aaron Folsom•Symon Foster•Chris Fotos•Christina Fryant•Corey Galjour, C-Port LLC•Wilbert Gardner•Jeremy George, Devon Energy•Elila Gift•Kevin Gilman•Waleed Gomaa, Weatherford•Ramon Gomez•Denise Gordon•April Grady, Novotus•Melynda Gray, Energy Services LLC•Robbie Green•Matthew Grimes, BP Husky Refinery•David Haggard•Bonnie Haltom, Dresser-Rand Co.•Steve Ham•Marlon Harding•Ben Harper, Transcanada•Samuel Hoskin, Kinder Morgan Co2•Jared Huggins•Ljaz Hussain, Branch of SINOPEC•Michael Hyman•Richard Israel•Tommy James•Casey Jones•Trent Junga, Marathon Petroleum Company•Pamela Keesbery•Larry Kelley•Christopher Kennedy, Veolia ES Industrial•Robert King•Brice Koprivnak4Well Informed www.asse.org 2011

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•Bryan Krugma, Aera Energy•Drew Laughlin, Marsh Creek LLC•Joel Leblanc, USA Compression•Dwayne Lejeune•James Lewandowski•Russell Lichty•Rickey Lindsey•D. Landon Link, Enogex•Arnold Logan, Saudi Aramco•Albert Lopez, JD Rush•Lindsay Magdaleno, Plains Exploration& Production Co.•Bright Maya•Nicholas McCormic, AGI Industries Inc.•Joanna McDonald, Chevron Australia•Daniel McEntee, Universal Well Services•Michael McKenna•Preeti Mehta, Shell Oil Co.•Jon Meysing, Baker Hughes•Jason Millenbruch•Brent Miller•Nancy Mota•Chris Mouton, Intracoastal Liquid Mud Inc.•Kashif Mubashir•Christian Navarro, COSAPI Engineering& Construction•John Neeley, Valero Engergy Corp.•Andrew Nelson•Jude Ofulue, Nigerian Institute of SafetyProfessionals•Peter Ojevwe, Shell Petroleum Development Co.•Brownson Okereke, Nigerian National PetroleumCo. Ltd.•Bolaji Olarewaju•Saheed Olawale, Italian Style Qatar WLL•Tawheed Olayiwola, Shell PetroleumDevelopment Co.•Olusola Olusuyi•Adeniyi Omolola, National Engineering &Technical Co.•Kenneth Onogwu, Nigerian NationalPetroleum Corp.•Adnane Ouakedi, Ch2m Hill Veco Engineering•Rene Oubre, Baker Hughes•Marycela Padgett•Nick Peightal•Melissa Perkins•Robert Pickering, REP Safety Consulting LLC•Jeffrey Pinkton•Garnett Pizarchik•Bethicia Prasek, M-I SWACO, A Schlumberger Co.•Ogaganefe Raphael•Willis “Chip” Rich, Marathon Oil Company•John Rich•Marina Robertson•Grant Ross, Northwest Companies•Eric Roth•Mark Ruder•Oscar Schot, Flour•Sinayah Segaran•Usman Segun•Mr. Shahedin, Branch of Sinopec InternationalPetroleum Service Corp.•Don Sheets, Aztec Well Family of Companies•Adrian Sierra•Melvin Sinquefield•Leo Skiba•Brandon Smith, Holloman Corp.•Shanna Smith, Sandridge Energy Inc.•George Snodgrass, Alpine Meadow Inc.•Michael Soltis, TETRA Technologies Inc.•Bradley Spratt•Keith Stephenson, Valero Energy Corp.•Thomas Stewart•Graham Stirman•Richard Suter•David Swader•Lonnie Terrell•Jubril Thomas•Lasey Thompson•Lance Thornton•Glenn Tiania•Chuka Udeze•Stephen Udezi, Fenog Nigeria Ltd.•Larry Umukoro, Shell Petroleum DevelopmentCo. Nigeria Ltd.•Samuel Uwoghiren•Ekpen Uwubanmwen•Taram Wan Abdullah, Takusnab Nakaysia Ltd.•Angela Ward, Great White Directional Services•Lou Weaver, Belltech•Dallas Weems, Crosstex Energy Services•Michael West, BP America•Lee’O Whisenant•Phillip White•Travis Williams•Jeremy Wilson•Doug Wollum, Shell Canada Energy•Daniel York, Paramount Petroleum•Dewey Youngermann•Cai Zheng Wei, Sinopec Service Saudi Branch 6Well Informed www.asse.org 2011

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INTERVIEWInside Look at STEPS NetworkRICK INGRAM IS A CO-FOUNDER OF THE SOUTH TEXAS EXPLORATION ANDPRODUCTION SAFETY (STEPS) NETWORK AND CHAIR OF THE NATIONALSTEPS NETWORK AD HOC COMMITTEE.In this interview, Ingram provides background on STEPS, discusses the organization’sgoals and objectives and explains STEPS’ current initiatives to reduce injuries and fatalitiesin the oil and gas industry.WI: Please providea briefdescriptionofyour professionalbackground andof your role withthe STEPSNetwork.RI: I amemployed by BPNorth AmericaGas Division asthe OSHA VoluntaryProtectionPrograms (VPP)RICK INGRAMcoordinator. I haveworked in the oil and gas upstreamindustry in various roles since 1978. Iam a co-founder of the STEPS Networkand SafeLandUSA, as well as theNational STEPS Network. I serve as anOSHA Special Government Employee,and am as a member of the NIOSHNORA subcommittee for Oil and GasExtraction.OSHA’s Corpus Christi Area Officereached out to the oil and gas explorationand production, or upstream,industry 8 years ago through the localASSE chapter in response to a high rateof fatalities and serious injuries in theirSouth Texas Region. OSHA, along withindustry leaders, associations, educatorsand other regulators, subsequentlyfounded the original STEPS Network inSeptember 2003 in a cooperative effortto better understand issues behind highincident rates, and to work toward solutions.The team worked to understandhow best to serve the industry, whycompanies would join the organizationas well as what would keep peopleaway.The team understood that companiesneeding assistance could leastafford it. Key decisions made were notto charge fees for membership ormeetings, and not to allow sales pitchesby speakers. Many hours werededicated to developing a simple buteffective charter and bylaws withpossible future expansion in mind.Those early decisions have provensound, as the organization has nowgrown into the National STEPS (ServiceTransmission Exploration andProduction Safety) Network, comprisedof twelve independent regionalorganizations serving 14 states withmore in development.WI: How does STEPS promoteoccupational safety and health withinthe U.S. oil and gas industry?RI: STEPS has effectively bridgeda gap in communication between operatingcompanies, contract partners,industry associations, regulators andeducators that did not exist previously.Each individual organization and associationhas a niche group of members.What we have been able to do, especiallywith the help of OSHA as a partner,is to bring the industry togetherunder one umbrella and to establish acommunication network with a broadreach. As the network has grown, sohas health and safety awareness. Localor regional issues are shared across theU.S., while issues and initiatives thatcould affect the entire industry areshared so that regional or local groupsare not continually reinventing thewheel. Members have gained a betterunderstanding of how OSHA standardsapply to our industry, and OSHA officialsin turn have gained a much morepractical understanding of our industry.Working as one industry team has createdsolidarity among peers for fundamentalhealth and safety excellence, byfocusing our collective resources andefforts on one industry segment.WI: What are the greatest safety,health and environmental (SH&E)hazards currently facing workers inthe oil and gas industry, and how isSTEPS addressing them?RI: Like many others, ours is aninherently dangerous industry withmany hazards. Driving, lifting, droppedobjects, working at heights, large heavymovingmachinery, excavation, chemicals,the stresses of extreme heat in thesummer and extreme cold in the winter,flammable gas and liquids under highpressure, and various industrial hygieneissues are a few of the challenges facedeach day. During our meetings, wemaintain a broad perspective, but wealso concentrate on specific themeswhen needed.A key tool used to prevent recurrenceof incidents is to share lessonslearned from various incidents andinvestigations with our members.OSHA provides an updated statisticalreport each month, and members participatein roundtable discussions.Educators provide classes at a reducedcost or at no cost in conjunction withsome meetings, while pertinent technicalinformation is shared by variousassociations, such as the InternationalAssociation of Drilling Contractors,Association of Energy Service Companies,American Petroleum Institute,ASSE, U.S. Border Patrol, the FederalBureau of Investigation and variousguest speakers and member experts.WI: How does STEPS stay informedof urgent issues as well as changinglaws and regulations that affect thoseworking in the oil and gas industry?RI: STEPS Network members are8Well Informed www.asse.org 2011

