Region 6 - Alliance Annual Report - November 22, 2016

The Occupational Safety and Health Administration (OSHA)
Oklahoma City Area Office
And the
Mid Continent Exploration and Production Safety Network (MCEPS)
November 22, 2016

  1. Alliance Background

    1. Date Signed

      Original Alliance signed September 9, 2007 and renewed through January 15, 2015

    2. Evaluation Period

      October 1, 2015 to Sept 30, 2016

    3. Overview

      The emphasis is on promoting worker awareness of industry-related hazards and solutions in the exploration and production of oil and gas. OSHA, MCEPS, and ODOL/Consultation are committed to improving worksite operations and reducing work-related injuries and fatalities by providing members and others with information, guidance and access to training resources that will help them protect the health and safety of workers and understand the rights of workers and the responsibilities of employers under the Occupational safety and Health Act. MCEPS meets the third Thursday of each month to provide members with presentations and discussions of relevant safety and health issues in the industry.

    4. Implementation Team Members


      David Bates
      Area Director (AD), Oklahoma City Area Office
      Jorge Delucca
      Compliance Assistance Specialist (CAS), Oklahoma City Area Office


      John Dyer
      OSHA Consultation Representative

      Mid Continent Exploration and Production Safety Network (MCEPS)

      President: Justin Lawson
      Cactus Drilling
      Vice President: George Villreal
      BP (resigned April 2016)
      Scribe: Susan Lobsinger
      Lobdock Impairment Detection

      Executive Committee:

      Jorge Delucca
      OSHA Representative
      Past President: Joyce Ryel
      Superior Energy Services-NAS
      Gary Hanson
      Range Resources
      Ralph Tijeran
      Sandridge Resources
      Todd Smith
      Colin Lackey
  2. Implementation Team Meetings

    • There were frequent email communications between members to assist agenda planning in preparation for future meetings.
    • In addition to the formal meetings, the Alliance coordinators from both groups maintained regular contact throughout the reporting period to monitor the Alliance's progress and results.
  3. Results

    The following table summarizes the Alliance's activities in support of the goals in the Alliance agreement.

    Raising Awareness of OSHA's Rulemaking and Enforcement Initiatives:

    Activity Type Activity Name/Summary OSHA Areas of Emphasis Supported Number Reached
    Alliance Product No Activities N/A


    1. 9/30/2016: OSHA/NIOSH/National STEPS Hazard Alert regarding fatalities associated with hot work on oilfield tanks, tankers, and other related equipment.

    2. 8/25/2016: Invitation to attend Oklahoma Section of the American Industrial Hygiene Association (AIHA) fall conference (Regulatory Update) on October 7, 2016 in Oklahoma City and October 21, 2016 in Tulsa, Oklahoma.

    3. 6/29/2016: Link to Dr. David Michael's teleconference on June 27, 2016, regarding the dangers of heat illnesses in the workplace.

    4. 4/01/2016: Announcement that National STEPS is looking for small businesses in the oil and gas industry to participate in Small Business Panel review of the PSM standard.

    5. 3/24/2016: Announcement and link to OSHA final rule on crystalline silica.

    Fire/explosion, Toxic Gases, LOTO, PPE

    OSHA Update; Silica; OSHA significant cases in Oklahoma


    Process Safety Management







    Event No Activities N/A


    Meeting No Activities N/A


    OSHA Product Review No Activities N/A


    Speech/Presentation David Bates, Area Director (AD), or Steven Kirby, Assistant Area Director (AAD), provide an OSHA Update during each monthly meeting with the latest regulations, fatalities in Oklahoma, or OSHA activity in Oklahoma

    10/15/2015: David Bates, AD gave an update on an industrial hygiene study being done by Salt Lake Tech Center (SLTC) during tank gaging; they recommend using monitors to measure LEL, O2 and other VOCs, in addition to H2S.

