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Flame-Resistant Clothing
    And the Oilfield




       y             p
   Rocky Mountain Chapter – ASSE
          September, 2010
                  Intent
• To present the details of the OSHA
  enforcement letter
• To evaluate the impact on the oil and gas
         y
  industry
                    Agenda
•   Basis for issuing the letter
•     q
    Requirements outlined
•   OSHA citation basis
•   Impact to the industry
•   What’s next
           Oilfield Safety
– Fatality Rate is 5 times the national average
– Between 1997 and 2003 16% of the fatalities
         i in the ilfi ld          l t d to fire d
  occurring i th oilfield were related t fi and
  explosion (OSHA)
           OSHA’s Response
                          Flame-Resistant
• Enforcement Policy for Flame Resistant Clothing in Oil
  and Gas Drilling, Well Servicing and Production-Related
  Operations
                 19,                  Fairfax,
• Issued March 19 2010 by Richard Fairfax Director of
  Enforcement Programs
• 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
         Flash Fire Hazards
• A flash fire is a fire
  that spreads rapidly
  through a diffused
  fuel, such as
  hydrocarbon liquids or
         ith t the
  gas, without th
  production of
              pressure.
  damaging pressure
        Hazard Assessment
• Basic requirement of conducting a Job Hazard
  Analysis (JHA) followed by a Personal
  Protective Equipment Assessment (PPEA) to
  determine the potential need for protective
  equipment against flash fire hazards under 29
  CFR 1910.132(a).
    OSHA’s Unique Position
• OSHA concluded that engineering and
  administrative controls serve to reduce,
  but not eliminate flash fire hazards.
• OSHA concluded that employers are
                              p y
  required to provide and ensure the proper
                  p
  use of FRC in specific situations.
Drilling Operations
          • Prior to and during drilling
            in active hydrocarbon
            zones.
          • In areas where “kicks”
            can be expected.
          • Until above situations are
            controlled by the
                      g
            cementing of casing.g
    Well Servicing Operations
• During any open hole
  operations.
• Fracturing or perforating
    well.
  a well
• Flow testing, blowing
                  g
  down or venting a well.
• Any operation where the
  wellhead or wellbore is
          pressure
  under pressure.
Production Related
   Operations
         •   Maintenance of production
             equipment.
         •   Equipment start-up.
         •   Line breaking or valve
             changes.
         •   Tank gauging.
         •   H d      b      d     d
             Hydrocarbon and produced   d
             water transfer operations.
         •   Hot work operations.
           Design of FRC
• National Fire Protection Association
  (NFPA) 2112, Standard on Flame-
  Resistant Garments for Protection of
  Industrial Personnel Against Flash Fire
  provides the minimum performance and
  certification requirements for FRC.
               Certification
• Must be by a third party to the manufacturer or
      d       ith t         t
  vendor, without a monetary i t        t i the
                                 interest in th
  product’s profitability.
  Testing b             dit d laboratory t meet
• T ti by an accredited l b t             to    t
  certification.
• Garments must be labeld with certification
  statement specific to NFPA 2112.***
                  Label
• This flame-resistant garment meets the
  requirements of NFPA 2112, standard on
  flame-resistant garments for protection of
  industrial personnel against flash fire,
  2007 edition
   Selection and Care of FRC
• National Fire Protection Association (NFPA)
  2113, Standard on Selection, Care, Use and
  Maintenance of Flame-Resistant Garments for
  Protection of Industrial Personnel Against Flash
  Fire provides a standard regarding the
     l ti                 d    i t        f FRC.
  selection, care, use and maintenance of FRC
          FRC Requirement
                  per NFPA 2113

• Based on the results of a
  hazard assessment.
• Garment performance
  evaluation per specific
  need.
• Develop specifications
  for purchase.
                     FRC Selection
                             per NFPA 2113
•   Spaced thermal protective rating (TTP)
    > 25.3 J/cm2 (6.0 cal/cm2) and contact
    TTP > 12.6 J/cm2 (3 0 cal/cm2) Arc
           12 6        (3.0       ).
    Flash Hazard Category 1.
•   Cover upper and lower body and
                         y
    flammable under layers.
•   Avoid meltable closure systems.
•   Offer minimal interference with the
    work, but not tight-fitting.
•   Minimize non-flame resistant heraldry
    on exterior (logos, name tags, artwork,
    etc.)
FRC Use
per NFPA 2113

       •              t     t
           FRC as outermost garment. t
       •   Collars closed.
       •   Sleeves and cuffs down and
           secured.
       •   FRC or non-melting
           undergarments next to skin.
       •   Employee instruction.
       •    Other PPE as determined by
           JHA.
FRC Care – Cleaning
     per NFPA 2113

            •   Cleaned according t
                Cl      d       di to
                manufacturer’s
                recommendations
            •   Washed dry-cleaned at l
                W h d or d         l             t
                                         d t least
                once prior to initial use.
            •   Washed or dry-cleaned with
                    h frequency so as to
                such f                  t
                prevent build-up of
                contaminants that reduce
                       resistance
                flame resistance.
         FRC Care – Storage
                    per NFPA 2113
         p
• Stored per
  manufacturer’s
  recommendations.
  Not t d i         li ht
• N t stored in sunlight.
• Cleaned and dried before
  storage.
• Stored in well ventilated
  area and not with
           l items.
  personal it
    FRC Care – Maintenance
                  per NFPA 2113

• Employer must develop a systematic FRC
  inspection program.
  Program should i l d i
• P                             ti    ft
            h ld include inspection after eachh
  cleaning and any potential damage.
  Program must include repair or replacement
• P             ti l d       i      l        t
  procedures per manufacturer’s
  recommendations.
  recommendations
          OSHA Citations
• Failure to conduct a JHA or PPEA.
• Failure to provide FRC where employees
  have occupational exposures to flash fires.
• Failure to provide FRC that is of safe
      g
  design and construction
• Failure to assure that FRC is properly
  maintained.
  maintained
           OSHA Citations
                             employee by
• Citations to be made on an emplo ee b
  employee basis.
• Specific cite NFPA 2112 and 2113 as employer
   p                                     p y
  guidance.
         OSHA Enforcement
• Regional Emphasis
      g
  Programs (      )
             (REP) on
  various oil and gas
  operations in Regions 2
  (NY), 3 (PA & WV), 6
  (TX, OK AR LA) (KS)
  (TX OK, AR, LA), 7 (KS),
  8 (CO, UT, ND, MT) and
  10 (offshore).
• Proposed National
  Emphasis Program (NEP)
  on oil and gas drilling
   Additional Requirements
• Other PPE
• Heat Prevention Plan
          Industry Impact
• Increased cost
• Increased employee
  involvement and
  i   l       t d
  responsibility
  Increased
• I       d
  enforcement
          Recent Events
• OSHA met with the Association of Energy
  Servicing Contractors (AESC) on August
  16th at 2:00 PM EST in Washington, DC
  regarding the FRC Letter of
  Interpretation/Enforcement.
           Recent Events
• AESC requested that OSHA:
  – Withdraw its letter of
    interpretation/enforcement
                             rule making
  – Follow the established rule-making process
    with regard to FRC, including involvement of
    stakeholders
  – In the future include industry in the
    interpretation process instead of making them
    a victim
            Recent Events
• OSHA responded:
  – It is not willing to withdraw the letter of
    interpretation/enforcement
  – Are willing to involve industry in developing an
    enforcement guideline

				
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posted:4/28/2011
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Description: workers safety