RIDGWAY – At a recent meeting of the Elk County Gas Task Force, Compliance Assistance Specialist Mark F. Harmon of the Occupational Safety and Health Administration’s (OSHA) Erie office presented a “top 10 list” of the most frequent violations OSHA has encountered recently in the oil and gas industry.
According to Harmon, the following violations are those for which OSHA representatives have issuing the most citations:
1. Guarding floor/wall openings
"The most cited item we've had in the last 12 months for oil and gas was the guarding of floor openings or well openings. In most cases, that's referring to fall protection," Harmon said. "If it's a person
working a Marcellus rig, he could be 90 feet off the ground. That standard would apply when working anything above four feet, so you have to protect someone from falling."
2. Permit required confined space
"Oil and gas has that particular hazard. We’ve cited that quite frequently," Harmon said.
He explained that wellheads usually have “cellars” about six or eight feet deep underneath the rig.
“If people have reasons to go down in there, that would meet the definition of a confined space,” Harmon said.
3. General duty clause #5A1
"If we don’t have an OSHA standard, we can issue a citation, and that’s what it’s referred to, as a general duty citation," Harmon said. "But in order for us to do that, we have to prove a few things. We have to prove that it's a recognized hazard, but also that there's an employee exposed, that there's a means to correct it, to make it safe, and that it's feasible to do so. Oil and gas is unique in that they have a lot of hazards out there that don't fall into the OSHA book."
4. Electrical wiring methods
"Almost everywhere you go-- oil and gas is no exception-- you're going to have people using electricity," Harmon said. "OSHA compliance officers, we're not electricians by trade. Mostly what we're
looking for is, does it look like it's safe, does it have all the covers, and is it used according to what the manufacturer called for? Electrical violations are going to be almost everywhere you go if you look
5. Personal Protective Equipment (PPE)
"We've got a lot of talk about this one over the last year, two years," Harmon said.
He said OSHA has taken a new direction in enforcing Personal Protective Equipment (PPE) and flame-resistant clothing (FR) regarding oil and gas. A memo distributed by OSHA said employees at oil and gas locations working at or near hydrocarbon zones could potentially be exposed to flash fires.
"The way in which you would protect someone from a flash fire would be putting flame-resistant clothing on," Harmon said. "The petrochemical industry, like the refineries, they already have this in place. If you go onto any refinery location, whether it's Warren or Bradford, you go into their facility, you gotta put your FR on. Now it's something that we're addressing even at the well location.
"The OSHA regulations are the minimum required by law. A company policy can always be much more stringent. Most of these larger operators are being very stringent and saying, 'If you come out to our location, you've gotta put it on.'"