    11/19/2015: David Bates, AD, provided the following update brief:
    1. No oil and gas fatalities recently;
    2. There were six (6) fatalities since October 1st including three (3) in construction and three (3) in general industry: Two (2) electrocutions, one (1) struck by, one (1) explosion while plasma cutting a barrel of flammable chemicals, and one (1) in a trench cave-in;
    3. Reporting injuries to OSHA for hospitalizations, amputations and loss of an eye is required. OSHA will levy citations for companies that do not report. If OSHA decides not to investigate, they will fax a letter to the company asking the employer to investigate the cause of the accident and inform OSHA of what preventive actions were taken;
    4. OSHA penalties may be increasing. Congress passed a bill authorizing federal agencies to increase penalties aligned with the Consumer Price Index. No information has been received yet as how OSHA penalties will be increased.

    12/17/2015: Steven Kirby, AAD, gave a presentation to 64 attendees of the MCEPS meeting. The presentation was a review of the hospitalization and amputation reporting for the past year and a quick summary of the fatalities so far this year.

    01/21/2016: David Bates, AD, provided feedback to MCEPS members: 1. OSHA responded to truck fires at a Fracking site. Company had a contingency plan; 2. Report in MMWR on sudden deaths at oil and gas fields from hydrocarbon inhalation during tank gaging and sampling (on CDC website); 3. Provided information regarding the 2016 "Step up for Safety" campaign during the months of February and March; Showed a safety overview video by Dr. David Michaels and Dr. Howard (NIOSH).

    2/18/2016: David Bates gave an update on occupational fatalities occurring in Oklahoma in FY 2016 (none in oil and gas); Announced the new NIOSH-OSHA Hazard Alert on Tank gauging at Oil and Gas extraction sites (Jorge Delucca, CAS, brought 60 hard copies); National Stand Down to prevent Falls (May 2-6); Briefed on-going "Step-Up for Safety" campaign in oil and gas industry, and how to sign up on the web site (February to March); Worker Memorial Day (April 28). David Bates will be participating in an OSHA Task Force that will address how to work with the oil and gas industry.

    3/17/2016: David Bates, AD, gave an update on the status of the Silica Standard; Worker Memorial activity occurring April 28th; and statistics regarding the new Severe Injury Reporting (SIR) requirements (for FY 2016 in Oklahoma, there were there have been 21 amputations and 71 hospitalizations, with 20 of these having been inspected - Eight (8) of these were in the oil and gas industry with two (2) inspections).

    4/21/2016: David Bates, AD, gave update on the OSHA Silica final rule, the Fall Stand Down in early May 2016; Workers memorial Day observation in the State Capitol on April 28, 2016, noting10 work-related fatalities in Oklahoma in FY 2016 YTD; The VPP Cameron/Schlumberger Safety Fair on April 15, 2016, and the Oklahoma Safety & Health Conference held in Tulsa on June 17-18, 2016.

    5/19/2016: Steven Kirby, AAD, provided a presentation on confined spaces during a meeting with 80 attendees of the oil and gas industry.

    6/16/2016: Steven Kirby, AAD, provided a presentation on the RRI procedure for severe injury reporting, with an emphasis on oil and gas.

    7/21/2016: David Bates, AD, provided the following updates:
    1. The final rule for Electronic Submission of Injury and Illness Records;
    2. Anti-retaliatory language used in the Final recordkeeping rule will be delayed until November 2016;
    3. Increase in penalties.

    8/18/2016: David Bates, AD, provided an overview of the OSHA informal conference process and how employers participate in the process.

    9/15/2016: David Bates, AD, discussed two fatalities and a severe injury that had occurred in the construction industry in Oklahoma.

    Additionally, David Bates and Justin Lawson from Cactus Drilling discussed a safety recall of the DBI-SALA Lad-Saf Sleeve (fall protection equipment).

    Hazards of tank gauging

    Oil and gas, electrocutions, struck by, trenching and excavation, fire and explosions

    Reporting severe injuries

    OSHA penalties

    Record keeping/severe Injuries

    Oil and gas; hazards of tank gaging; "Step Up for Safety"

    Occupational fatalities; Hazard Alert on Tank gaging; fall prevention; step-up for safety; Worker memorial day; emergency response

    Silica; Worker memorial day; Severe Injury Reporting

    Silica; Falls stand down; Workers Memorial day; occupational fatalities in Oklahoma; VPP safety fair; Oklahoma safety & Health Conference

