PPE Hazard Assessment For US Onshore E&PRick Ingram, S.G.E.OSHA VPP AdvisorBP North America Gasrickey.email@example.com Permian Basin STEPS Network Meeting October 11, 2011
Collaborate • Research • Standardize • Simplify • Educate National STEPS Network Creating the Safest Industry in Industry WOGISA KO:2011 • >1000 companies • > 4000 members • growing KO: 2012? Fatality Rate in South Texas has dropped from 8 to 1
4 Corners May 5, 2011 • OSHA Factsheet: www.OSHA.gov • PPE Standard; 1910.132.d • Training Requirements; 1910.132.f • FRC and the Oil patch – The Memorandum • How To: ABC’s of PPE Hazard Assessment • Examples of a PPE Hazard Assessment • A NIOSH Study: Unseen Hazards • Back-up slides: NFPA
OSHA, The US Oil patch & FRC AESC, IADC, National Steps Network, API and Attended a meeting with OSHA in Washington, D.C. on August 16, 2010 and followed up on September 21, 2011 OSHA is Joining a work team in Houston to develop a Recommended Practice Updated information will be shared upon request.
OSHA, The US Oil patch & FRC Enforcement Policy for Flame-Resistant Clothing in Oil and Gas Drilling, Well Servicing and Production-Related Operations A Memorandum was issued on March 19, 2010 by Richard Fairfax, Director of Enforcement Programs The Memorandum was intended to clarify OSHA’s policy for citing the general industry standard for personal protective equipment (29 CFR 1910.132(a)) for failure to provide and use FRC
PPE & Worker Protection Personal Protective Equipment PPE comes in at third place in OSHA’s Hierarchy of means to protect workers. “Eliminate Control and Protect” PPE is the Last Line of Defense
From the OSHA PPE Factsheet • Engineering controls involve physically changing a machine or work environment. • Administrative controls involve changing how or when employees do their jobs. • Work practices involve training workers how to perform tasks in ways that reduce their exposure to workplace hazards.
From the OSHA PPE Factsheet As an employer, you must: • Assess your workplace to determine if hazards are present that require the use of PPE. • If such hazards are present, you must: • Select PPE and require employees to use it • Communicateyour PPE selection decisions to your employees • and select PPE that properly fits your workers.
The OSHA Standard: 1910.132(a) Protective Equipment 1910.132(a) Application. Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.
The OSHA Standard: 1910.132(b), (c) Employer Responsibility, Design • 1910.132(b) Employee-owned equipment. Where employees provide their own protective equipment (i.e. Boots),?? Who is responsible?? the employer shall be responsible to assure its adequacy, including proper maintenance, and sanitation of such equipment. 1910.132(c) Design. All personal protective equipment shall be of safe design and construction for the work to be performed.
OSHA Standard: 1910.132(d) Hazard assessment and equipment selection. 1910.132(d)(1) The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).
OSHA Standard: 1910.132(d) Hazard assessment and equipment selection. • If such hazards are present, or likely to be present, the employer shall: • 1910.132(d)(1)(i) Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
OSHA Standard: 1910.132(d) Hazard assessment and equipment selection. 1910.132(d)(1)(ii) Communicate selection decisions to each affected employee; and, 1910.132(d)(1)(iii) Select PPE that properly fits each affected employee. Note: Non-mandatory Appendix B contains an example of procedures that would comply with the requirement for a hazard assessment.
1910.132(d) Hazard assessment and equipment selection 1910.132(d)(2) The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment. What if OSHA Asks? Demonstrate Compliance
How To: PPE Hazard Assessment Basics Make a list: A Simple Spreadsheet will work • List the different types of tasks: • Use JSA’s, Incidents, Near Misses, Industry Data • List the potential hazards within the tasks • List the PPE needed to help protect • Research the specific PPE needed • Involve the employees performing the work • Add a certification and date • Most effective are Craft Specific • Make it a living document and Post it • Use it to develop better JSA’s • Continually Improve the list • Use it for training
OSHA Standard: 1910.132(e) Hazard assessment and equipment selection. 1910.132(e) Defective and damaged equipment. Defective or damaged personal protective equipment shall not be used.
OSHA Standard: 1910.132(f)(1)Training 1910.132(f)(1) The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following: 1910.132(f)(1)(i) When PPE is necessary; 1910.132(f)(1)(ii) WhatPPE is necessary; 1910.132(f)(1)(iii) How to properly don, doff, adjust, and wear PPE; 1910.132(f)(1)(iv) The limitations of the PPE; and, 1910.132(f)(1)(v) The proper care, maintenance, useful life and disposal of the PPE.
1910.132(f)(2)Training 1910.132(f)(2) Each affected employee shall demonstrate an understandingof the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE.
1910.132(f)(3) Training 1910.132(f)(3) When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (f)(2) of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where:
1910.132(f)(3) Training 1910.132(f)(3)(i) Changes in the workplace render previous training obsolete; or 1910.132(f)(3)(ii) Changes in the types of PPE to be used render previous training obsolete; or 1910.132(f)(3)(iii) Inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill.
1910.132(3)(f)(4) Training 1910.132(f)(4) The employer shall verify that each affected employee has received and understood the required training through a written certification that contains the name of each employee trained, the date(s) of training, and that identifies the subject of the certification.
Payment for PPE 1910.132(h)Payment for protective equipment.1910.132(h)(1) Except as provided by paragraphs (h)(2) through (h)(6) of this section, the protective equipment, including personal protective equipment (PPE), used to comply with this part, shall be provided by the employer at no cost to employees. 1910.132(h)(2) The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job-site.
Payment for PPE 1910.132(h)(4) The employer is not required to pay for:1910.132(h)(4)(i) The logging boots required by 29 CFR 1910.266(d)(1)(v);1910.132(h)(4)(ii) Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots; or1910.132(h)(4)(iii)Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen.