arguably some of the best informed individuals in industry.The National STEPS Network uses e-mail, monthly meetingsand our regional and national websites as communicationresources. Through our close association with OSHA,other regulators and industry associations, including stateand regional oil and gas associations, we stay appraised ofchanges as they are proposed and implemented. In manycases, our members participate in the process as industryexperts, periodically sharing progress toward proposedchanges with their network peers. When changes are madeto regulatory rules or industry hazards are identified, ourmembers are notified immediately by e-mail or duringmonthly meetings.WI: What challenges has STEPS faced, and how did itovercome them?RI: Our industry is separated by lease and county andstate lines, by basins and by corporations. Ensuring that ourworkers return home safely is best achieved by workingtogether, exchanging ideas and best practices. Safety is discussed,but unfortunately, it is not taken as seriously bysome companies or individuals as it has been by others.However, we are seeing a decrease in incidents in many ofthe regions we serve.Inviting OSHA to work with our industry was a majorchallenge to some. A wise person once stated that perceptionis reality. Partnering with a regulator was a foreignconcept to many in our industry and remains so in someregions of the country. The perception of OSHA and industryat opposite ends of a tug of war is rapidly changing,however, due to the dedication and hard work of our OSHAand industry volunteers.Like any volunteer organization, keeping interest istough, but the effort is worth it. We use surveys and feedbacksessions to obtain new ideas from our members andnetwork with other organizations to find interesting guestspeakers. It is rewarding when some of the smaller independentcompanies walk into a meeting, and it is even betterwhen they return the next month and get involved with agroup. We still have much work before us, but we continuallyseek to improve and learn.WI: In what ways is STEPS expanding nationally?RI: To date we have twelve regional networks servingfourteen states, with around 1,000 companies and morethan 3,500 individual members, and growing.A primary education initiative born from the STEPSNetwork is SafeLandUSA, a high-quality basic health andsafety orientation developed by our industry for our industry.This effort is gaining momentum and provides a solidfoundation of knowledge for our entry-level workforce aswell as for industry veterans. SafeLandUSA includes anational database and photo ID system and is a natural progressiontoward consistency and standardization. To date,more than 175,000 SafeLandUSA ID cards have beenissued to workers.The National STEPS Network is being developed to providea communication hub for the industry. The nationalorganization supports the existing regional groups and assistswith the development of new ones. Our goal is to eventuallyserve all oil and gas producing regions in the U.S. At the timeof this writing, we are currently working with OSHA inArkansas, West Virginia, Pennsylvania and other states toexpand the network.WI: In what ways does STEPS partner with governmentagencies?RI: A founding principal of the network is to partnerwith OSHA, which has been formalized through OSHAAlliances. Nearly all of these organizations have signed formalalliances with OSHA. The Alliance program is a naturalprogression in the working relationship and has provento add value, credibility and sustainability. Please seeAlliances for descriptions and listings. Our primary contactsare OSHA Compliance Assistance Specialists, but in manycases, Area Directors, Assistant Area Directors and evenregional staff and Regional Administrators are directlyinvolved. Many of our leaders assist with regional safetyconferences in partnership with OSHA.One primary example is the biannual Region 6 OSHASafety Conference for Oil and Gas E&P, which had an attendanceof more than 1,200 in 2010. Many also serve on theNIOSH NORA committee for oil and gas extraction amongother endeavors, and agency employees are welcome to speakor teach at various monthly meetings. We continue to searchfor meaningful ways to work with others, including governmentagencies, and are always open to suggestion.WI: What do you consider to be STEPS’ most notableaccomplishment?RI: The STEPS Network is an all-volunteer organization.Our dedicated volunteers take time from their busylives and careers to help plan new networks, speak at kickoffmeetings and serve on committees because they believethat helping to raise awareness within the industry to saveworkers from serious incidents is worth the effort.Before the network, we did not know each other. We wereliterally working in circles, trying to accomplish the samethings. Now we are a united group of friends with a commongoal. We have effectively erased the lines of corporate divisionsthat kept us apart. Most importantly and most rewardingis that we have seen fatality and serous incident rates drop inregions where we have active networks, but we all believe ourmost notable accomplishments are yet to come.WI: What are STEPS’ goals and objectives for theremainder of the year?We continue to explore opportunities for improvement andexpansion both at the regional and national levels. We continueto strive to improve our websites, and we are planning ourthird annual national conference in December 2011.Our volunteers are fond of saying that they receive muchmore than they give. We urge the readers of this interviewto consider donating a bit of time to a worthy cause if youare not already doing so.If you would like to become involved in STEPS, or Safe-LandUSA, or would like additional information, click here,or contact any of the National STEPS Network officers:Chair: Rick IngramCo-Chair: Jerry JacobsCo-Chair: Joyce RyelOSHA Advisor: Marianne McGee 9Well Informed www.asse.org 2011

ERGONOMICSBY CYNTHIA L. ROTH &HENRY ROMERO, PH.D., CPE, CSPImportance of Ergonomicsin the Oil & Gas IndustryThe oil and gas industry has experienced manyyears of growth and change. One of thechanges has been an emphasis on the safety andhealth of direct employees and subcontractorsworking onshore and offshore to the point ofdemanding an injury- and incident-free environment.Many realizations have been made in regard to achievingthis goal, but the most dramatic has been the understandingof the contribution of ergonomics or human factorsnot only to achieving the goal of injury- and incidentfree,but also to reducing the overall lifecycle costs ofoperating an oil and gas facility.A look at some recent injury statistics in one region ofthe world demonstrates that incident types addressed byergonomics (overexertion, bodily reaction and most falls)are a major source of incidents and musculoskeletal disordersare a major source of injury types.Some incidents also highlight the need for considerationof ergonomics in reducing human error.Table 1Top 5 Incident Types (2000-04)From Worksafe, BCTable 2Top 5 Nature of Injury Types(2000-04) From Worksafe, BCWHAT IS ERGONOMICS?Ergonomics (or human factors) is the scientific disciplineconcerned with the understanding of interactionsamong humans and other elements of a system and theprofession that applies theory, principles, data and methodsto design to optimize human well-being and overallsystem performance (IEA, 2000). Ergonomics promotesa holistic approach in which considerations of physical,cognitive, social, organizational, environmental and otherrelevant factors are taken into account.Physical ergonomics is concerned with humananatomical, anthropometric, physiological and biomechanicalcharacteristics as they relate to physical activity.Examples include physical access to valves, design ofstairs and walkways, planning manual handling tasks andoptimization of the working environment.Cognitive ergonomics is concerned with mentalprocesses, such as perception, memory, reasoning andmotor response, as they affect interactions amonghumans and other elements of a system.Examples include the design of graphicaluser interfaces in control rooms and fieldequipment rooms.Organizational ergonomics is concernedwith the optimization of sociotechnicalsystems, including their organizationalstructures, policies and processes. Examplesinclude human actions during abnormalsituations, emergency egress planning andcontrol room communications.The design objectives for ergonomicsare:Operability. To ensure that all controlsand displays/instruments and other operatedmachinery can be reached, operatedand viewed effectively and safely by theexpected working population.Maintainability. To ensure that the needfor safe and efficient maintenance tasks hasbeen incorporated into the design.Access/Egress. To ensure that all areasof the plant and equipment can beaccessed and evacuated safely and efficientlyunder normal, adverse and emergencyconditions.Materials Handling. To ensure thatrequirements for lifting, pulling and pushingof equipment manually and mechani-10Well Informed www.asse.org 2011

