Safe Tank Alliance - Annual Report - June 29, 2006

ALLIANCE ANNUAL REPORT
The Occupational Safety and Health Administration (OSHA) and the
Safe Tank Alliance
June 29, 2006

  1. Alliance Background

    Date Signed

    March 22, 2004

    Evaluation Period

    March 29, 2005 - March 28, 2006

    Overview

    Through the OSHA and Safe Tank Alliance, OSHA, American Petroleum Institute (API) and National Fire Protection Association (NFPA) are promoting safe tank entry, cleaning, maintenance, and rescue operations and work within and around petroleum and petrochemical liquid storage tanks. The workers include, but are not limited to, tank owners and operators, tank maintenance and repair workers, tank contractors and rescue personnel.

    Implementation Team Members

    OSHA:

    Jess McCluer
    Office of Outreach Services and Alliances
    Terry Meisinger
    Office of Small Business Assistance

    API:

    William J. Erny
    Manager of Safety Programs, Regulatory Affairs Department
    Karen Haase
    Senior Regulatory Analyst

    NFPA:

    Guy R. Colonna
    Assistant Vice President, Fire Protection Applications & Chemical Engineering

    Contributors

    Kristi Dearing
    Contractor for OSHA, Salt Lake Technical Center (SLTC)

  2. Implementation Team Meetings

    July 14, 2005
    Meeting, OSHA, Washington, DC
    September 21, 2005
    Teleconference, Safe Tank Module
    November 16, 2005
    Meeting, OSHA, Washington, DC
    December 14, 2005
    Teleconference, Safe Tank Module
    February 14, 2006
    Teleconference, Safe Tank Module
    March 23, 2006
    Meeting, API, Washington, DC

  3. Results

    1. Events and Products

      Outreach and Communication Goals

      • Encourage petroleum and petrochemical industry workers including tank owners and operations supervisors, tank repair and maintenance supervisors, tank contractor supervisors and confined space rescue leaders to take the OSHA train-the-trainer course on occupational safety and health standards and to carry that knowledge back into field to train operators, workers and rescuers in safe work practices in the petroleum and petrochemical liquid storage industry.

      The OSHA and Safe Tank Alliance Implementation Team has not started work on programs or projects to address this goal.

      • Share information on best practices and lessons learned, as jointly determined by OSHA, API, and NFPA, with others in the industry and publicize the results through outreach by API and through OSHA-, API- or NFPA-developed training programs and materials.

      Events

      Safe Tank Entry Best Practices Seminar

      OSHA and the Safe Tank Alliance developed and held a one and half day Safe Tank Entry Best Practices Seminar on April 7-8, 2005 at the API member facility, ChevronTexaco Richmond Technology Center in Richmond, California. More than 80 representatives from the OSHA and Safe Tank Alliance, joined refinery professionals, OSHA National Office and Region X staff; along with Alaska and California State Plan State participants to hear technical presentations on safe work practices, lessons learned and new technology being used by the oil and gas industry during tank entry and cleaning operations. Lee Anne Jillings, Director Office of Outreach Services and Alliances (OOSA), USDOL-OSHA made a presentation; “Confined Space Safety Statistics.” The attendees also participated in a half-day tour of ChevronTexaco's facility.

      During the tour, a special emphasis was placed on above ground petroleum storage tank operations.

      Products

      Confined Space and Hot Work Brochures

      OSHA and Safe Tank Alliance member, NFPA is updating a maritime-oriented hot work and confined space brochure so that it can be used by the petrochemical industry. The hot work brochure will address the hazards associated with flame producing activities like welding and spark producing activities such as drilling. The confined space brochure will focus on the recognition, evaluation and control of confined space hazards.

      Fall Protection Fact Sheet on Safe Tank Entry

      OSHA and Safe Tank Alliance member, API is developing a fall protection fact sheet on Safe Tank Entry. The fact sheet will focus on preventing falls near above ground storage tanks.

      OSHA Potential Flammability Hazard Associated with Bulk Transportation of Oilfield Exploration and Production Waste Liquids Safety and Health Information Bulletin (SHIB)

      API reviewed and provided OSHA with comments on the Agency's draft Potential Flammability Hazard Associated with Bulk Transportation of Oilfield Exploration and Production Waste Liquids SHIB. OSHA is revising the document and will provide it to API for additional comments.

      • Develop and disseminate information through print and electronic media, including electronic assistance tools and links from OSHA's, API's, and NFPA's Web sites.

      Products

      OSHA and Safe Tank Alliance Web page

      OSHA is continuing to update the OSHA and Safe Tank Alliance Web page that is posted on the Agency's Web site. It includes the OSHA and Safe Tank Alliance agreement, news releases, events and milestones and successes.

