Oil and Gas Well Drilling

        One of the new emerging markets for FR clothing is the oil and gas well drilling, servicing and production industry. Unlike the oil refineries and chemical plants, many of these companies have not historically been in FR clothing. Their move into FR was prompted by an OSHA memorandum on March 19, 2010. The OSHA memorandum was issued to clarify their policy for issuing citations to oil and gas well drilling industry, under the general industry standard for personal protective equipment (PPE) 29 CFR 1910.132. They referenced a history of burn-related injuries and fatalities due to flash fires in these operations, and thus concluded that their employers are required to provide and ensure the use of FR clothing.

       OSHA stated that “NFPA 2112 and 2113 applies to general industry workplaces and to drilling, well servicing, and production-related operations”. NFPA 2113 is the Standard on Selection, Care, Use, and Maintenance of Flame-resistant garments for Protection of Industrial Personnel Against Flash Fire”. This standard specifies the minimum selection criteria for FR garments shall be in compliance with NFPA 2112 which is the “Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire”. NFPA 2112 provides the minimum performance requirements for FR garments including minimum FR fabric performance, labeling requirements, garment certification requirements, garment manufacturer quality assurance programs, plus a number of other requirements. You should note that not all FR garments in the marketplace have been certified to NFPA 2112.

       As of 2011 the OSHA compliance officers were given citation guidelines that included citing 1910.132(a) for the failure to provide and ensure the use of Flame-Resistant Clothing (FRC) in this industry when their operations have a potential for flash fire hazards. Those operations include:

Drilling – During drilling operations in gas and hydrocarbon producing zones. OSHA believes there is a high potential for a flash fire.

Servicing – During servicing operations on wells involving the accessing and extracting of oil and gas. These operations present a potential a flash fire.

Production – During production operations where well fluids are brought to the surface, separated, stored, and prepared for delivery. These operations could also have the potential for a flash fire.

       OSHA feels that although each of these operations typically has engineering controls to reduce accidental releases, these controls do not entirely eliminate the possibility of a flash fire.

       To better understand why not all FR garments are created equal and the FR standards and requirements that apply, http://www.knowyourfr.com/ is a good site to visit. You’ll find videos to help learn the basics for evaluating FR garments and fabrics plus the basic requirements and performance tests for standards like NFPA 2112. There are video chapters introducing the basic hazards and standards, FR performance testing and one specifically related to flash fires and flash fire performance testing.      

       The bottom line is that starting in 2011 OSHA will be looking for oil and gas drilling, servicing and production-related operations to have their employees in a flame-resistant clothing program.