cally have been considered bearing in mind the capabilitiesof the expected user population.Labeling/Communication. To ensure that equipmentidentification and communication of operational andmaintenance information have been addressed with theobjective of improving human performance and reducinghuman error.Environmental, To ensure that environmentalrequirements applicable to human performance, includingnoise, lighting, vibration, climatic conditions andproximity to hot, cold, hazardous and contaminatedequipment or areas, have been addressed.Constructability: To ensure the ease and safety ofconstruction operations.WHEN TO APPLY ERGONOMICSIt is important to recognize that ergonomics can beapplied any time during the lifecycle of the facility fromdesign or redesign through normal operations. However,the later in the lifecycle that ergonomics is applied, theless influence it will have on the safety and health of theemployees and the efficiency of the operations. Whenergonomics is applied after processes are designed and inplace, employees are exposed to risk factors. Conversely,the longer the implementation is delayed, the greater thecost often because of needing to remove the currentequipment and to replace it or make major equipmentmodifications. Therefore, whenever approaching a majorrevamp or new facility redesign, ergonomics needs to bea part of the design team to derive the greatest benefit.ERGONOMICS TOOLS &METHODSGenerally, ergonomists use tools, such as biomechanicalanalysis, task analysis, link analysis, human-computerinterface analysis, valve criticality analysis, humanreliability assessment, user testing and validation,HAZOPs, safety and operability reviews and engineeringdesign reviews, including 3D model reviews.Several areas in which ergonomists typically getinvolved in project design include:•stairs, ladders and work platform design;•crane cab design and crane operation;•equipment access and removal for maintenance;•vendor supplied equipment;•consoles, panels and workstations designs;•control room layout and DCS, SPDS, F&G andPAGA design;•living quarters design;•valve location and orientation;•labels and pipe marking;•escape, evacuation and rescue;•materials handling;•instructional material (procedures, manuals and jobaids);•personnel selection (competency profiles).Several areas in which ergonomists can assist existingfacilities include:Physical ergonomics is concerned withhuman anatomical, anthropometric, physiologicaland biomechanical characteristics asthey relate to physical activity. Examplesinclude physical access to valves, designof stairs and walkways, planning manualhandling tasks and optimization of theworking environment.•reducing the risk of manual materials handling;•improving tool designs;•reducing risk of hand-arm vibration;•improving working environments, including reducingrisks associated noise, thermal environments, ionizingradiation hazards, etc.;•reducing risks of poor postures by redesigning andrevamping equipment and changing work methods;•improving the ergonomics of administrativework areas.BENEFITS OF ERGONOMICSSeveral tangible and intangible benefits result fromimplementing ergonomics. These benefits have beendemonstrated over many years in many industries. Somespecific examples from the oil and gas industry include:•reduction in CAPEX = 0.25% to 5%;•reduction of design rework = 1% to 5% (less rework,less late changes);•reduction in operations and maintenance costs = 3%to 6% per year;•reduced turnaround times (up to 25% reduction);•reduced training times (up to 50% reduction);•improved emergency egress times;11Well Informed www.asse.org 2011

Table 3Incidents Highlightingthe Need for Considerationof Ergonomics•improved morale;•reduced musculoskeletal disorder rates.BARRIERS TO IMPLEMENTATIONIf the implementation of ergonomics can be so beneficialand mission-critical, why is it not yet whollyembraced in the oil and gas industry? There are ten barriersto the complete and consistent application ofergonomics.1) Lack of knowledge about ergonomics and itsbenefits. The science of ergonomics is really just beingunderstood and applied across the oil and gas industry,and some regions, clients and projects have yet to developthe technical skills needed.2) “We already do that” syndrome. Ergonomics issuch a part of every engineering discipline on a projectthat it is easy to say that it already is included. However,while piping designers may well design ladders andstairs, they might not be using the latest understanding ofbody size, human simulations and how people use stairsand ladders.3) “It is just common sense” syndrome. The solutionsengendered by ergonomists are often simple to seein hindsight, but the science behind ergonomics issophisticated, and understanding the system-wideimpacts and causes often involves very specialized skills.4) Perceived lack of time on projects. Often, projectsbuild in manhours for ergonomics work, like theydo with other engineering disciplines. Also, they tend tothink that the additional reviews and efforts will add tothe design time, when it often reduces it due to increasedquality and reduced rework.5) Apply it only as an audit check (“Just come doan audit or P&ID review”). Ergonomics must beapplied and treated as any other engineering discipline.It cannot be applied effectively in a spot fashion or byreview/audit due to its system-wide impact.6) Lack of readily available trained resources(“Can’t our other engineers do this?”). The best analogywould be to ask if civil engineers can do the work ofmechanical engineers. After all, they both learnedstrength of materials and statics. Ergonomists must workwith other disciplines to be effective, but they represent asignificant, separate skill set.7) Cultural (“It is simply not the way these thingsare designed”). This is similar to the statement, “Wehave never had an accident here, so why do I need towear my safety glasses?” We know the benefits; they areboth tangible and demonstrable. To overlook ergonomicsis to agree to develop a plant that does not optimize thesafety and efficiency of its operations.8) No readily known or recognized references(“Aviation, nuclear and military standards cannotapply here”). International (ISO) and regional standardsdealing specifically with ergonomics exist in the U.K.,U.S., Canada, Australia, Brazil, Argentina and severalother countries. Most of these refer to earlier work donein defense and aerospace industries, but they arenonetheless applicable.Abu Dhabi National Oil Company (ADNOC) hasestablished a code of practice known as OccupationalHealth and Risk Management—Ergonomic Factorswhich is testament to the fact that ADNOC has recognizedthe importance of ergonomics as an integral componentof SH&E policies and practices.ADNOC shareholders demand that guidelines areestablished to implement ergonomics in the workplaceso as to be on-par with the top 5% of the world’s leadingoil and gas industries and to be recognized as a worldclassorganization.9) Suppliers are not on board with this concept.Often this is true, but would oil and gas clients acceptsupplied package units that did not meet specified reliability,availability and maintainability requirements?Certainly not and therefore, suppliers have designed theirequipment to meet these client demands. The same willhappen regarding ergonomics in time if it is demandedof the suppliers.10) The cost to implement is too high. This one is12Well Informed www.asse.org 2011

the most difficult to address. The cost of not having anergonomics process in place is the most expensive wayto do business. Depending on the complexity of projectscope, the ergonomics effort amounts to 0.004% to0.09% of overall engineering manhour costs.While the benefits of ergonomics are tangible anddemonstrable, they are not commonly known. Also, theowner of the facility is generally not the constructor ordesigner. The constructor and designer are often judgedon whether they are the lowest-cost bidder and will dotheir best to keep the cost of design and construction aslow as possible to improve their profit margins.Yet, the owner must be concerned with the lifecyclecost of the plant, not just the cost of design and construction.Mistakes and redo work are costly. The greatesteconomic benefits of ergonomics is during operationsand maintenance of a facility versus design and therefore,the return on investment is skewed to the owner andaway from the designer who bears the initial cost of theergonomics implementation. A change needs to bewrought in how bids are evaluated as they apply to safetyand ergonomics.After the facility is designed and operating, operatorsand maintainers are often subcontractors and do not ownthe facility. Therefore, operators and maintainers havelimited control over the issues directly impacting thedevelopment of musculoskeletal disorders. Owners arestarting to demand an injury- and incident-free culture oftheir subcontractors, which will require teaming to applyergonomics and develop solutions.MAJOR OIL &GAS OWNER ERGONOMICS STANCESMany of the oil and gas companies have begun tostrongly embrace ergonomics both inside their plants andwithin their administrative areas. Royal Dutch Shell hasdeveloped several design engineering procedures coveringmany aspects of ergonomics that are required for use ontheir projects. Shell has adopted ergonomics as part of itscorporate health management guidelines. ChevronTexacois upgrading its Safety in Design manual to incorporateergonomics and now evaluates subcontractors on their abilityto perform in this area. It is a critical part of their incident-and injury-free corporate culture as well.BPAmoco currently does not have specific engineeringguidelines but has a highly developed understanding ofergonomics and demands its implementation on their projectsby their subcontractors. ExxonMobil has specificdemands regarding ergonomics and a sophisticatedunderstanding of the topic. Subcontractors are expectedto have expertise in this area. Certain regulators are lookingfor the implementation of ergonomics as they performas-built reviews.CONCLUSIONErgonomics is a valuable tool for the oil and gasindustry. It can well be the missing piece in a plant’ssafety program that can provide significant return oninvestment. It is far more effective to implement ergonomicsearly during the design or revamp of a facility,although it can be applied to a facility during any stageof its lifecycle.If a plant wants to achieve incident- and injury-freeperformance, ergonomics must be a large part of thateffort. Cynthia L. Roth is CEO of Ergonomics Technologies Corp.Henry Romero, Ph.D., CPE, CSP, is a senior consultant withPHS Concepts Inc.Oil & Gas PracticeSpecialty Resources*Mentoring Services•Members Only (click Mentor Contacts)•ASSE staffJob Search Assistance•Nexsteps•ASSE’s Career Resources LinkedIn site•Local ASSE chapterCareer Resources•Career Resource CenterNetworking•LinkedIn•Facebook•ASSE’s social media sitesTechnical Questions/Advice•24/7 online question submission form•OGPS Volunteer Advisory CommitteePublication Opportunities•Article submissions (earn COCs and win a cashprize if you are the top article)•Topic suggestions and interview requestsEducational Resources•OGPS website•SH&E Standards Digest•Special Issues & Best of the Best Publication•Key Issues publication•Interviews•Business of Safety Committee•Nanotechnology Support Site•WebinarsStandards•ANSI/ASSE SH&E Standards InformationCenter•New standards•ASSE’s Standards Development Committee*Click any of the bulleted items to accesslinked content.13Well Informed www.asse.org 2011