      Alliance Quarterly Review

      Information on the activities of the OSHA and Safe Tank Alliance has appeared in the Program's Alliance Quarterly Review. For more information on the article, see the “Alliance Program Reach”.

      OSHA's Electronic Assistance Tools

      The following API and NFPA staff and members continue to participate on the editorial boards and review and provide comments on the following OSHA Safety and Health Topics pages and eTools:

      Oil and Gas Well Drilling and Servicing Safety and Health Topics page:

      • Ray Cook, Marathon Oil; Houston, TX
      • Bill Erny, API, Washington, DC
      • Lane Smith, Chevron Texaco; Houston, TX

      Confined Spaces Safety and Health Topics page:

      • Guy R. Colonna, P.E., NFPA, Quincy, MA

      Oil and Gas Well Drilling and Servicing eTool:

      • Bill Erny, API, Washington, DC
      • Lane Smith, Chevron Texaco; Houston, TX
      • Ray Cook, Marathon Oil, Houston, TX
      • Charlie Curlee, Marathon Oil, Houston, TX
      • Joe Sologub, Marathon Oil, Houston, TX

      Storage Tank module for the OSHA Oil and Gas Well Drilling and Servicing Safety and Health Topics page

      Through the OSHA and Safe Tank Alliance, API and NFPA members and staff are reviewing and providing comments on the draft Storage Tank module for the OSHA Oil and Gas Well Drilling and Servicing Safety and Health Topics page. As part of this addition, the topics page will be renamed to OSHA's Oil and Gas Well Drilling, Servicing and Storage Safety and Health Topics page.

      • Speak, exhibit, or appear at OSHA or industry conferences such as the API/NFPA Safety Tank Entry Workshop.

      Events

      API Safety & Fire Protection Sub-committee, May 2, 2005, Washington, DC

      Lee Anne Jillings, Director, OOSA, USDOL-OSHA and Jess McCluer, Program Analyst, OOSA, USDOL-OSHA updated the API Safety & Fire Protection Sub-committee on May 2, 2005 about the OSHA Alliance Program and activities of the OSHA and Safe Tank Alliance.

      API Contractor Management Conference, November 17-18, 2005, Austin, Texas

      Joann Natarajan, Compliance Assistance Specialist, Region VI Austin Area Office, USDOL-OSHA and Ron Tom, Texas Workers Compensation Commission, Workers' Safety and Health Division, staffed an OSHA and Safe Tank Alliance exhibit at the API Contractor Management Conference on November 17-18, 2005 in Austin, Texas.

      • Promote and encourage the petroleum and petrochemical industry's participation in OSHA cooperative programs such as compliance assistance, the Voluntary Protection Programs, and Consultation and its Safety and Health Achievement Recognition Program.

      Events

      2005 Storage Tank Management and Technology Conference and Safe Tank Entry Workshop, October 24-27, 2005, Phoenix, Arizona

      Ernie Miller, Industrial Hygiene Consultant, Arizona Department of Occupational Safety and Health, made a presentation on OSHA's Onsite Consultation Program to 35 attendees at the 2005 Storage Tank Management and Technology Conference and Safe Tank Entry Workshop on October 25, 2005 in Phoenix, Arizona.

    2. Executive Summary

      Through the OSHA and Safe Tank Alliance, OSHA, API and NFPA are continuing to work together to promote safe tank entry, cleaning, maintenance, and rescue operations and work within and around petroleum and petrochemical liquid storage tanks. This positive relationship has led to the development of products that the team is sharing with the public:

      • OSHA and the Safe Tank Alliance developed and held a one and half day Safe Tank Entry Best Practices Seminar at the API member, ChevronTexaco Richmond Technology Center in Richmond, California. More than 80 representatives from the Safe Tank Alliance, joined refinery professionals, OSHA National Office and Region X staff; along with Alaska and California State Plan State participants for a full day of presentations and a half-day tour of the ChevronTexaco facility with special emphasis on entry into above ground petroleum storage tanks.

      In addition, OSHA, API and NFPA representatives are sharing their expertise through participating on OSHA's electronic assistance tools' editorial boards and speaking and exhibiting opportunities. For example:

      • API and NFPA members and staff are continuing to serve on OSHA's Confined Space and Oil and Gas Well Drilling and Servicing Safety and Health Topics and eTool editorial boards.

      • API and NFPA members and staff are reviewing and providing comments on the draft Storage Tank module which will be added to the OSHA Oil and Gas Well Drilling and Servicing Safety and Health Topics page.

      • Lee Anne Jillings, Director, OOSA, USDOL-OSHA and Jess McCluer, Program Analyst, OOSA, USDOL-OSHA updated the API Safety & Fire Protection Sub-committee about the OSHA Alliance Program and activities of the OSHA and Safe Tank Alliance.

