Energy Symposium 2010 - Worm Session 08/12/2010 When Safety on the Rig Comes Falling Down - Jacqueline Armstrong 1 When Safety on the Rig Comes Falling Down How to Work with an OSHA Compliance Officer after an Injury or Fatality Course Objective • Participants will learn: • What steps to follow after an injury or fatality at a rig and • What steps to take to document the event during an inspection by an OSHA Compliance Officer. • What is OSHA? • OSHA Standards are Law • Region VI Areas of Interest • Fatality‐ OSHA Rules about Contact • Walk Around with the OSHA Compliance Inspector and Document the Inspection • Citation, Conference Course Outline
Transcript
Energy Symposium 2010 - Worm Session 08/12/2010
When Safety on the Rig Comes Falling Down -Jacqueline Armstrong 1
When Safety on the Rig Comes Falling Down
How to Work with an OSHA
Compliance Officer after an Injury or
Fatality
Course Objective• Participants will learn:
• What steps to follow after an injury or fatality at a rig and
• What steps to take to document the event during an inspection by an OSHA Compliance Officer.
• What is OSHA?
• OSHA Standards are Law
• Region VI Areas of Interest
• Fatality‐ OSHA Rules about Contact
• Walk Around with the OSHA Compliance Inspector and Document the Inspection
• Citation, Conference
Course Outline
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What is OSHA?
What is OSHA?
• Occupational Safety and Health Administration
• Developed in 1970 • Standards are Law • Responsible for Worker Health and Safety in
United States
OSHA Standards are Law
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• OSHA Standards are found in the Code of Federal Regulations (CFR)
• Most of the Oil and Gas Industry Safety Regulations are taken from the CFR 1910 General Industry
• Some of the Safety Regulations are from the CFR 1926 Construction
• Failure to follow the CFR may result in Fines, Penalty, and or imprisonment.
OSHA Standards are Law
Region VI• Meet your Area Director before any
inspection. »North Area Director-
Mr. David Doucet»South Area Director-
Mr. Mark Briggs
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Region VI – OSHA Key Areas of Interest
• Each Area Director for OSHA has key regional areas of interest
• As a result of fatalities, or trends in reportable injuries, a clue to inspection focus.
Region VI-Houston Area of Interest
Construction - Hispanic Workers
Fall Protection (Fatality Rates Highest in this area, lack of training, language barrier, signs, fall arrest systems)
Equipment that can cause amputation
Ammonia – Process Safety Management (PSM) Cold Refrigeration Equipment
OSHA Inspections May be Scheduled or UnscheduledOSHA Inspections May be Scheduled or Unscheduled
Inspections may be required due to an observed imminent danger, reported site injury, fatality,
employee complaint, follow up , or they may be unscheduled inspections.
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Fatality- Contact OSHA• If your site has a Fatality you have to contact the
local area Office and speak to a Compliance Office, to report it.
• Record all accidental injuries that are occupational on the 300 Log Form.
• Report to OSHA if you have more than 3 injuries that require hospitalization, or a fatality, within 8 business hours
Potential Hazards and Sources of Events
• Struck by falling pipe
• Caught in tongs, chains, drill string
• Struck by spinning chain, kelly, rotary table, high pressure hose
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Potential Hazards and Sources of Events
Fire from well blow out, drilling, swabbing (release of gas) uncontrolled ignition sources near the well head, heater in doghouse, electrical equipment
When the Rig Comes Down
When the Rig Comes DownIf an event results in a fatality, take
care of the worker’s body first.
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When the Rig Comes DownHave someone document the scene for your files and then have the ambulance come in and remove the body.
You do not have to wait for OSHA to arrive before removing the body. They may have a long drive/flight
Preserve evidence at the scene, and barricade
When the Rig Comes DownTake care of the other employees
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When the Rig Comes Down
• Take care of the other employees
• Some employees may need to be taken home, do not risk other injuries while employees are distracted and upset
• Be sensitive to shock that employees may experience
• Record all names and witness statements while information is fresh.
When the Rig Comes DownFollow your company’s crisis plan for
media interaction
Prepare statements that can be used by the media crisis team, anticipate news media coverage and be aware that OSHA will also monitor what statements were given to the new media.
OSHA will determine if your company changed statements and will investigate
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If the CSHO is responding to an event, then remember:
• Your first priority is the safety of your personnel
• Medical treatment is your first responsibility for the employee (s)
• Follow your Incident Command Procedures
• Get everyone out of harm’s way
• Get control of the situation
• Secure the area
Prior to the OSHA InspectionYou Should Document Everything
• Preserve evidence• Do not remove any structure on any piece of equipment that
was involved in an event.
• Remove equipment that is necessary to free an injured person from the parts that may trap them or they may be caught in.
