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.
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.