STANDARDSBY ADELE BASSETTMopping UpStandards for Oil Spill Cleanup & Toxicity AssessmentWorking in conjunctionwith boomsare skimmers, theotherworldly lookingequipment thatuses vacuums,disks, brushes andother devices toremove oil from thewater’s surface.It is a sad fact of life that it often takes a catastropheto spotlight a chronic issue. The Deepwater Horizonspill in the Gulf of Mexico was not the largest oilspill ever. That record is currently held by the 36 billiongallons [93 million m 3 ] that retreating Iraqi forcesuncorked when they left Kuwait in 1991 (Broder &Zeller, 2010). But, oil spills are far from rare.“Oil spills of 1,000 gallons [3.8 m 3 ] or so are actuallyroutine occurrences throughoutthe world,” says Mervin Fingas, anindependent consultant in Alberta,Canada, veteran member of ASTMInternational Committee F20 onHazardous Substances and Oil SpillResponse, and author of The Basicsof Oil Spill Cleanup. “Eight to ninespills occur daily in Canada, withabout 10 times that many happeningin the U.S.”The Deepwater spill was especiallydisconcerting because of its locationin the Gulf of Mexico (bothdeep undersea and far off the U.S.shore) and its nature (a continuous,rather than more readily controlledand contained one-point spill, such as a leaking tanker ora ruptured pipeline).THE ROLE OF STANDARDSThe enduring economic and environmental consequencesof the Gulf spill demonstrated the crucial significanceof the standards developed over the past 35 yearsby ASTM International Committee F20. According toPeter Lane, president of Applied Fabric Technologies inOrchard Park, NY, and F20 committee chair, nearly halfof the 56 standards overseen by the committee will comeinto play sooner or later, directly or indirectly.Since 1975, the oil producers, regulators, equipmentsuppliers and manufacturers who have written the standardsfor Committee F20 have not necessarily anticipatedthe political turmoil, extreme engineering challengesor human failure that have characterized more recent oilspills. But, their standards have grown to cover justabout every aspect of response from control, removaland treatment to in-situ burning, surveillance and tracking,shoreline measures and bioremediation.BOOMS &SKIMMERSAmong the more significant standards developed byCommittee F20 have been those related to booms, thelong, sausage-like devices that corral slicks during the initialstages of a spill. ASTM International standards F962,Specification for Oil Spill Response Boom Connection:Z-Connector, and F2438, Specification for Oil SpillResponse Boom Connection: Slide Connector, ensure thatcompliant booms link together, much like the perfect fit ofstandardized electrical plugs and wall sockets.Fingas, who chairs F20 subcommittees on in-situburning and remote sensing and detection, says, “It hastaken 20 years to align manufacturers to produce better,stronger booms that meet an industry standard and thatconnect together, no matter what their size and shape.”In the case of the Gulf spill, the crews in fishing boats,laying miles of booms, “may have been among the mosteffective control measures, catching oil in the initialstages of the spill and preventing it from coming toshore,” he says.Working in conjunction with booms are skimmers,the otherworldly looking equipment that uses vacuums,disks, brushes and other devices to remove oil from thewater’s surface. Committee F20 has developed a numberof standards related to equipment selection and testing,but a more recent standard, F2709, Test Method forDetermining Nameplate Recovery Rate of Stationary OilSkimmer Systems, holds manufacturers responsible foraccurately reporting the capabilities of their skimmers.The standard specifies the skimmer capacity that is actuallyneeded to clean up certain types of oil spills.14Well Informed www.asse.org 2011

DSTANDARDASTMCommitteeE47“Mechanical means of combating an oil spill—booms, skimmers and temporary storage facilities—canbe effective, weather permitting and provided they areoperated continuously,” explains Crickard.IN-SITU BURNINGThe Deepwater Horizon spill required other measuresduring initial response. In-situ burning involves corrallingconcentrated areas of oil within fireproof booms,moving the collected oil away from other cleanup operationsand setting fire to it. Early on, the U.S. CoastGuard conducted a series of small in-situ burns, clearingthe Gulf’s surface of some of the oil.“Previously, there were a lot of myths about what insituburning could accomplish,” says Fingas. ASTMF2152, Guide for In-Situ Burning of Spilled Oil: Fire-Resistant Boom, “was a landmark ASTM standard,where the standard was actually developed in conjunctionwith the creation and testing of an improved fireresistantboom.” The U.S. Coast Guard, U.S. MineralsManagement Service and Environment Canada, amongother groups, worked together, setting up a series of testbasins in Mobile, AL, to develop a superior productand ASTM International standards. Committee F20 isalso responsible for F1788, Guide for In-Situ Burning ofOil Spills on Water: Environmental and OperationalConsiderations. F1788 is designed to aid decision makersand spill responders in contingency planning, spillresponse and training.DISPERSANTSDispersants are yet another surface control measure;they are super-strength detergents, usually sprayed ontooil slicks from airplanes. Dispersants break down oilslicks into tiny droplets that are driven into the water columnand almost instantly turn into a cloud with morevolume than the initial slick. The cloud eventually disappearsas it is picked up by currents and dispersed into thevastness of the ocean. Over time, sunlight and microorganismsbiodegrade the oil. But, for dispersants to beeffective, conditions must be right—fresh and thick oil,plus some wave agitation to mix the oil and water.“Most oils are initially dispersible,” explains StevePotter, vice president of SL Ross Environmental ResearchLtd., Ontario, Canada. “The more they weatherand the more viscous they become, the more difficult itis for dispersants to act effectively.”According to Lane, the Deepwater Horizon spill triggeredone of the “first large-scale uses of dispersants,”certainly one of the first in the U.S.“ASTM has had a minor influence on the developmentof dispersants in that we have helped get rid ofbad concepts and helped design delivery systems,” saysFingas. For example, among other standards dealingwith dispersants is ASTM F1413, Guide for Oil SpillDispersant Application Equipment: Boom and NozzleSystems.SURVEILLANCE &TRACKINGWith the Deepwater Horizon slick at one point measuringmore than 80 miles [130 km] wide and more than140 miles [230 km] long, surveillance and tracking hasbeen especially crucial because what sometimes appearsto be a slick might not be (Mufson & Achenbach, 2010).“You have cloud shadows, features on the bottomand organic materials that can mimic oil,” says Lane,explaining the challenges of reporting and tracking spills.Also, adds Potter, “It is crucial that the parties involvedspeak the same language during large incidents.”That is where ASTM F1779, Practice for ReportingVisual Observations of Oil on Water, had come into play.“I had been e-mailing friends working at the spill, andthat standard was definitely used,” says Fingas. CommitteeF20 is also responsible for F2534, Guide forVisually Estimating Oil Spill Thickness on Water.SHORELINE MEASURES &BIOREMEDIATIONLater-stage response measures kick into action as oilspills spread. In heavier concentrations, oil can have atoxic, smothering effect. Depending on the situation, it issometimes effective to reduce concentration by addingnutrients or fertilizers. For wildlife, though, ingesting oil,while attempting to clean soiled fur or feathers, amountsto a death sentence.As oil hits land, says Crickard, “Cleanup operationsbecome very labor intensive, primarily using workerswith buckets and shovels to scoop oily mousse (brownwater emulsified oil) into trash bags.”ASTM F2464, Guide for Cleaning of Various OiledShorelines and Habitats, provides techniques for addressingand documenting shoreline cleanup activities in asystematic and consistent way.“The areas under greatest near-term threat from theDeepwater Horizon spill were marshes and delta forms,”says Potter. “If an area is lightly oiled, sometimes theproper choice is to not undertake a cleanup because itwill create more harm than good. If the area is heavilyoiled, you might use water streams to flush it and skimmersto pick up the oil.” In some cases, he says, the bestchoice is burning, a technique addressed by ASTMF2823, Guide for In-Situ Burning of Oil Spills inMarshes. “It may seem like a repugnant choice, but wetlandswill recover from that,” Potter says.Additionally, there are Committee F20 standardsrelated to bioremediation, which rely on oil-eatingmicrobes. Right now those standards are “very elementary,”according to Fingas. “They provide language andconcepts but little protocol for carrying out bioremediationtechniques.”ADSORBENTSAdsorbents are used in the final stages of an oil spillcleanup. Generally made from plastics, they pick upoil coming onto shore or, “as the paper towel of the oilspill business, provide the final polish,” says Fingas.15Well Informed www.asse.org 2011

