2. OSHA Oil and Gas REP Overview Megan Meagher Compliance Assistance Specialist (303) 844-5285 x105

3. What we will cover Region VIII Oil and Gas REP –History –Statistics –Most Common Violations –How it Works Focused Inspection Directive Cooperative Programs

4. Local Emphasis Program Initiated in response to previous OSHA Strategic Management Plan which identified oil and gas field servicing operations (SIC 138) as one of 7 high hazard industries. Denver Area Office began Local Emphasis Program (LEP) in spring of 2004. Program covered only northern Colorado jurisdiction

5. Regional Emphasis Program Targeting program adopted as region-wide enforcement program in FY 2005 Expanded to cover all of Colorado, Montana, North and South Dakota Includes the following SIC’s: –1381 – Oil and Gas Well Drilling Services –1382 – Exploration –1389 – Field Support Services

6. Why Oil and Gas? Standard Industrial Classification (SIC) Code - 138 –2006 BLS Fatality Rate for All Industries = 4.2 –2006 BLS Fatality Rate for SIC 138 = 30.1 –Oil and Gas industry fatality rate is roughly 7.2 times the national average

7. Statistics – since beginning of LEP/REP # of Inspections *With Citations # of Accidents (since 5/04) # of Accidents (5/98 – 5/04) Total 3321482419 Colorado 2791151415 Montana 251331 North Dakota 282073 South Dakota 0000 *Includes open inspections for which citations may not yet be determined

8. Most Common Violations (Region VIII) 5(a)(1) 1910.23(c)(1) 1910.151(c) 1910.212(a)(1) 1910.132(a) 1910.23(a)(8) 1910.132(d)91) 1910.184(e)(1) 1910.133(a)(1) 1910.134(d)(1)(iii) 1910.134(e)(1) 1910.151(b) 1910.184(d) 1910.219(d)(1) 1910.219(e)(3)(i) 1910.303(f)

9. 5(a)(1) – General Duty Clause Consensus Standards –API (RP 54) – Occupational Safety for Oil and Gas Well Drilling and Servicing –API (RP 4G) – Use and Procedures for Inspecting, Maintenance and Repair of Drilling and Well Servicing Structures –AESCAESC –OSHA PUB 8-1.8 Guidelines on the Stability of Well Servicing Derricks

10. Most Common Violations (Colorado) 5(a)(1) 1910.23(c)(1) 1910.151(c) 1910.212(a)(1) 1910.23(a)(8) 1910.132(a) 1910.184(e)(1) 1910.184(e)(3) 1910.219(d)(1) 1910.133(a)91)

11. Oil and Gas REP Targeting – Offices using different methods 1381 - DAO use database to target drilling activity in selected county: Garfield, Mesa or Weld (rotate selected county) –Also may stop at any observed work site 1381 & 1389 - EAO focus on zones A (San Miguel, Dolores, Montezuma, La Plata counties), B (Las Animas county), C (Baca Cheyenne, Kiowa and Prowers counties) –May inspect any observed work in targeted zone; rotated periodically

12. Oil and Gas REP 1382 & 1389 – DAO will use database to identify any establishments in these SIC codes Randomized inspection list created Opening conference held at office and inspection site selected based on active work locations Will also be included in any inspection of employer in SIC 1381 if onsite

13. Inspection Focus Limited to employers with more than 10 employees Comprehensive safety inspection, any observed health hazards also included

14. New CPL 02-00-146 Focused Inspection Directive Effective Date 3/6/08 NAICS codes 213111/213112 included in directive

15. Focused Inspection Directive Sites can qualify for focused inspection based on having lower DART and DAFWII rates than national average Records must be readily available for review (3 year review)

16. DART/DAFWII Rates IndustrySIC/NAICS2006 DART2006 DAFWII Oil and Gas Well Drilling and Services Drilling Oil and Gas Wells 1381/2131112.81.6 Support Activities for Oil and Gas Operations 1382 & 1389/213112 1.91.3

17. 5 Inspections falling within Category 2 only qualify for focused status if two or more of the DART rates are at or below the national average AND the two most recent complete year DAFWII rates show a declining trend.

18. Inspection Focus

19. Cooperative Programs Alliances –Usually association based agreements to work together to make improvements in safety and health for an industry Local Alliances –OSHA and Mountain States Energy Alliance –Proposed alliance with Western Slope Safety Council

20. Resources Industry Standards Colorado Newsletter www.osha.gov –Oil and Gas e-Tool –OSHA Technical Manual Section IV, Chapter 1 OSHA Offices –800-321-OSHA

21. QUESTIONS??

22. Disclaimer This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at www.osha.gov.