Payment for PPE 1910.132(h)(5) The employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE. 1910.132(h)(6) Where an employee provides adequate protective equipment he or she owns pursuant to paragraph (b) of this section, the employer may allow the employee to use it and is not required to reimburse the employee for that equipment. The employer shall not require an employee to provide or pay for his or her own PPE, unless the PPE is excepted by paragraphs (h)(2) through (h)(5) of this section.
Payment for PPE 1910.132(h)(7) This paragraph (h) shall become effective on February 13, 2008. Employers must implement the PPE payment requirements no later than May 15, 2008.Note to § 1910.132(h): When the provisions of another OSHA standard specify whether or not the employer must pay for specific equipment, the payment provisions of that standard shall prevail.
OSHA, The US Oil patch & FRC What is a Flash Fire? A flash fire is a fire that spreads rapidly through a diffused fuel, such as hydrocarbon liquids or gas, without the production of damaging pressure.
PPE Hazard Assessment Examples http://nasupplierhsse.bpglobal.com firstname.lastname@example.org Cell: 361.816.7217
PPE Selection Based on the task performed Based on hazards present Physical state – gas, liquid, solid Concentration
Where do I get this information? Material Safety Data Sheet? List of constituents and composition “Wear gloves.” “Wear respiratory protection.” Websites – Ansell Edmont (glove example); 3M respiratory protection Take field measurements of concentrations
Task: Operating mountain mover (MM), transfer belt (TB) and blender truck (BT) Mountain mover MM oper. station Blender truck operator Transfer belt Mountain mover and transfer belt moving sand to blender truck. MM and BT truck operators wore N-95 filtering face piece respirators. Mountain mover and transfer belt not operating
Task: refilling mountain mover with frac sand Hose connections from sand refill truck are made on both sides of mountain mover (MM); pressurization of MM causes fine dust to escape from MM Sand truck Mountain mover fill nozzles As opposite sides of MM are being refilled with frac sand, fine dust is released from filling nozzles
Task: operation of equipment pump trucks Diesel engines Midday: diesel particulates not highly visible despite multiple operating engines Early a.m. diesel emission cloud visible above work area due to Tyndall effect from stationary lighting sources
Task: Chemical truck operator Chemicals contained in plastic carboys, direct connections made to blender truck via mixing manifold. Workers well protected, dermal, respiratory protection used appropriately, work operations occur in open area.
NIOSH Frac Study October 20-21, 2009 - field site visit BP location - McAlester, OK September, 2010 – field site visit – Encinal, TX Chemical/work task observations for development of exposure assessment sampling strategy Silica – 40/70 frac sand transferred from Mountain Movers via transfer belt to blender truck Diesel particulate – generated from use of motive power (14 diesel engines pumper trucks) used to pressurize well fracturing fluids. Chemicals – review of MSDS’s, observation of use & handling of chemical products used in well fracturing operations
NFPA 2113-07-FRC A.3.3.16 Definition: Flash Fire. A flash fire requires an ignition source and a hydrocarbon or an atmosphere containing combustible, finely divided particles (e.g., coal dust or grain) having a concentration greater than the lower explosive limit of the chemical. Both hydrocarbon and dust flash fires generate temperatures from 538°C to 1038°C (1000°F to 1900°F).
NFPA 2113-07-FRC The intensity of a flash fire depends on the size of the gas or vapor cloud. When ignited, the flame front expands outward in the form of a fireball. The resulting effect of the fireball’s energy with respect to radiant heat significantly enlarges the hazard areas around the gas released. Additional information describing flash fires is provided in Assessing Flame-resistant Clothing Use, CMA Manager’s Guide.
NFPA 2113-07-FRC Chapter 4 : Selection 4.1 General. The organization’s selection process for flame resistant garments shall be based on the following: (1) The conduct of a hazard assessment of the workplace to determine the need for the wearing of flame-resistant garments (2) An evaluation of flame-resistant garment designs and characteristics to determine the type of flame-resistant garments suitable for protecting workers from flash fire (3) The development of specifications for purchasing flame resistant garments
NFPA 2113-07-FRC 4.2* Workplace Hazard Assessment. 4.2.1 The organization shall conduct a hazard assessment of the work environment to determine the requirement for wearing flame-resistant garments.
NFPA 2113-07-FRC 4.2.2 The hazard assessment shall be performed based on a review of the facility to determine if flammable materials are present in quantities that will generate a flash fire and endanger a person. (3) The potential for the task being performed to increase the possibility of a flammable release; this could result from a mechanical failure such as a line breaking. (4) Operating conditions of the process — that is, potential for flammable fumes or vapors, and so forth.
NFPA 2113-07-FRC (5) The presence of engineering controls designed to reduce exposure to flammable materials present during normal operations (6) Accident history (7) Means and duration ofegress within potential exposure zone (e.g., location and distance to exits, potential congestion, elevated or restricted areas, connections to lifelines/ fall protection, capability of workers to escape, etc.)
NFPA 2113-07-FRC 4.2.3* The general workplace hazard assessment process shall include consideration of the following: (1) Determination of the type of hazard or hazards present in the workplace and the potential magnitude and duration of the hazard (2) Determination of the adverse effects of unprotected exposure to the hazards identified (3) Determination of whether other control options (engineering, administrative, and so forth) can be used instead of flame-resistant garments
NFPA 2113-07-FRC (4) Determination of garment performance characteristics needed for protection. (5) Determination of the need for garment decontamination where applicable. (6) Determination of ergonomic constraints of work to be performed while wearing the garment. (7) Comparison of risks and costs of all options. (8) Implementation of selected option (s)