Most Commonly Misunderstood Standards for Oil and Gas Industry

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1 Most Commonly Misunderstood Standards for Oil and Gas Industry Presented by: Dale Robinson HR Safety Consulting, LLC Erie, Colorado Like us on Facebook at: HR Safety Consulting, LLC

2 What do you think are the most commonly misunderstood standards in the Oil and Gas Industry?

3 Lockout / Tagout? Hazard Communication? Excavation and Confined Space? PPE Hazard Assessment process?

4 Let s look at Lockout / Tagout 29CFR Control of Hazardous Energy

5 The scope: (a)(1)(i) This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees.

6 The scope: (a)(1)(ii) This standard does not cover the following: (a)(1)(ii)(e) Oil and gas well drilling and servicing.

7 So does this mean that the Oil and Gas Industry is exempt from the Control of Hazardous Energy Standard? No. The entire.147 standard applies to every facet of the O & G industry except during drilling or servicing operations only. Employers of Drilling and Servicing operations must still protect their employees during operations and they do regardless of this exemption.

8 The standard requires 5 major components: 1. Program 2. Energy control procedures, 3. Employee training 4. Periodic inspections 5. Additional Requirements to ensure the machine or equipment is isolated from the energy source, and rendered inoperative.

9 The Program: 1. Methods of controlling energy bytagout. If an energy isolating device is not capable of being locked out, the employer s energy control program shall utilize a tagout system.

10 The Program: 1. Methods of controlling energy by Lockout. If an energy isolating device is capable of being locked out, the employer s energy control program shall utilize lockout,

11 The Program: 1. Methods of controlling energy by Tagout. unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection.

12 2. Energy control procedure: (c)(4)(i) Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section. Lockout Procedures Or Tagout Procedures

annually to ensure that the procedure and the requirements of this

13 3. (c)(6) Periodic inspection (c)(6)(i) The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed. Lockout Procedures Or Tagout Procedures

14 4. (c)(7) Training and communication The employer shall provide training to ensure that understanding, knowledge and skills are obtained for the safe application, usage, and removal of the energy controls and function of the energy control program.

15 4. (c)(7)(iii)(b) Additional retraining: whenever a periodic inspection reveals, or whenever the employer has reason to believe, that there are deviations from or inadequacies in the employee s knowledge or use of the energy control procedures. (c)(7)(iii)(c) The retraining shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary.

16 5..147(f) Additional requirements: Outside personnel (contractors, etc.). (f)(2)(i) Whenever outside servicing personnel are to be engaged in activities covered by this standard, the onsite employer and the outside employer shall inform each other of their respective lockout or tagout procedures. (f)(2)(ii) The on-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer s energy control program.

17 Hazard Communication? Excavation and Confined Space? PPE Hazard Assessment process?

18 Let s look at HAZCOM 29CFR Hazard Communication

19 (b) Scope and application (b)(1) This Section requires chemical manufacturers or importers to classify the hazards of chemicals which they produce or import, and all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, safety data sheets, and information and training.

20 (b) Scope and application It is the responsibility of the Producer to develop Labels and SDS s for every chemical THEY produce. It is the responsibility of all Producers to make available all Labels and SDS s to all employees and to all contracted or outside employers employees that they may be exposed to.

21 (e) Written hazard communication program (e)(1) Employers shall develop, implement, and maintain at each workplace, a written hazard communication program. (e)(1)(i) A list of the hazardous chemicals known to be present (aka. A chemical inventory list)

22 (e)(2) Multi-employer workplaces. Employers who produce, use, or store hazardous chemicals at a workplace in such a way that the employees of other employer(s) may be exposed shall additionally ensure that the hazard communication programs developed and implemented include the following:

23 (e)(2) Multi-employer workplaces. The methods the employer will use to provide the other employer(s) on-site access to safety data sheets for each hazardous chemical the other employer(s) employees may be exposed to while working; The methods the employer will use to inform the other employer(s) of any precautionary measures that need to be taken to protect employees during the workplace s normal operating conditions and in foreseeable emergencies; and

24 (e)(2) Multi-employer workplaces. The methods the employer will use to inform the other employer(s) of the labeling system used in the workplace.

25 (f)(6) Workplace labeling: The employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked.. (f)(10) The employer shall ensure that workplace labels or other forms of warning are legible, in English, and prominently displayed on the container, or readily available in the work area.

26 (g) Safety data sheets Employers shall have a safety data sheet in the workplace for each hazardous chemical which they use. (g)(8) The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s).

