OSHA Interpretation on Logos for Arc Rated and FR Clothing Puts Responsibility on the Employer

OSHA actually addressed logos for flame resistant clothing (arc rated clothing) related to arc flash in an interpretation letter.  This is interesting. They didn’t give specific guidance but indicated the employer is responsible. ASTM F1506 does not require logos to … Continue reading

Flame Resistant Clothing Requirements Pushed for Oil and Gas Well Drilling, Servicing & Production Operations

“OSHA’s policy for citing the general industry standard for personal protective equipment (PPE), 29 CFR 1910.132(a), for the failure to provide and use flame-resistant clothing (FRC) in oil and gas well drilling, servicing, and production-related operations. For the purpose of this memo, FRC includes both flame-resistant and fire retardant treated clothing. Clarification of the need to provide and use FRC during certain drilling, servicing, and production-related operations is necessary to resolve its inconsistent use among drilling contractors, well servicing contractors, and oil and gas companies that employ thousands of workers in these operations. OSHA inspection history and current information, including consensus standards, scientific evidence, and accident and injury data, indicate a potential for flash fires during certain well drilling, servicing, and production-related operations….

Citation Guidance for 29 CFR 1910.132(a)

Where appropriate, CSHOs shall cite 29 CFR 1910.132(a) for the failure to provide and ensure the use of FRC in oil and gas drilling, well servicing, or production-related operations when there is a potential for flash fire hazards as discussed below.

Drilling Operations
FRC is usually not needed during initial rig up and normal drilling operations prior to reaching active hydrocarbon zones, unless other activities warrant their use; e.g., fracing a previously drilled well while rigging a well in close proximity.

A potential for flash fire exists once active gas or hydrocarbon zones are reached. Appropriate FRC shall be worn by exposed employees working on the well site prior to drilling into identified gas or hydrocarbon zones. CSHOs should verify that employees are wearing FRC in advance of reaching such zones.

Appropriate FRC should also be worn when there is a history of fluid or gas kicks from underground producing zones.

Once FRC is identified for use as provided above, employees should wear appropriate FRC until the final casing is cemented and the well is effectively closed.

Well Servicing Operations
CSHOs shall determine whether FRC is provided and worn during well servicing or workover operations, such as:

Pulling wet string tubing
Snubbing tubing
Swabbing operations
Fracturing or perforating the well
Using bridge plugs or packers
Open hole work
Flow testing, blowing down or venting the well
Plugging an abandoned well
Flowback operations
Cementing
Stimulation
Wireline operations
Any operation working with wellhead or wellbore under pressure

Production-Related Operations
In OSHA’s experience, the potential for flash fire also exists in production-related operations that fall outside of drilling and well servicing. CSHOs shall determine whether FRC is provided and worn during production-related operations, such as:

Equipment openings (e.g., line breaking or valve changes)
Gauging
Transfer of hydrocarbons
Maintenance operations on production equipment
Hot work operations
Tank heating
Using open flame
Start-up operations” Continue reading