    Confined spaces

    Severe injury reporting


    Employers Rights and Responsibilities

    Fatalities and severe injuries

    Fall protection/PPE













    Training No Activities N/A


    Other No Activities N/A


    Outreach and Communication:

    Activity Type Activity Name/Summary OSHA Areas of Emphasis Supported Number Reached
    Presentation 10/15/2015: The Occupational Health nurse from BPO gave presentation on fitness for duty-return to work connection. Injury and Illness Tracking


    Presentation 11/19/2015: Brian Bishop with Trinity Services and Consulting spoke about Exposures to H2S in the oil and gas industry in Oklahoma. H2S


    Presentation 12/17/2015: Chris Hyde, Marathon Oil Corporation provided a briefing on "Manual Tank Gauging."

    Susan Lobsinger, Lobdock Detection Service provided a briefing on "The Ultimate Plan for Contractor Drug Testing Compliance - How to manage multiple contractors most efficiently in your drug and alcohol testing program."
    Manual tank gaging

    Drug testing


    Presentation 1/21/2016: Howard Sewell of Liberty Mutual gave a presentation on Loss Risk Management of transportation accidents – "Important - Have a Fleet Safety Program."  


    Presentation 2/18/2016: Joyce Ryel provided a briefing addressing the need for a vertical OSHA standard in the oil and gas industry.

    Nancy Davis, consultant, provided a briefing addressing Department of Transportation (DOT) Compliance Concepts.

    Melissa McLawhorn Houston, newly appointed Oklahoma Commissioner of Labor, spoke about her background and the goals for the Oklahoma Department of Labor (ODOL).
    OSHA Standard promulgation for the oil and gas industry

    Oklahoma Department of Labor


    Presentation 3/17/2016: Various presentations were provided, including Phillip Browder, meteorologist, who gave a seasonal weather update about effects of El Niño and La Niña on Oklahoma.

    Marvin Ross gave a presentation about Engage Management, and the need for engage workers to change unsafe behaviors.

    Behavior-Based Safety


    Presentation 4/21/2016: Dr. Kyle Murray, from the Oklahoma Geological Survey, gave a presentation regarding the causes of earthquakes in Oklahoma as a result of disposal of wastewater from oil and gas production into injection wells.  


    Presentation 6/16/2016: Denise Deeds, consultant, gave update on the HAZCOM 2012/GHS standard that became fully effective in June 2016. HAZCOM 2012


    Presentation 7/21/2016: John J. Omohumdro gave a presentation on "Developing a Workplace Violence Program - (Including Active Shooter)." Workplace violence


    Presentation 8/18/2016: David Bates provided an overview of the OSHA informal conference process and how employers participate in the process.

    Jerry West, Damage Prevention Manager, Oklahoma One-Call System, Inc. provided a briefing on "Communication - First Step and Damage Prevention"
    Employers Rights and Responsibilities


    Presentation 9/15/2016: David Bates, Paul Ross (Labor Attorney), Kathy Willingham (HR manager, Cactus Drilling), and Susan Lobsinger (Lobdock drug and alcohol testing), discussed the proposed OSHA ban of blanket post-accident drug testing under the 19104.35 Tracking workplace injuries and illnesses. Reporting injuries and illnesses: post-accident drug testing




  4. Evaluation

    This alliance successfully reaches a significant number of safety and health professionals employed, or related to the oil and gas industry in Oklahoma. The information discussed in the meetings by OSHA representatives and industry representatives is of great value to the oil and gas industry. The number of fatalities in this industry has been significantly reduced.

  5. Upcoming Milestones

    2016 Oil and Gas Conference, November 29-30, 2016 - David Bates, AD, will be the OSHA Chair. David Bates and Marianne McGee, CAS, Corpus Christi Area Office will jointly present an OSHA Update. David Bates and Susan Lobsinger (Lobdock Drug and Alcohol Testing) will present "Changes to OSHA Recordkeeping Rule and Post Accident Drug Testing Impacts." Carmen Martinez, AAD, Oklahoma City Area Office, will provide a presentation on "The OSHA vs Industry Investigation Process."

Report prepared by: Jorge A. Delucca, CAS, November 22, 2016.