PT Notes
OSHA RFI - Oil-Well and Gas-Well Drilling and Servicing and Production Facilities
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On December 3, 2013, the U.S. Occupational Safety and Health Administration (OSHA) announced a request for information (RFI) seeking public comment on potential revisions to its Process Safety Management (PSM) standard. Multiple issues were addressed in the RFI.
One issue deals with oil-well and gas-well drilling and servicing. Paragraph (a)(2)(ii) of the PSM standard exempts oil-well and gas-well drilling and servicing operations from PSM coverage. The preamble to the standard explained that OSHA excluded these operations because it had begun a separate rulemaking for oil-well and gas-well drilling and servicing operations. However, OSHA subsequently removed these operations from its regulatory agenda and never promulgated a final rule for them. Consequently, OSHA is requesting public comment on whether to retain or remove the exemption.
OSHA has posed these questions on the issue in the RFI:
- If your facility conducts oil-well and gas-well drilling or servicing operations not covered under the PSM standard, do you treat these activities as covered by the PSM standard for safety or other reasons? Are the activities covered under other federal or state regulations?
- Would removing the exemption for oil-well and gas-well drilling and servicing operations prevent worker injuries and fatalities? What would be the economic impact of removing the exemption? Are there any special circumstances involving small entities that OSHA should consider with respect to this option?
Another issue deals with oil-production and gas-production facilities. The exemption in Sec. 1910.119(a)(2)(ii) does not extend to oil-well and gas-well production operations and a 1999 memo from the OSHA Compliance Programs Director to OSHA regional administrators explained that production facilities were always intended to be covered under PSM.
The memo described covered production operations as a phase of well operations that deals with bringing well fluids to the surface, separating them, and then storing, gauging and otherwise preparing the product for the pipeline. The production phase occurs after a well has been drilled, completed, and placed into operation, or after it has been returned to operation following workover or servicing. A completed well includes a "Christmas tree" (control valves, pressure gauges and choke assemblies to control the flow of oil and gas) which is attached at the top of the well where pressure is expected. It is at this point, the top of the well, where OSHA states that the covered PSM process begins. The distance between separation equipment and the well is not a factor when determining PSM applicability for production facilities.
The American Petroleum Institute objected to the 1999 memo on the grounds that PSM coverage of oil-production and gas-production facilities was invalid because OSHA did not conduct an economic analysis addressing such coverage during the original PSM rulemaking proceedings. OSHA conceded the point and suspended enforcement of the PSM standard for oil-production and gas-production operations pending performance of the analysis.
OSHA is now considering completing this economic analysis so that it can resume enforcement of the PSM standard for oil production and gas production facilities. OSHA believes that implementation of an effective PSM program in accordance with the requirements of the PSM standard by oil-production and gas-production facilities could prevent or mitigate accidents.
OSHA has posed these questions on the issue in the RFI:
- If your facility is conducting oil-production and gas-production operations for which OSHA is not currently enforcing PSM requirements, do you follow PSM requirements for these operations for safety or other reasons? Are the activities covered under other federal or state regulations?
- What would be the economic impact of resuming enforcement of the PSM standard for oil-production and gas-production facilities? Are there any special circumstances involving small entities that OSHA should consider with respect to this option?
Also, OSHA has asked for employers to provide any data or information on workplace accidents, near misses, or other safety-related incidents involving oil-and gas-well drilling or servicing operations and oil-production and gas-production facilities.
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