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OSHA Says FR Clothing Required in Many Oil & Gas Jobs

A March 19 memo sent to regional administrators and state plans by Richard Fairfax and Steve Witt, who head the OSHA enforcement and state programs units, clarifies when citations should be issued for failing to provide it.

  • Mar 26, 2010

A memorandum dated March 19 from Richard Fairfax and Steve Witt, who head the OSHA enforcement and state programs units, clarifies that OSHA expects its compliance officers to issue citations when employers fail to provide or ensure the use of flame-resistant clothing (FRC) during certain oil and gas well drilling, service, and production work. Posted online by OSHA, the memo is addressed to regional administrators and state plans. It was issued to clarify OSHA policy, according to the document, and notes that flame-resistant clothing includes both flame-resistant and fire retardant treated clothing.

The memo says the policy is needed because of the potential for flash fires during the tasks; it says for a citation under 29 CFR 1910.132(a) to be issued, there must be evidence the employer "had actual notice of a need for protective equipment, or that a reasonable person familiar with the circumstances, such as facts unique to the industry, would have recognized a hazardous condition warranting the use of that equipment."

The potential for flash fires is lower when the operation in question has not reached gas and hydrocarbon producing zones, the memo states. So it says FRC is usually not needed during initial rig up and before reaching active hydrocarbon zones, unless other activities warrant its use. The memo lists well servicing operations and production-related operations where FRC should be provided and worn, including open hole work, cementing, stimulation, equipment openings, hot work operations, tank heating, and using open flame.

Compliance officers should issue a citation when the employer has failed to ensure employee-owned FRC is properly maintained and sanitary, has failed to provide FRC that is of safe design and construction for the work being performed, when the FRC is defective or damaged, or where the employer failed to provide it at no cost to the worker(s). Employers may consult NFPA 2112 and 2113 to comply, it says.

Comments

Sat, Nov 10, 2012

it's a perfect example of people enforcing rules like the fr clothing that don't have a clue what the oil field is all about . yet somehow we let these morons keep making stupid decisions that don't affect their lifestyles at all . in fact i have always said some one high up like these to idiots are getting thier pockets padded, maybe someday the real story will unfold.

Fri, Jul 20, 2012 Ira Masters Bakersfield

Mr Gunn you are an idiot! I am ex military and that comment about the difference between military and roughnecks is an insult to intelligence. Let's start with the obvious differences. In the military they own you and your life. They don't have to follow laws of fair treatment or intimidation and you are forced to do what they want, when they want, and how they want with no regard for yourself! They have their own set of laws and justice system called the UCMJ. (Uniform Code Of Military Justice). Look it up! This definitely sounds like what you are trying to accomplish with your f'ing retarded clothes but you don't own these people and as free citizens of the United States, they have a constitutional freedom to decide what is best for themselves under guidelines set by OSHA and the companies they work for! The military wears armor etc. as protection from an actual threat of attack in combat situations. When not in a combat situation or in a danger zone you will not see them wearing body armor! I have to wear frc constantly in 100 degree plus weather and in over 40 years of my companies existence there has never been an example of anyone being burned by a flash fire but there have been many of heat related illnesses! Use some common sense and let the people who will be affected by your actions have a decision in their own safety and well being!!!

Tue, Jun 26, 2012 Kris

FR's will hurt people more than help , I have to wear these junky a$$ things and I can be honest to say , I'm surprised more people haven't died by wearing them . The fact is they get insurance cuts for making them mandatory on the job site or their property . So to save a dollar they put you in more harms way . They do not have a clue how it feels to work in them because they will sit in the a/c 90-100% of the time . I feel they need to get out here side by side with us and see how they feel . FR's are *** plain and simple

Mon, Jun 25, 2012

Those that made these rules should be forced to wear them. Do you really think FRC works? Who's pockets are being padded? Damn sure isnt us workers. How many heat related deaths and heat exhaustion causes will it take to stop your stupid ruling?

Mon, Mar 19, 2012 justin brown east texas

To Mr. Dan Gunn if I wanted to do all of the *** the military does I would of signed up for it. Get your ass out here and see if you can hang without taking a damn break every 15 minutes. We all know that if you got a break every 15 minutes in the oilfield the oilfield would take a *** Its either put up or shut up out here.

Thu, Mar 8, 2012

Found some short sleeved fr t shirts. Will osha allow them in the oil field or do they require long sleeves?

Tue, Sep 6, 2011 gulf cosat of texas

frc's are here to stay...... The solution is to work the OSHA recommended work schedule for temperatures in the extreme, as they are around the rat hole. funny they don't have a recommendation for cold weather........ See the osha website. At 100 degree and 75 % humidity thats 15 minuets of strenuous work and 45 min of rest in shade,with airflow,and 3 20 oz containers of water in the 45 min time frame. Gas will be $5.00 a gallon just like uncle obumma wants but YOU will go home safe tonight. I support the FRC rule, but EMPLOYERS you got to be flexible in your work schedule. No more balls to the walls for 12.

Thu, Sep 1, 2011 Waterhauler Kansas

I understand the importance of FRC but the clothing is not 100 perent cotton, so static electricty is a possible problem .

Tue, Aug 9, 2011 Editor

Steve Witt no longer works for OSHA. He joined VPPPA on July 11 with the title senior advisor.