(g) Safety data sheets Retention of SDS s (g)(11) Safety data sheets shall also be made readily available, upon request, to designated representatives, the Assistant Secretary, and the Director, in

27 (g) Safety data sheets Retention of SDS s (g)(11) Safety data sheets shall also be made readily available, upon request, to designated representatives, the Assistant Secretary, and the Director, in accordance with the requirements of 29 CFR (e). 29 CFR Preservation of records: (d)(1)(ii) Employee exposure records. Each employee exposure record shall be preserved and maintained for at least thirty (30) years. (d)(1)(ii)(b) Safety data sheets need not be retained for any specified period as long as some record of the identity (chemical name if known) of the substance or agent, where it was used, and when it was used is retained for at least thirty (30) years;

28 (h) Employee information and training Employers shall provide employees with effective information and training on hazardous chemicals in their work area.. (h)(3)(iv) The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information. Section 1, Identification; Section 2, Hazard(s) identification; Section 3, Composition/information on ingredients; Section 4, First-aid measures; Section 5, Fire-fighting measures; Section 6, Accidental release measures; Section 7, Handling and storage; Section 8, Exposure controls/personal protection; Section 9, Physical and chemical properties; Section 10, Stability and reactivity; Section 11, Toxicological information. Section 12, Ecological information; Section 13, Disposal considerations; Section 14, Transport information; and Section 15, Regulatory information. Section 16, Other information, including date of preparation or last revision.

29 Excavation and Confined Space? PPE Hazard Assessment process?

30 Let s look at Excavation verses Confined Space 29CFR Excavation and Trenching 29CFR Confined Spaces in Construction

31 Although an excavation or trench may have the same characteristics as a confined space or even as a permit required confined space; Definition of a Confined Space Limited entry or exit Large enough to bodily enter to perform assigned work Not designed for human occupancy

32 Definition of a Permit-required confined space Permit space means a confined space that has one or more of the following characteristics: Contains or has a potential to contain a hazardous atmosphere; Contains potential for engulfing an entrant; Has a potential entrapment hazard Contains any other recognized serious safety or health hazard.

The Confined Spaces in Construction standard states: 1926.

33 The Confined Spaces in Construction standard states: (b) Exceptions This Standard does not apply to: (b)(1) Construction work regulated by Subpart P of this Part (Excavations).

34 The Excavation Standard has its own protective system designed in it to keep it from being classified as a Permit Required Confined Space.

35 Saying this, Subpart P Excavation 29CFR plus appendix A F require the employer to designate a Competent Person to oversee all excavation and trenching activities.

36 Definition of a Competent Person: Means one who is capable of identifying existing and predictable hazards in the surroundings, or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

37 Definition of Competent: Possessing the skills, knowledge, experience, and judgment to perform assigned tasks or activities satisfactorily as determined by the employer.

38 Per Subpart P, the competent person on an excavation or trench must possess skill, knowledge, experience and judgment of the entire Excavation standard including: Surface encumbrances Underground utility locates Access and egress Exposure to vehicular traffic Exposure to falling loads Warning systems for mobile equipment Hazardous Atmosphere (testing and controls) Hazards associated with accumulation of water Stability of adjacent structures Protection from loose rock or soil Inspection requirements Fall protection Soil classification determination Protective systems requirements Protective systems selection

39 PPE Hazard Assessment process?

40 Let s look at PPE Hazard Assessment 29CFR (d)

29CFR 1910.132(d) PPE - The LAST line if Defense for Hazard Control.

41 29CFR (d) PPE - The LAST line if Defense for Hazard Control. Each employer must perform a Hazard Assessment to determine if PPE is necessary or not.

42 Hazard Assessment 29CFR (d) If a hazard exists, the employer must do everything they can (per the hierarchy of controls) to keep employees from exposure

43 Hazard Assessment 29CFR (d) If a hazard cannot be controlled and PPE is necessary to help reduce the effects of exposure, then the employer must: 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; Communicate selection decisions to each affected employee; and, Select PPE that properly fits each affected employee. And 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.

44 Training 29CFR (d) The employer shall provide training to each employee who is required to use PPE. Each such employee shall be trained to know at least the following: When PPE is necessary; What PPE is necessary; How to properly don, doff, adjust, and wear PPE; The limitations of the PPE; and The proper care, maintenance, useful life and disposal of the PPE.

45 Training 29CFR (d) Each affected employee shall demonstrate an understanding of the training and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE.

46 Training 29CFR (d) Yes this means: Foot protection (Safety foot wear) eye and face protection (Safety glasses, googles and face shields) Hard hat Hearing protectors and earmuffs Protective clothing i.e. FRC s Gloves Respirators Fall Arrest (Harness and lanyards) Fall Restraint (Body belt or harness with tether)

47 There are other subparts that are commonly misunderstood: Hearing Protection 29CFR (a) & (b) Hearing Conservation 29CFR (c) (o) Respiratory Protection 29CFR (g) HAZWOPER 29CFR (a) and (q) Hot Work 29CFR (a) and API RP2009

48 Any questions?

49 Thank you for attending Presented by: Dale Robinson HR Safety Consulting, LLC Erie, Colorado Phone: Like us on Facebook at: HR Safety Consulting, LLC

FACT SHEET Standard: Lockout - Tagout

FACT SHEET Standard: Lockout - Tagout LOCKOUT - TAGOUT INTRODUCTION Workers performing service or maintenance on machinery and equipment may be exposed to injuries from the unexpected energization, startup of the machinery or equipment, or