Keeping Volunteers Safe During Hurricane Recovery Efforts

I had not seen a good plain English guide for volunteers who come into a hurricane area to do recovery work, so I combined a lot of OSHA and industry tips into one document: Hurricane crew safety.   I hope it is helpful.

Here in Houston, people are starting to put their lives back together.  With more than 185,000 homes damaged on the Gulf Coast, recovery will take a while.   Now Irma threatens to impact thousands of people in Florida.

Continue reading “Keeping Volunteers Safe During Hurricane Recovery Efforts”

What’s Going On With Offshore Safety?   Four Trends To Watch

In my last post I looked at the ways that the government agency overseeing offshore safety is addressing the challenge.  As a followup, here is a look at some of the trends impacting offshore safety.

The safety net is bumping into the bottom line in offshore oil and gas.  We are three years onto a truly savage downturn in prices and at least one Supermajor wonders if the phrase “lower for longer” should really be “lower forever.” Continue reading “What’s Going On With Offshore Safety?   Four Trends To Watch”

Offshore Oil & Gas Enforcement: Smarter, More Focused

The last decade has been a wild ride for offshore oil and gas in the Gulf of Mexico.   Macondo oil spill disaster.   Crash of oil prices.   New regulations like the Safety and Environmental Management (SEMS) rule.  Then there is decommissioning, a trend that which hasn’t gotten the attention it deserves.

It has been traumatic for industry, but it has also had a big impact on government regulators, who have gone through three name changes (MMS-to-BOEM-to-BSEE), four directors and a sea change in the way they do business.   So it is worth asking, how has BSEE – the Bureau of Safety and Environmental Enforcement – adapted. Continue reading “Offshore Oil & Gas Enforcement: Smarter, More Focused”

JSA Best Practices Discussion July 14th in Lafayette, LA

Very honored to be participating in a morning-long session on best practices for Job Safety Analysis at the next Gulf Coast Safety Training Group Meeting on Friday, July 14th in Lafayette, LA.

They have put together an outstanding lineup of speakers, including representatives from the Bureau of Safety and Environmental Enforcement, Chevron, Fieldwood Energy and Versa Integrity.   it is a great chance to learn best practices on JSA’s from the perspective of government regulators, large and medium oil and gas companies and contractors.

I will focus my presentation on the role of supervisors in making sure everyone understands their role in the JSA and aligning operating procedures with JSAs to supercharge your safety program.

You need to RSVP to attend.  Go to to learn more and register.

OSHA’s Silica Rule – What It Means To Oil and Gas

In about a week, OSHA’s rule on silica was supposed to go into effect for the construction industry.  However, the Administration delayed implementation until late September and the rule has also been challenged in court.

That doesn’t mean industry is off the hook however.  Silicosis kills about a hundred people a year and OSHA says more than two million American workers are exposed to harmful level of silica a year.  Without as standard on exposure, companies may avoid OSHA fines, but wind up facing liability for silicosis cases down the road.

Construction is not alone in facing a compliance deadline if the rule goes into force.   General industry and maritime will need to comply by June of next year. Oil and gas fracking operations need to comply with new engineering controls by June of 2021.    That 2021 date has caused some confusion within the oil and gas sector.  Many read it to mean that they don’t need to meet the requirement for four more years.   However, the rule actually says that fracking operations need to protect workers from silica exposure by next June, just like other general industries.    The 2021 date is when they need to adopt engineering control to limit the amount of respirable silica around drilling sites.

The chemical company ArrMaz produces a product that coats sand to reduce silica dust used in fracking operations.  The company has developed one of the best explanations of how the rule will be applied in oil and gas operations that I have seen.   You can download a copy of their graphic here: ArrMaz_Respirable Crystalline Silica_InfoGraphic.

The bottom line is that there are ways to reduce silica dust on a frack site and industry is working on other engineering solutions, but companies need to understand that the requirement to protect workers on the exposure side is likely to arrive in a year.


The Clock is Ticking: Deadline For New OSHA Fall Protection Training

It hasn’t gotten a lot of attention, but companies have just under one month to train workers in the new OSHA General Industry Walking Working Surfaces and Fall Protection Standards.  The regulation was released last November. Parts of it took effect at the start of the year, but the training requirements kick in on May 17th.

You can read an overview of the new standard here.   OSHA says the rule incorporates  advances in technology, industry best practices, and national consensus standards, as well as giving employers more flexibility about implementing some worker protections.

Training: The training provisions say employers must make sure that any workers who use personal fall protection and work in other specified high hazard situations are trained on the fall and equipment hazards, including fall protection systems.   They must be retained if there is a change in the workplace or the employee appears to lack skills and knowledge.

Training must be done by a  qualified person and must show them how to  identify and minimize fall hazards; use personal fall protection systems and rope descent systems; and maintain, inspect, and store equipment or systems used for fall protection.

Safety Stand-down:  As it happens, OSHA is holding a safety stand-down to prevent falls in construction from May 8-12.  The website for the stand-down has a wealth of information about participating and general fall protection material.   Even though it is focused on construction and the changes in the standard apply to general industry, it is a valuable resource.

What If Companies Ignore The Requirement?:  That is always a challenge with new OSHA deadlines.  There is always a chance that OSHA will call on a facility and ask to see training records as a part of the inspection.  But the real risk for companies is if there is an incident.   Falls are the leading cause of death in construction and the most cited violation.  The change in the general industry standard closely tracks construction.

In other words, falls are an ever-present danger in the workplace.  An employer who ignores the new standard and has an incident is liable to be cited for the incident, failing to update to the standard and failing to adequately train workers.   Considering the increase in penalty levels that went into effect lasts year, ignoring this update is an expensive gamble.

Update: New Classes Scheduled For Operating Procedures Class

If your company falls under OSHA, PHMSA or BSEE, chances are you need to have effective, compliant operating procedures in place.   Now there is a place to learn how to write procedures that make sense, meet compliance requirements and will make your company safer.   This is especially important in offshore oil and gas, where companies are required to have operating procedures that meet the SEMS regulations.  Auditors have identified this as one of the top areas of noncompliance with SEMS plans.

We have set up two new sessions for our Secrets to Writing Compliant, Effective Operating Procedures Class. Continue reading “Update: New Classes Scheduled For Operating Procedures Class”