Mon, Aug 8, 2011 Rohn Ishmael

I think that Mr. Witt and Mr. Fairfax that head the OSHA enforcement division should have to wear FRCs in their offices and turn their thermostats up to 95, put some heat lamps in the ceiling to represent the sun, and get up every 15 minutes or so and do some jumping jacks to represent some kind of physical labor, and then let's see if they whine about the working conditions. Let just the AC quit working in one of their offices for a couple of hours, and they will be crying about how miserable they are. I heard there were over a dozen people that died in Dallas last week because of the heat. Forcing people to put on heavy long sleeve coveralls and run around out in the HOT sun is STUPID to point of being Dangerous when there is little or no chance of a flash fire. The next time someone else dies because of this worse than stupid rule, I think the people that made that rule in their air conditioned office should be charged with negligent homicide.

Mon, Aug 1, 2011

I think they are stupid. Yeah, wear them when they need to be worn but like where I work, on brand new locations, there should not be frc policies. Like said before, I think they hurt more than they help and all these people sitting in their air conditioned offices dreaming up this **** are just finding new ways to make their selves richer and not care about the "labor hands." We are the ones that have to deal with the elements, not them. The oilfield might be a lil bit more enjoyable again if you didn't have to wear all this hot clothing that even restricts you in some ways while you are trying to work. To me there is nothing good about them.

Wed, Jul 27, 2011 Dan Gunn South Texas

FRC's save lives and prevent tremendous amounts of pain, suffering and permanent disablity to anyone exposed to a flash fire situation. What a bunch of whiners! Educate your employees on heat injury prevention, proper hydration, and make darn sure your tool pushers, drillers and company men understand the signs and symptoms of heat injuries and take appropriate action to prevent a serious injury / fatality due to heat stress. The US military has been rolling 24-7 for over 10 years in 120 degree heat wearing full body armor, combat fatigues while wearing a 12 pound hard hat to boot. What's the difference between a roughneck and a soldier? Soldiers are trained to recognize signs and symptoms and to properly hydrate. Roughnecks need to be trained not to go out boozing all night when they are off tower. I have worked worm corner, have been a soldier for 19 years and I am a safety manager for a petrochemical inspection company and have been an EMT for 13 years and have worked on the burn ward at Vanderbilt in Nashville and Brook Army Medical Center treating and caring for victims of burns. You just have to be smarter than your average bear on this stuff and watch your co-workers back and do not forget to drink water!!!

Thu, Jul 21, 2011 Beau Young Louisiana

I also agree that FRC is hot. I've worked in the oil field before and I know the hazards of heat exhaustion. But what I have come to realize after study on the matter is FRC comes in many shapes and forms. During my last job, the managers took my advice and switched to Glen Guard FRC Overalls and Shirts/Pants. If you are currently in Indura Ultrasoft or another form of FRC, Glen Guard offers a more lightweight and breathable alternative. Talk to your bosses to learn more about it. You can't imagine the difference switching from a 6.4 oz FRC to a 4.5 oz FRC garment has changed my attitude about it. And also I've seen the effects of flash fire with someone without FRC and with. I would much rather sweat more to protect 95% of my skin than lose over 80% without.

Tue, Jul 5, 2011 No_whinin

FRC can look pretty much like the clothes people are currently wearing on the job. Pants and shirts or just coveralls over your BVD's if that's how you swing. The whining and excuses were heard in the petrochemical industry at first as well. What's hotter than a Texas refinery worker between some heat exchangers on the hot concrete floor of a process unit? You have the sun and hot process equipment radiating heat at you all day. There are also a lot of cooling options that should be considered whether or not FRC is in use when heat stress on the job is as bad as descibed. American ingenuity and can do attitude is what is needed not more complaining.

Wed, Jun 29, 2011 motor man texas

I work on a drilling rig located in the texas panhandle. frc clothing has been required on my rig approximately 3 months now. wearing frc's is a joke. 100+ temperatures and required frc's have led to heat exaustion and even death. they are more of a hazard than help. The folks who are making these a requirement most likely have never even worn the things and soak up the ac for the majority of the day. guess what you guys, we do not have air conditioning on rigs to enjoy and our boss's say well if you feel over heated take a break then we get griped out for taking a break. while tripping pipe it's not like we can shut down for a cool down break and if we did. where are we going to cool down at. the inside of the 120 degree doghouse. come on really. i know might little tid bits will not matter but there has to be something done before more people over heat and possibly die.

Mon, Jun 27, 2011 DaylightDiller Kansas

You get a rare flash fire you probably get an explosion to go with it. Temp has got over 100 and I have had hands puking out the window and off the floor. When your tripping pipe in these suits, its 100+, what are we suppose to do, shut down the rig and wait til dusk? I really think these suits are going to cause more health problems/deaths, then prevent them.

Mon, Jun 13, 2011 Kim

As a secretary for an oilfield company and a nurse of 20 years, I find it hard to believe that anyone passing this has ever acutally been in the oilfield while wearing FRC's. If it is appropriate and warranted, then fine, but seriously, these folks making the decisions need to run around outside of their air conditioned office and see what hell they are putting the "real hands" through. The benefits are not worth the risk that they are taking with these peoples lives.

Mon, May 30, 2011 Oklahoma

I think it's pathetic the you people say everyone must wear frc always. Apparently you spend your time in an air conditioned office and have no clue how hot it gets here. I hope you plan to be held responsible for heat strokes and death from overheating. The people who have actually been burned are a very minute number. They are usually caused by people being stupid. You can wear all the crap you want but you can't fix stupid. I ve been in all phases of oil and gas work and I still am. Never have I seen anyone burned in any way for almost thirty years. There are some jobs I do wear frc and I m all for it when it's necessary. But you people are borderline communist. Get educated. Look at statistics before spewing some horse *** law out of your mouths.more people will overheat than ever got burned. Put some frc on and go do some hard work in the hundred plus degree heat for a week and see if you still believe that's best. Do you people own stock in an frc company. Seriously. Please email me back

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