• Take photos of an injured body part
If an Event Involved an Injury and Equipment:
Be prepared for all Documents to be searched such as:• Maintenance records, • Inspection lists for:
• daily, • weekly, • monthly, • quarterly checks,
• Lock Out Tag Out records, • Hot work, • Work permits
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• Standard Operating Procedures (SOP)• Training Records• Daily meeting records• Emergency Action Plans,
– Record of drills
If an Event Involved an Injury and Equipment:
Be Prepared to Verify Permit Procedures
Employee Complaints-OSHA Inspections
Employee Complaints-OSHA Inspections
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• Disgruntled Employees
• Employees who have been terminated
• They may have taken photos with their cell phone and sent them to the OSHA office
• The CSHO will want to see these areas
• The CSHO may interview employees. This is when you see how effective your training has been, can the employees remember the basics of their training?
Employee Complaints-OSHA Inspections
Employee Complaints-OSHA Inspections
During the OSHA Inspection You Should Document
• Assign a scribe, someone who can take notes, recording what the CSHO says, and what your reply was to the question(s), or replies from any other employee who is interviewed
• Take photos of everything the CSHO records in photos, so you have a record of what was seen and discussed
• Have an “Action Person” ready to repair any findings ASAP. Document it. And attempt to have as many items corrected before the CSHO leaves your facilities, then inform of the correction before the CSHO leaves.
33J Armstrong 2010 August BMB Risk
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Enforce the Safety RulesDuring the
OSHA Inspection
Enforce the Safety RulesDuring the
OSHA Inspection
Enforce the Safety RulesEnforce the Safety Rules• Require the OSHA Compliance Officer to
follow the safety rules at your site.
• Have them identified, Log in, watch the safety video, issue PPE as required, inform them of the required safety PPE and procedures
• Escort them everywhere. You don’t want them to get hurt, plus you must see what they record, and document it
• Always ask them questions about what their concerns are so you can be ready to defend
Enforce the Safety RulesEnforce the Safety Rules
Be courteous
Be respectful
Answer Questions
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If you don’t know the answer, state you don’t know but that you will get back at a specific date and time with an answer
Don’t give answers if you do not know the answer.
Do Not Argue.
During the OSHA Inspection You Should Document Everything
During the OSHA Inspection You Should DocumentDuring the OSHA Inspection You Should Document
• Have someone ready to retrieve any document the CSHO asks to view or to have it sent to the OSHA Office.
• For example: If the CSHO asked if the employee in question is trained, indicate the date of the training. Present a copy of the file showing the training dates.
• DO NOT offer to show any documents except those that were requested.
During the OSHA Inspection
Neat, organized documents that are available should be used to verify your statements. Remember when employees are interviewed they are often nervous about responding incorrectly and they may not give the best answers about context or frequency of training, because they cannot remember. If the employees have a current Training Card have them present it for inspection.
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Inspection Priorities:
Inspection Priorities:• Imminent Danger
– Any condition that can be expected to cause death or serious physical harm immediately, or before the danger can be eliminated through normal enforcement procedures.
• Fatalities and Catastrophes – Resulting in hospitalization of 3 or more employees
• Employee Complaints/Referrals• Programmed High-Hazard Inspections• Follow-ups to previous inspections
What is the Inspection Process?
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What is the Inspection Process?
• Inspection Process– CSHO displays official credentials– Opening Conference– Walk around Inspection– Closing Conference
What is the Inspection Process?
• Conducting the Walk around Inspection
– CSHO & Accompanying Representatives (employer and employee) inspect the establishment for potentially hazardous working conditions
– CSHO discusses possible corrective actions with the employer
– CSHO may consult, at times privately, with employees
What happens after the OSHA
Inspection?
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What happens after the OSHA Inspection?
• After CSHO reports findings, the area director (supervisor) determines what citations, if any, will be issued, and what penalties, if any, will be proposed.
• Citations and notices of proposed penalties are sent to employers by certified mail.
What happens after the OSHA Inspection?
• OSHA may or may not issue citations
• Citations inform employer and employees of the regulations and standards allegedly violated and of the proposed time for abatement
• Employer must post a copy of each citation at or near place where violation occurred, for 3 days or until violation is corrected, whichever is longer
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OSHA CitationsSerious
Willful
Repeat Fine includes a multiplier of each unabated violation.
De Minimus- No value Record keeping error is an example of a small findings
General Duty Clause:Each employer "shall furnish . . . a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees.“
This is the clause that allows an OSHA Compliance Office to write a citation for “anything unsafe” when no standard exists for it.
After the OSHA Report
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After the OSHA Report
• You may request an informal hearing
• You will be given a level of time to comply or to abate (correct) the safety problem.
• At the informal hearing the Area Director will indicate if you’re abatement was accepted, if any more change is needed, and your penalty reduction if any
