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
“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.
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
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
Any operation working with wellhead or wellbore under pressure
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)
Transfer of hydrocarbons
Maintenance operations on production equipment
Hot work operations
Using open flame
Start-up operations” Continue reading
My new article on choosing arc flash PPE is unbiased and real helpful on getting the right things without all the industry hype. We don’t sell the PPE but we do most of the arc flash testing at ArcWear.com so … Continue reading
This paper is feared by some because Tom is calling us to really understand the arc. What the real outcome of the paper is that faceshields and arc rated rainwear may be better protection than we realized and textiles might … Continue reading
This is an older story but a good one to see when OSHA started working to enforce more on electrical safety surrounding arc flash. Up until 2000, OSHA really only addressed arc flash in electric utilities. The 1994 law 29 … Continue reading
In this excellent article interviewing Scott Margolin Imperial Sugar tells of their plan to use “FR” uniforms. They chose excellent uniforms by the way, BUT the photo on the cover has the female worker in a melting hairnet. Sad this … Continue reading
Hugh Hoagland’s new article on common PPE mistakes covers like melting rainwear that says it is flame resistant when it isn’t, failing to train workers and the issues that come up because of this. When following NFPA 70E companies must … Continue reading
This new article on American Chronicle is helpful for arc flash training. Click here to read the article.
Another arc flash training article which emphasizes things the numbers won’t tell you. Having labels on equipment doesn’t mean the workers are qualified or that the clothing is like linking Garanimals (from when I was a kid). You have to … Continue reading
This article builds on e-Hazard.com training for arc flash and electrical safety. Caring for FR clothing requires some training. This article is part of e-hazard resources for arc flash training. Read the article on American Chronicle.