      • Ernie Miller, Industrial Hygiene Consultant, Arizona Department of Occupational Safety and Health, made a presentation on OSHA's Onsite Consultation Program to 35 attendees at the 2005 Storage Tank Management and Technology Conference and Safe Tank Entry Workshop.

      • Joann Natarajan, Compliance Assistance Specialist, Region VI Austin Area Office, USDOL-OSHA and Ron Tom, Texas Workers Compensation Commission, Workers' Safety and Health Division, staffed an OSHA and Safe Tank Alliance exhibit at the API Contractor Management Conference.

      In addition, API and NFPA are developing several products for OSHA to review and provide recommendations on in 2006. These include the hot work and confined space brochures and fall protection for safe entry fact sheet. API and NFPA also are working to update their Web sites to include a specific section to promote the OSHA and Safe Tank Alliance. Finally, API and NFPA expressed interest in renewing the Alliance with OSHA and would like to add the Steel Tank Institute as a signatory.

    3. Alliance Program Reach

      Type of Activity (Conference, Training, Print and Electronic Distribution, etc.) Number of Individuals Reached or Trained
      OSHA and Safe Tank Alliance Web page on OSHA's Web site 5,253
      Oil and Gas Well Drilling and Servicing Safety and Health Topics page 24,915
      Oil and Gas Well Drilling and Servicing eTool 24,606
      Confined Spaces Safety and Health Topics page 85,143
      April 7-8, 2005 Safe Tank Entry Best Practices Seminar, Richmond, California

      Speaker: Lee Anne Jillings, Director, OOSA, USDOL-OSHA      		 80
      May 2, 2005 API Safety & Fire Protection Sub-committee, Washington, DC

      Speakers: Lee Anne Jillings, Director, OOSA, USDOL-OSHA and Jess McCluer, Program Analyst, OOSA, USDOL-OSHA      		 15
      2005 Storage Tank Management and Technology Conference and Safe Tank Entry Workshop, October 24-27, 2005, Phoenix, Arizona

      Speaker: Ernie Miller, Industrial Hygiene Consultant, Arizona Department of Occupational Safety and Health      		 35
      API Contractor Management Conference, November 17-18, 2005, Austin, Texas

      Alliance Program Exhibit      		 120
      September 2005 - "Safe Tank Entry, Tank Design Focus of Safety Seminar," Alliance Quarterly Review 300
      TOTAL 140,467

  4. Upcoming Milestones

    The OSHA and Safe Tank Alliance Implementation Team has discussed a number of activities that will be undertaken in the upcoming year. In addition, API and NFPA will continue to work with OSHA and will sign an OSHA and Safe Tank Alliance renewal agreement. The Alliance is being expanded and The Steel Tank Institute is being added as a signatory.

    During the upcoming year, the Alliance is interested in developing a second Safe Tank Entry Best Practices Seminar through the OSHA and Safe Tank Alliance. It would be a one day seminar focusing on topics including, emergency preparedness and lessons learned from Hurricane Katrina. The seminar would be followed by a full day of classes on specific topics such as, fall protection, lockout/tagout and personal protective equipment.

    In addition, the Alliance's representatives from the signatory organizations will continue to be members of OSHA's Confined Space and Oil and Gas Well Drilling and Servicing Safety and Health Topics pages and eTool editorial boards and review and provide comments on the resources. In addition, the implementation team will continue to develop the Storage Tank module for the OSHA Oil and Gas Well Drilling and Servicing Safety and Health Topics page.

    NFPA will also complete the draft petrochemical confined space brochure and share it with OSHA for feedback. API will complete the fall protection fact sheet for safe tank entry. API will also review OSHA's updated draft Potential Flammability Hazard Associated with Bulk Transportation of Oilfield Exploration and Production Waste Liquids SHIB.

    The OSHA and Safe Tank Alliance will continue to promote the activities of the Alliance and provide information on OSHA's cooperative programs through exhibits and presentations. API and NFPA agreed to have two seats available, at no charge, for OSHA attendees at the NFPA and API Confined Space workshops in Spring 2006. Region II has expressed interest in attending the April 27-28, 2006 workshop in Atlantic City.

    On June 6, 2006, Lee Anne Jillings, Director, OOSA, USDOL-OSHA, will make a presentation on OSHA's cooperative and compliance assistance programs, with a particular focus on the Safe Tank Alliance at the NFPA World Safety Congress and Exposition, on June 4-8, 2006, in Orlando, Florida.

    Finally, OOSA will provide publications promoting OSHA's cooperative programs and compliance assistance materials at the API 2006 Storage Tank Management and Technology Conference and Safe Tank Entry Workshop on September 25-28, 2006 in Tulsa, Oklahoma.

Report prepared by: Jess McCluer, Alliance Coordinator, Office of Outreach Services and Alliances, June 29, 2006.