ASTM F276, Test Method for Sorbent Performance ofAdsorbents, offers guidelines for what to use under whatcircumstances.CHALLENGES AHEADThe effectiveness of any cleanup operation depends onfickle weather and ocean currents, the properties of the oilinvolved and the success or failure of all the strategies usedto plug leaks and to stop the oil from flowing. If theDeepwater Horizon spill demonstrated the significance ofthe existing standards created by ASTM InternationalCommittee F20 on Hazardous Substances and Oil SpillResponse, then it also raised the question of what newstandards may be required to address spills at sites involvingextreme engineering and difficult access.“All of us in the community try to apply lessonslearned. We might be tweaking existing standards,” saysPotter. “We always reevaluate after any spill.”Fingas points to the issue of research funding.“Control agencies and research organizations do nothave the ability to do long-term meaningful research onspills and spill response. We are always fighting forfunding.”Potter agrees. “We need a less reactionary and morestable interest in oil spills,” he says. “Interest comes andgoes. The Deepwater Horizon spill showed the importanceof keeping at it. Otherwise, these things tend to falloff the radar.”On the standards development side, Lane expects thatCommittee F20 members may have new ideas for safetystandards, among others. And Crickard wants to hearfrom more producers, manufacturers, regulators and endusers. “The more people we have in the pool comprisingour committee, the more voices we will have to helpimprove our standards and to vastly improve our oil spillresponse system.” REFERENCESBroder, J.K. & Zeller, Jr., T. (2010, May 5). Gulf Oilspill is bad, but how bad? New York Times.Mufson, S. & Achenbach, J. (2010, May 17). BPsticks tube in leaking well. Washington Post.Adele Bassett is a freelance writer who has covered everythingfrom youth gangs in Colorado to earthquakes in Connecticutwhile working for a variety of corporations and publications. Sheholds a B.A. in English, an M.S. in journalism and an M.B.A.Reprinted, with permission, from ASTM Standardization News,Volume 38, No. 4, copyright ASTM International, 100 BarrHarbor Drive, West Conshohocken, PA 19428.The Future of Oil & GasASSE and the Oil & Gas Practice Specialty (OGPS)would like to thank Ashok Lenka, Eric Roth andDudley Plaisance for recently stepping up to volunteeron the OGPS Advisory Committee. Since we are amember-driven organization, volunteers determineour strength, opportunities and contributions to theindustry and safety community. Please join me in welcomingAshok, Eric and Dudley.If you would like to get more involved and workwith this great group of volunteers, click here formore information. WebinarsPlease join us on the upcoming webinars. Formore information, click the links below orvisit http://www.asse.org/education.Safety Leadership: The Final Hurdle TowardZero Oct. 5, 2011 11:00 AM-12:30 PM CDTA Framework of OSHA’s Proposed Injury &Illness Prevention Program (I2P2): Learning fromCal-OSHA’s Experience Nov. 9, 2011 11:00 AM-12:30 PM CDT. Best of the BestASSE and the Oil & GasPractice Specialty wouldlike to congratulate MeaganJohnson and Larry Johnson fortheir article, “ManagingGeneration X.” This article wasone of 17 articles selected forinclusion in the 2010-2011 Bestof the Best publication. Clickhere to view this compilationof technical material and visit http://www.asse.org/psfor more information or click here to add an additionalpractice specialty to your membership. 16Well Informed www.asse.org 2011

Safety 2011RecapIt is safe to say Safety 2011 was a huge success.There was record attendance and specialevents to celebrate ASSE’s 100th anniversary.The Oil & Gas Practice Specialty (OGPS) held itsannual face-to-face meeting and sponsoredtwo sessions plus a roundtable. OGPS volunteersalso helped answer questions at thePractice Specialties booth where free practicespecialties were raffled off, complimentarynewsletters were available for all 28 groupsand mouse pads were given out. Click here forour blog recap of what happened in Chicagoat our biggest and best conference yet! Clickhere to order CD or MP3 audio recordingsfrom Safety 2011 conference sessions. If youwere unable to make it to Safety 2011, pleasemark your calendar now for Safety 2012 inDenver, CO, June 3-6, 2012. 17Well Informed www.asse.org 2011

Heat Illness Can Be Prevented!Heat kills–get help right away!OSHA Heat Illness Fact Sheet18Well Informed www.asse.org 2011

COVER PAGEOSHA’s Flame-Resistant Clothing Policycontinued on page 1trina demonstrated the need for prompt federal actionand the recent BP disasters have demonstrated the needfor greater safety and environmental accountability. Inthe author’s opinion, an enforcement emphasis in the oiland gas industry is justified considering the risk of thisindustry segment to potentially cause serious injury anddeath to workers and significant environmental andfinancial losses to the surrounding community.OSHA has 13 national emphasis programs (NEPs),which include one NEP that intensifies the focus on theindustry through petroleum refinery process safety management(PSM), one proposed NEP on oil and gas drillingand several regional emphasis programs. The safety recordfor the oil and gas industry is flaring up, if not permanentlystained, and if you consider OSHA’s new direction forincreasing enforcement, the oil and gas industry is directlyin the crosshairs of OSHA’s emphasis. For more onOSHA’s enforcement trend, the reader should refer toNeuman’s (2011) article, “New OSHA Sheriff in Town,”in the January 2011 issue of Professional Safety.According to the Association of Energy ServiceCompanies, the industry is fighting a negative image,and even BP was reported to “toughen their safety culture”by adding a new CEO and by creating a “safetyand risk division,” but clearing the smoke may be a challenge(Maslowski, 2010; Engineering News Record,2010). One such challenge involves the potential implicationsof OSHA’s policy on flame-resistant clothing(FRC) announced in March 2010. This article discussestwo broad implications—one that directly affects the oiland gas industry, and a second more philosophical implicationas it relates to how safety professionals will identifyand control hazards in the future.Figure 1Future U.S. Energy DemandPPE ENFORCEMENTThe first implication affects the oil and gas industry.In March 2010, OSHA issued a memorandum as policy,which is intended to clarify enforcement for PPE under29 CFR 1910.132(a), which concerned the failure toprovide and use FRC in the oil and gas industry (Fairfax& Witt, 2010). The memorandum was apparently necessary,as the PPE standard was inconsistently used“among well drilling contractors, well servicing contractors,and oil and gas companies.” OSHA creates emphasisfor the policy by referencing a paper created by a taskgroup that reviewed upstream onshore oil and gas fatalitiesbetween 1997 and 2003, where it was found that16% of the fatalities occurring in the oilfield were relatedto fire and explosion or roughly five times the nationalaverage (Curlee, et al., 2005). The policy in summary is“(w)here FRC is not being used by workers in theseoperations, a citation under 29 CFR 1910.132(a) requiresevidence that . . . a reasonable person familiar with thecircumstances . . . would have recognized a hazardouscondition warranting the use of that equipment.”During an OSHA enforcement action, an employer’srebuttal for any reasonable person who would not be wearingFRC PPE would then be to provide evidence that theperson was unfamiliar with the circumstances. At firstglance, the policy seems clear enough, where for mostresponsible employers the likelihood of an untrained orunskilled person working under a hazardous condition,such as a flash fire, would be unlikely; however, in readingthe additional citation guidance, compliance safety andhealth officers (CSHOs) “shall cite 29 CFR 1910.132(a)for the failure to provide and ensure the use of FRC in oiland gas drilling, well servicing or production-related operationswhen there is a potential for flash fire hazards. . . .”The policy lists numerous activities for well drilling,servicing and operations, including tasks, such as drillinginto hydrocarbon zones, open hole work, startups, flowtesting, stimulating, cementing, working with the wellheadunder pressure and equipment maintenance. In fact,“(m)aintenance operations on production equipment” isoften a daily activity to ensure proper well operation, takemeasurements, collect data and make equipment adjustments.For those experienced in exploration and production,the policy covers essentially all well field operations.The implication of the policy for oil and gas companiesis, therefore, “workers must wear FRC,” whichbecomes a prima facie form of regulating this specificindustry through the policy.20Well Informed www.asse.org 2011IDENTIFYING &CONTROLLING FRC HAZARDSThe second implication affects safety professionals asto how they will identify and control FRC hazards in thefuture. Enforcement of FRC as stated in the March 2010memorandum for the oil and gas industry seems to bedifferent from an earlier OSHA interpretation for thepetrochemical industry dated March 7, 2006 for a scenarioinvolving PSM, where 4 years earlier, the OSHA

