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”

Hidden Lesson From United Airlines Debacle

Quick True-or-False Question:  United Airlines kicked a passenger off one of its planes last week and, when he wouldn’t leave, the airline dragged him off the plane.

False, but you would hardly know that from reading the news reports on the incident.  In fact, it happened on a United Express flight that was operated and staffed by Republic Airways and the passenger was pulled off the plane by Chicago Department of Aviation personnel, as angry United pilots have made clear. Continue reading “Hidden Lesson From United Airlines Debacle”

Sign Up Now For Our Next Operating Procedures Classes or Attend a Free Preview This Week.

Lifeline Strategies has launched a new class on writing effective, compliant operating procedures, especially under the offshore Safety and Environmental Management Systems (SEMS) regulations.  SEMS has very specific requirements for operating procedures.   Auditors, the Center for Offshore Safety and the Bureau of Safety and Environmental Enforcement have all identified operating procedures as one of the top areas for improvement.  Make sure your company is following the rules!

Classes are scheduled for: Continue reading “Sign Up Now For Our Next Operating Procedures Classes or Attend a Free Preview This Week.”

Writing Operating Procedures: 5 Tips (plus 1) For Working With An SME

I got a surprise in teaching our first class on writing compliant operating procedures last week – The one topic that produced the most participant discussion was on how to work with Subject Matter Experts (SMEs).  Everyone in the class agreed that SMEs are critically important in developing quality procedures, but everyone also seemed to have a war story about the problems of working with an SME.  With that in mind, here are five tips (plus one extra) for making the process of working with an SME go smoothly.

Continue reading “Writing Operating Procedures: 5 Tips (plus 1) For Working With An SME”

Coast Guard Launches Newsletter For Offshore Oil and Gas Mission

The U.S. Coast Guard has been beefing up its offshore oil and gas expertise and now has launched a newsletter aimed at communicating with the offshore industry.  The newsletter, named DRILL DOWN, is produced by the Outer Continental Shelf National Center of Expertise.  The first issue came out on March 27th, quickly followed by a second newsletter a few days later. You can access them and all future newsletters by clicking here.  The first two letters are more of an introduction to the center of expertise. The Coast Guard is soliciting questions and comments from industry and the public and will use the newsletter to engage and inform on its work and interpretation of the regulations.

The OCS center was formed in 2009 to provide a focal point for subject matter expertise on offshore compliance and safety that falls under the Coast Guard’s authority.  That includes inspection of Offshore Supply Vessels (OSVs),  Mobile Offshore Drilling Units (MODUs), and Production Facilities as well as incident investigations.


Special Discount on Operating Procedures Class

Do your Operating Procedures meet the offshore SEMS rules? Are they easy to understand and use? Do they make your operations safer?  Poor operating procedures were identified as a cause of more than half of serious offshore accidents in one study and have been one of the top areas of noncompliance in SEMS audits.

Lifeline Strategies is launching a one-day class with teach people in the oil and gas industry how to create SEMS-compliant procedures, use best practices to write procedures that make sense and can become an important tool to identify and control hazards.

The first class will be held in Houston on March 28th.  For this class, we are offering  a special introductory offer of $50 per student!

The class will teach you how to:

  • Write procedures that comply with the Safety and Environmental Management Systems (SEMS) rules.
  • Follow best practices to create procedures that are easy to understand and use on location.
  • Use procedures as a powerful safety tool to identify and control hazards.
  • Manage procedures as a system.

Get more information
Register Now!
I can’t make it, but let me know about new classes.

If you would like to know about future classes or hold one at your office, contact us at Info@lifelinestrategies.com.

In addition to the class, I will be also presenting talks on using operating procedures to enhance safety twice in the next month.

Thibodeaux, LA, Tuesday, March 21:  ASSE Bayou Chapter lunch meeting, 11:30 at Nicholls State in Thibodeaux. The charge is $25 to help fund the chapter.  Register by emailing the ASSE Bayou Chapter here.

Houston, TX, Thursday, April 13:  ASSE Energy Corridor Section, Spring Creek BBQ, 2100 Katy Fwy, Katy, TX.   You do not have to be an ASSE member to attend.

Safety Agencies May See Big Cuts In New Budget

The Administration’s released its budget plan this morning.  It is called a blueprint and gives an overview rather than a detailed view.  The full budget request will come out in the next month or so,  then it is up to Congress to decide on the actual numbers.

The short message is no surprise – Increases for defense and border security with cuts in domestic programs to offset the increases.  Some of those domestic programs are closely tied to agencies that have a strong safety mission.  While the blueprint does not say exactly what will happen for most programs, it gives some picture of what may be coming when the full budget request is released.  Here’s what it looks like: Continue reading “Safety Agencies May See Big Cuts In New Budget”