Directorate of Enforcement Programs informed theAshland Specialty Chemical Company that it could becited when “. . . the employer has not conducted a hazardassessment” to determine the need to use FRC.OSHA’s response to Ashland was supported by expertiseoffered from two recognized third-party organizations, onefrom the National Fire Protection Association (NFPA) andanother from the Center of Chemical Process Safety(CCPS) under The American Institute of Chemical Engineers(AIChE). In the much earlier Ashland FRC interpretation,OSHA states that enforcement of “(t)he specificstandards related to when industrial personnel must useflame-resistant garments/FRC are found in Chapter 4 (referringto Annex A of NFPA 2113) and include mandatoryrequirements for the selection process and a workplace hazardassessment.” Most safety professionals would agree thatthe Ashland interpretation is consistent with methods appliedby general industry (i.e., the use of a hazard assessment).In the Ashland FRC interpretation, OSHA refers guidancefrom CCPS (quoting OSHA), “. . . PPE is not a primarydefense against hazards. They state that directhazard control through engineering and administrativecontrols must come first. PPE is then used as a supplementalmeasure against hazards” (American Institute ofChemical Engineers, 1992).Both NFPA and AIChE offer methods produced by committeesand professionals that are technically sound andoften reflect participation from a wide cross-section ofindustry (e.g., manufacturer, employer/users, installer/maintainer, labor representatives, applied researchers/test labs,enforcing authority, insurers, consumers and special experts.).From these organizations and others, consensus standardsemerge, such as ANSI/API RP 754, “Process SafetyPerformance Indicators for the Refining and PetrochemicalIndustries,” which was issued in April 2010 in part as aresult of the U.S. Chemical Safety and Hazard InvestigationBoard investigation of the 2005 BP Texas City incident.The oil and gas industry is not only an active participantin such standards, but is often the leader in process safety.Numerous standards pertaining to safety and environmentalprotection exist through the American PetroleumInstitute (API). Hazard assessment is a standardized approachused to identify and control risk and is advocatedby not only the higher-risk industries to which OSHAenforcement efforts are directed, but also by internationallyrecognized consensus organizations (i.e., the subject matterexperts).OSHA continues to validate the hazard assessmentapproach where in the most recent interpretation onthe matter a response is given to the InternationalAssociation of Drilling Contractors (IADC) dated Oct.19, 2010, which states, “When an employer conducts ahazard assessment (HA) per NFPA 2113, Chapter 4, oruses some other method to determine the need for wearingFRC as protection against flash fire hazards, OSHACSHOs will evaluate the adequacy of the HA or othermethods in determining whether to issue citations whereemployees are not provided with, or wearing FRC duringdrilling, well-servicing and production-related operations.OSHA expects employers’ HAs or other methodsused to determine the need for FRC to be comprehensiveand robust.” IADC’s interpretation lists multiple factorsfor consideration of a “comprehensive and robust” hazardassessment, and in particular, this one comment:“Note low-probability/high-consequence eventscan occur when engineering and administrative controlsfail. The recent Deep Water Horizon off-shore drillingplatform event resulted in a massive well blowout,explosion/fire resulting in the death of 11 workers,injuries to other workers and immenseenvironmental damage. Eventhough several investigations are stillongoing, preliminary findings showthat a number of engineering andadministrative controls failed leadingto the incident.”There is no question that protectionof people, our communities andthe environment is of paramountimportance. The question is rather,“What is the appropriate basis ofsafety in which we can work andlive?” Intuitively, decisions need to bebased on “providing an environmentthat is free from recognized hazards”;however, it is the author’s opinionthat recognizing a hazard and theassociated severity and likelihood(i.e., risk) of the outcome is notunderstood by most organizations andrequires specific skills.MANAGEMENT SYSTEMSManagement systems, which advocate hazard identificationand control (e.g., OHSAS 18001, ANSI Z71,RC14001, ISO14001, etc.), are tools that organizationscan use to limit risk. Subsequent to the events in Alaska’sPrince William Sound during the Exxon Valdez spillin 1989, Exxon implemented an operations integritymanagement system, a framework similar to ResponsibleCare® 14001, which consists of 11 elements that createa system to implement safety, security, health, environmentand product safety policies.Exxon has reported that its incident rate per 200,000work hours dropped to 0.35 in 2009 from 0.43 the yearbefore; however, risk management to reduce “everyinjury,” “all hazards” and even “residual risk” requiresadvanced expertise often combining multiple disciplines(e.g., finance, safety, risk, insurance, security, environment,etc.). A low-probability/high-consequence riskresulting in catastrophic proportions, such as the DeepWater Horizon event, is not something that most safetyprofessionals, risk managers and loss prevention professionalscould prevent without a concerted effort amongHazard assessment isa standardized approachused to identifyand control riskand is advocatedby not only the higher-riskindustriesto which OSHAenforcement effortsare directed, but alsoby internationallyrecognized consensusorganizations.21Well Informed www.asse.org 2011

Table 1Hypothetical Cost to Control OneOil & Gas Risk for a Small Operatormany subject matter experts having vast resources andtime at their disposal.CHALLENGESThe American Clean Energy and Security Act of 2009brought to light some controversial challenges to theU.S. petrochemical industry. Refineries around the worldcan produce identical grades of gasoline and diesel fuelfor export to the U.S., which is in direct competition toproducers; however, measures of operational safetyabroad do not reflect codes and standards found withinEPA, OSHA, NFPA, ANSI, API, etc. The NationalPetrochemical and Refiners Association’s (NPRA) messageto the U.S. Congress last year brings to mind thatwe may not be pursuing as a nation affordable and economicallysensible clean energy policies if we continuein the same direction (NPRA, 2010). As we pursue ournational goals for clean energy technology and renewableenergy growth, we need to remain both competitiveand safe so that our children may grow up working inthe same community in which they live and not havingto service other countries that make our goods and produceour resources.We cannot talk about lowering risk without talkingabout cost. The author recently completed a risk assessmentfor a smaller upstream natural gas exploration andproduction firm using a failure mode and effect analysisfor approximately 100 activities. The firm had 10 employeesand roughly 100 contract operators servicingapproximately 1,500 wells. This activity involved roughlya half-dozen subject matter experts who know thebusiness and consumed more than 100 hours of time justto identify a handful of “more critical risks.” This costwas ($10,000 at $100/hour) to identify a handful of risksand to keep the math simple. The goal was to prevent“one in a million” or one death in a population of a millionor a million dollars in property or environmentaldamage (i.e., a low-probability, severe-consequenceevent). The dollars of revenue required to pay forthe risk identification and control would varybased on the profit margin, but let us say just onerisk existed.For example, let us consider a risk concerning awell site where the lease operator would need toenter an area during drilling and completion andwhere there was the potential to hit a pressurizedzone involving a gas release (e.g., a blowout or kick).The risk management to implement just one controlwas to require a mandatory use for all operators touse a hazardous gas detector upon entry to the facility.In looking at a hypothetical cost to control the riskfor this small company, developing the policies andprocedures to properly use the gas detector wouldrun say $5,000, acquiring 100 gas detectors at$500/each would run $50,000, performing trainingfor 100 people would run $5,000 and maintaining theprogram annually would be say $5,000.According to API, profit margins or earnings per dollarof sales were 7.3 cents in the first quarter of 2010 forthe oil and natural gas industry (API, 2010). The hypotheticalcost to control one risk for a small operatorwould be say $75,000 in the first year and require roughly$1.02 million dollars in sales to cover the cost of theprogram; note that the cost will vary depending on theprofit margin (Table 1).However, as safety professionals know, multiple failuremodes (vectors or root causes) may need to be mitigatedto prevent a catastrophic failure, and for eachfailure mode, a handful of controls may be necessary forany one risk (e.g., FRC, improved intrinsically safedesign, improved bleed and block methods, improveddown-hole monitoring, improved training and emergencymethods, etc.). Having said this, the oil and gas industryhas multiple low-probability/severe-consequence eventsand for which equates to millions of dollars in cost annuallyfor every small company. Small employers shoulddo their share for preventing risk, but is preventing aone-in-a-million event robust enough; were we qualifiedto perform the hazard assessment?OSHA’s March 2010 enforcement policy may leave asafety professional thinking, “When can FRC not beworn and who will decide if a hazard assessment is comprehensiveand robust enough?” There does not seem tobe any independent judgment by the experts, such as fireprotection professionals, process safety experts or the oiland gas industry, when it comes to flash fire risk whenviewed through the lens of the OSHA 2010 interpretations.The March 2010 policy almost deviates from theenforcement of the long-established, performance-basedprocess of a hazard assessment using recognized expertiseand competence under the authority of §1910.132(a)by listing numerous activities for which FRC is expected,and the October 2010 interpretation presents cleardoubt as to if the oil and gas industry can implementcomprehensive and robust process controls. Therefore,22Well Informed www.asse.org 2011

the interpretations take on a more prescriptive approachto regulating oil and gas well drilling, servicing and production-relatedoperations.OSHA is within its right to enforce and clarify policywhen appropriate; however, both the March and October2010 interpretations imply an expansion of OSHA’s charterbeyond simply performing a public service. It is herewhere the second implication exists, “Is it OSHA’s role tobecome a subject matter expert when it comes to identifyinga risk and controlling hazards for a specific industry?”Codifying measures to protect workers and the communityfor potential risks is clearly warranted, but where is the dueprocess of rulemaking? The role of the safety professionalin guiding employers to a successful outcome to preventrisk becomes less clear if the experts for specific industrysegments become those who write and enforce the rules(i.e., it is like having the fox watch the henhouse).CONCLUSIONThis article is not intended to criticize the agency, butis intended to present a perspective of potential unintendedconsequences of the recent interpretations relative topolicy. At a minimum, these more recent interpretationsleave little room for the oil and gas industry to controlrisk using a hazard assessment and process knowledge,which becomes not only troublesome for safety professionals,but also limits the ability for an organization tomanage resources and control cost. In summary, theauthor is concerned about two implications regarding the2010 OSHA interpretations on the use of FRC. The firstis that there may be a prima facie form of regulating theoil and gas industry without stakeholder consensus ordue process, and the second is that identification andcontrol of hazards have become more difficult for theAmerican industry in which to demonstrate a comprehensiveand robust assessment to achieve compliance.As OSHA turned 40 last year, Assistant SecretaryDavid Michaels’s and Department of Labor SecretaryHilda Solis’s strategies focus on stronger enforcement,whereas some employers need incentives to do the rightthing (OSHA, 2010). The author believes in strongerenforcement and penalties to deter complacent employers;however, let us reflect on where the energy industryis going as safety professionals, for where it came hasbeen through programs, such as PSM, hazard communication,safety by committee and performance-basedmethods, which have matriculated in numerous voluntaryprotection programs and management systems certificationswhere companies have been recognized for ajob well done. These programs motivate consensusbuilding and create the best companies in the world.This is an industry built on “roughnecks” and“roustabouts” who have a “git-r-dun” work ethic, whoare not only “pencil pushers” or “white-collar workers,”but are “salt-of-the-earth” people, Americans who workin some of the most wild and remote areas on earth. Weshould always keep in mind what the President said in arecent State of the Union address, “. . . to help our companiescompete, we also have to knock down barriersthat stand in the way of their success.” All governmentregulations are by the people and for the people—maybeit is time to consider giving some back to the people(State of the Union Address, 2011). REFERENCESAmerican Institute of Chemical Engineers. (1992,April). Guidelines for hazard evaluation procedures (2nded.). With worked examples, Center of Chemical ProcessSafety, Appendix B—Supplemental questions for hazardevaluations.American Petroleum Institute. (2010, Sept. 20).Energizing America: Facts for addressing energy policy.American Petroleum Institute. (2011, Feb. 17). EnergizingAmerica: Facts for addressing energy policy.Curlee, C.K., Broulliard, S.J., Marshall, M.L., et al.(2005). Upstream onshore oil and gas fatalities: A reviewof OSHA’s database and strategic direction for reducingfatal incidents. Prepared for the 2005 SPE/EPA/DOEExploration and Production Environmental Conference,Galveston, TX, March. 7-9, 2005.Engineering News Record. (2010). BP toughens safetyculture. Retrieved Nov. 16, 2010, from http://enr.construction.com/.Fairfax, R. & Witt, S. (2010, Mar.ch19). Enforcementpolicy for flame-resistant clothing in oil and gas drilling,memorandum to regional administrators state designees.Washington, D.C.: U.S. Department of Labor, OSHA.Maslowski, A. (2010, March/April). The petroleumindustry’s public image. Well Servicing Magazine.Michaels, D. (2010, Jul. 19). OSHA at 40: New challengesand new directions. Comments by the AssistantSecretary, OSHA, U.S. Department of Labor.National Petrochemical & Refiners Association.(2010, April 28). Written statement as submitted to theSubcommittee on Energy and the Environment, U.S.House of Representatives Committee on Energy andCommerce on clean energy policies that reduce ourdependence on oil.Neuman, M. (2011, Jan.). New OSHA sheriff intown. Professional Safety, 8.The White House. (2011, Jan. 25). State of the unionaddress. Washington, DC: Office of the Press Secretary,U.S. Capitol.Christopher S. Clasen, CSP, CFI, CEM, is certified as an ISO14000 and OHSAS 18001 advanced environmental managementsystems auditor and is the owner of CSC Engineering LLC, a professionalenvironmental, fire and safety consulting firm specializingin environmental health and safety (EHS) compliance services.He has more than 25 years’ comprehensive experience in EHS inprivate industry, consulting and public regulatory agencies. Heholds an M.S. in Civil and Environmental Engineering fromCalifornia State University and a B.S. in Mechanical Engineeringfrom the University of California.23Well Informed www.asse.org 2011

WORKPLACE SAFETYLetter from David Michaels toNatural Gas Power Plant OperatorsFollowing is the warning letter Assistant Secretary of LaborDavid Michaels sent to natural gas power plant operatorsat the end of 2010 to prevent potential tragedies, such as theFeb. 7, 2010 gas explosion at the Kleen Energy plant inMiddletown, CT.I am writing to inform you of the hazards associated with thepractice of cleaning fuel gas piping systems using natural gas. OnFeb. 7, 2010, a devastating explosion at the Kleen Energy powerplant in Middletown, CT took a massive human toll, killing sixworkers and injuring another 50. This explosion was triggered bythe ignition of pressurized natural gas that was used to clearnewly constructed fuel pipes. After a comprehensive inspectionof the incident, OSHA recently issued citations with proposedpenalties totaling more than $16.5 million. This tragedy couldhave been easily avoided by the exercise of common sense,adherence to OSHA standards and industry-accepted safety proceduresand following internal safety rules.As an employer, you are responsible for eliminating or controllinghazards that may kill or injure your employees in thesefacilities. It is the responsibility of all employers, particularlythose operating in high-hazard industries, to ensure the safetyand health of their employees at the worksite. None of themajor employers at the Kleen Energy site on Feb. 7, 2010 tookappropriate action to eliminate or reduce hazards associatedwith fuel system gas blows, despite knowing of the potential fireand explosion hazards associated with such operations. Theemployers had reviewed and approved safety procedures forconducting these operations. However, OSHA’s investigationdetermined that many of these precautions were not followed.The practice of using natural gas blows to clean piping systemsis inherently dangerous. The U.S. Chemical Safety Board,which also investigated the blast, recommended that employersbe prohibited from releasing flammable gas to the atmospherefor the purpose of cleaning fuel gas piping. There are feasiblealternatives to cleaning gas fuel piping with natural gas; thesealternatives include the use of nonflammable, nonexplosivemedia to clean the pipes. OSHA strongly recommends the use ofnonflammable, nonexplosive alternative media when it is necessaryto use gas to clean piping.If you, as an employer involved in building or renovating gaspoweredelectrical generation plants, nevertheless elect to use agas blow procedure using natural gas, you must evaluate andaddress all potential hazards before and during the blows, andtake effective action to eliminate employee exposure to thosehazards.Specifically, you should vent the natural gas vertically andabove all structures, eliminate all ignition sources, remove allnonessential workers from the site and monitor potentiallyhazardous atmospheres during and after completion of theblows. At a minimum, the following requirements apply tothese operations:29 CFR 1926.20(b)(2): The employer must provide a competentperson able to recognize construction workplace hazards,including those associated with natural gas blows.29 CFR 1926.21(b)(2): The employer must train employeesto recognize construction workplace hazards, including thoseassociated with natural gas blows.29 CFR 1926.352(c): The employer must ensure that welding,cutting or heating at construction sites is not conducted inthe presence of flammable compounds, including natural gas.29 CFR 1926.403(b)(2): The employer must ensure that listed,labeled or certified equipment at construction sites is used inaccordance with instructions included in the listing, labeling orcertification (prohibit the use of equipment that can ignite naturalgas).Section 5(a)(1) of the Occupational Safety and HealthAct: The employer must keep its workplace free from recognizedhazards causing or likely to cause death or serious physicalharm. The hazards of natural gas blows are well-recognized inthe power plant construction industry. This letter provides individualemployers with direct knowledge of the hazards.It is imperative that you carefully evaluate all aspects ofnatural gas fuel system blows and follow through with theimplementation of all needed safety procedures. If you are asubcontractor at such a site and are not directly involved in thegas blows, you must nevertheless ensure that your employeesare fully protected.It is your responsibility to comply with the law and to fullyprotect workers at these sites. Any failure to adhere to the lawand industry-accepted safety standards in the course of a fuelsystem gas blow will be pursued vigorously by federal or stateOSHA agencies to the fullest extent of the law. The intent of thisletter is to ensure your knowledge of the inherent dangers offuel system gas blows as well as the safety requirements OSHAexpects to be observed. If OSHA finds violations of these requirements,it will strongly consider citing for willful violations thatcarry a maximum $70,000 civil penalty. If any employee dies as aresult of an explosion associated with a gas blow, in addition toany civil penalties proposed, OSHA will consider referring theincident to the Department of Justice for criminal prosecutionpursuant to the criminal provisions of the Occupational Safetyand Health Act of 1970.States operating state plans will consider similar action understate law. Federal OSHA and states that operate their ownOSHA-approved state plans are responsible for enforcing occupationalsafety and health laws and standards throughout thenation. Twenty-seven states and territories operate OSHAapprovedstate plans. If you are building or renovating a gaspoweredelectrical plant in any of these states, the state willenforce similar requirements in the private and public sectors.For contact and background information on state standards andenforcement programs click here.I am calling on you to prevent further needless deaths. If youare a small business, OSHA state on-site consultation programsare available to assist you in complying with OSHA standards. Ifyou have further questions, please contact your local OSHA areastate plan office or your state on-site consultation program. Foradditional information click here. Sincerely,David Michaels, Ph.D., MPH24Well Informed www.asse.org 2011

VSAFETY VIDEODeadlyPracticesNew Safety Video onOne-Year Anniversaryof Kleen EnergyThe U.S. Chemical Safety Board (CSB) has releaseda new safety video depicting two major accidentscaused by the intentional release of flammable fuelgas near work areas, one year after the Kleen Energyexplosion. The 15-minute video focuses on two accidentsinvestigated by CSB. A June 9, 2009 explosion atthe ConAgra Slim Jim plant near Garner, NC, that fatallyinjured four workers and injured 67 others, and a Feb.7, 2010 explosion at the Kleen Energy natural gas-poweredelectric generating plant under construction inMiddletown, CT, that killed six workers and injured atleast 50 others.The two incidents involved the intentional release offlammable natural gas into work areas, putting workersand nearby communities at risk of fires and explosions.At the Kleen Energy facility, workers were conducting agas blow, a procedure that forced natural gas at high volumeand pressure through newly installed piping toremove debris. The gas was vented to the atmosphere,where it accumulated, came in contact with an ignitionsource and exploded. At the ConAgra facility, workerswere purging a pipe feeding gas to an industrial heater.During the purging operation, gas was allowed to flowthrough the pipe and to exit through an open valve insidethe utility room where the water heater was located.Flammable gas accumulated inside the building andeventually found an ignition source.Titled “Deadly Practices,” the video includes animationsthat show the hazards of releasing gas into areaswhere it can accumulate, ignite and kill or injure workersor members of the public.In the video, CSB Chair Rafael Moure-Eraso says,“The deadly accidents at Kleen Energy and ConAgrawere entirely preventable. At CSB, it is our hope thatstandards will be put in place that will require these saferpractices, which we believe will save lives.”As a result of CSB’s investigation, the board releasedurgent recommendations aimed at preventing futuretragedies. CSB recommended that OSHA promulgateregulations that address fuel gas safety for both constructionand general industry. CSB also offers a safety bulletinon the dangers of purging gas piping into buildings.In the video, Don Holmstrom, CSB’s lead investigatorinto both of these incidents, speaks to a key recommendationon cleaning piping at power plants: “CSB believesthat the use of flammable natural gas in gas blows isinherently unsafe and alternate methods should beused.”In September 2010, the governor of Connecticutissued an executive order banning the use of natural gasblows during power plant construction in the state. TheNational Fire Protection Association and the InternationalCode Council are taking action to ban the use ofnatural gas for cleaning and purging pipes. The two incidentsinvolved the intentionalrelease offlammable naturalgas into workareas, puttingworkers and nearbycommunities atrisk of fires andexplosions.25Well Informed www.asse.org 2011

WORKPLACE SAFETYNORA National Oil & GasExtraction CouncilThe oil and gas sector is categorizedby North American Industry ClassificationSystem (NAICS) codes 211 foroil and gas operators, which own the rightsto drill for oil and gas; 213111 for drillingcontractors, which drill oil and gas wells;and 213112 for service companies, whichservice oil and gas wells. NAICS is the standardused by federal statistical agencies inclassifying business establishments for thepurpose of collecting, analyzing and publishingstatistical data related to the U.S. businesseconomy.The Bureau of Labor Statistics estimatedthat 476,000 workers were employed in thisindustry in 2008. During 2003 to 2008, 648oil and gas extraction workers were fatallyinjured on the job, resulting in an occupationalfatality rate several times higher than therate for all U.S. workers. The National OccupationalResearch Agenda (NORA) Oil and Gas ExtractionCouncil is currently working to address critical areas inthis sector.Council activities are outlined below. Contact the sectorcoordinator (RDHill1@cdc.gov) with any questionsor comments.SEPTEMBER 2009Third meeting to refine the preliminary draft goals. Thefour workgroups met to refine their research priorities andreceive feedback from the full council. Under considerationare strategic goals for preventing illnesses, fatalitiescaused by motor vehicle crashes, injuries caused by workersbeing struck by objects, harmful chemical exposuresand fatal and nonfatal injuries overall.FEBRUARY 2009Second meeting to refine the key safety and healthissues previously identified. The four workgroups met toreport on progress, refine their research priorities anddevelop an action plan for the next 6 to 12 months. Inaddition, the council began to define strategic goals forpreventing health outcomes, such as illnesses, fatalitiescaused by motor vehicle crashes and injuries caused byworkers being struck by objects.JULY 2008First meeting to identify and prioritize key safety andDuring 2003 to 2008, 648 oiland gas extraction workerswere fatally injured on thejob, resulting in an occupationalfatality rate severaltimes higher than the rate forall U.S. workers.health issues in the oil and gas extraction industry. Fourtopical areas emerged from this list: workforce issues,operations, information—regulatory/industry associationsand education and training. A workgroup wasestablished for each topical area. The workgroups willbegin drafting a research framework with goals andaction items.FEBRUARY 2008A preliminary meeting of the council was held to outlinesubsector issues, identify key stakeholders for possibleparticipation, plan future actions and prepare for thefirst full meeting. Participants began to develop a list ofresearch issues that should be considered by the councilin the development of the Oil and Gas Extraction Subcouncilstrategic plan. Topics discussed included injuries,worker and supervisor training, safety management practices,data collection and worker turnover. 26Well Informed www.asse.org 2011

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