Region 6 - Alliance Annual Report - September 21, 2018

The Occupational Safety and Health Administration (OSHA)
Oklahoma City Area Office
And the
Mid Continent Exploration and Production Safety Network (MCEPS)
September 21, 2018

Report prepared by:
Jorge A. Delucca, OSHA Compliance Assistance Specialist
Oklahoma City Area Office

  1. Alliance Background

    1. Date Signed

      Originally signed on September 9, 2007 and last renewed April 20, 2017.

    2. Evaluation Period

      November 21, 2017 to September 21, 2018

    3. Overview

      The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) Oklahoma City Area Office, Oklahoma Department of Labor, and MCEPS continue to recognize the value of maintaining a collaborative relationship to foster safer and more healthful American workplaces. To that end, OSHA, ODOL Consultation, and MCEPS hereby renewed the alliance signed on September 9, 2007 and renewed April 20, 2017, with a continued emphasis on promoting worker awareness of industry-related hazards and solutions in the exploration and production of oil and gas. Specifically, OSHA, MCEPS, and ODOL/CON are committed to providing MCEPS 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 (OSH Act). Through the Alliance, the organizations will continue to address work-related injuries and fatalities.

    4. Implementation Team Members


      David Bates; Oklahoma City Area Director
      Jorge Delucca; Compliance Assistance Specialist, Oklahoma City Area Office

      Oklahoma Department of Labor

      Melissa McLawhorn Houston; Oklahoma Commissioner of Labor
      John Dyer; Assistant Safety & Health Director

      Alliance participant

      Kevin Ediger; President (Chesapeake Energy Company)
      Jennifer Martin; Vice President (QES Pressure Control)
      Jenny Sloan; Secretary (TPS Alert)

      Executive Committee:

      Todd Smith-Executive Committee Member
      Chance Odom
      Chad Pahlke
      Justin Flanagan
      Oscar Melendez
      Susan Lobsinger

  2. Implementation Team Meetings

    • The Board members and Executive Committee met the fourth Thursday of each month

    In addition to these formal meetings, the Alliance coordinators from both groups maintained regular contact, via electronic mail, 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 Oil and gas


    Via email
    12/5/2017: Limitations of Multi-Gas Monitors Hazard Alert
    6/28/2018: Recordkeeping Reminder: Get Your 300As to OSHA by July 1
    6/25/2018: Safe & Sound Week August 13-19, 2018
    8/10/2018: Recall Notice
    9/18/2018: NIOSH Science Blog on gas and vapor exposure
    Oil and gas


    Exhibit No Activities Oil and gas


    OSHA Product Review No Activities Oil and gas


    Speech/Presentation 1/18/2018: Mike Leonard, Vitruvian Group, gave presentation about Optical Gas Imaging application to gas/vapor emission safety at oil and gas sites

    David Bates, Oklahoma City Area Director (AD), talked about four recent fatalities in oil and gas; increase in OSHA penalties; status of silica standard; changes to PSM NEP

    Joyce Ryels, discussed new National STEPS website and the recent update of API RP 54
    2/15/2018: David Bates, AD and Jorge Delucca, CAS, attended the February 2018 meeting of the Mid Continent Exploration and Production Safety Network.

    Brett McWilliams, Apex Safety LLC, gave a safety minute speech about static vs. dynamic safety training

    David Bates gave an OSHA Update speech about the 2016 BLS survey of occupational injuries & illnesses and the Census of Occupational fatal injuries (CFOI); he briefly mentioned the Quinton, OK explosion that killed 5 workers (no details given due to on-going investigation). He highlighted the benefit of MCEPS role in safety leadership.

    Mark Mollman, Chesapeake Energy Company, gave a presentation on the Incident Command System and contrasted some past industry responses that occurred in 2014 with recent Chesapeake responses.
    Andrew Baker, QES Pressure Control, discussed aspects of "Safety Minute," which included: What is safety? How can we make safety personal? Safety is family.

    David Bates provided an OSHA Update, which covered:
    -Discussion of six fatalities in oil and gas in the first half of FY 2018.
    -132 reports of severe injuries in Oklahoma (all industries): 99 hospitalizations, and 33 amputations resulting in 28 inspections and 104 Rapid Response Investigations.
    -Workers Memorial Day, which is observed April 26 at State Capitol, and feature approximately 41 silhouettes of fallen workers.
    -National Stand Down to Prevent Falls-in all industries. A free fall prevention class will be offered on May 10 at Oklahoma Safety Council
    -Unsafe trench collapse at Muskogee, OK that occurred on May 14.
    -Discussed new enforcement guidance for electronic recordkeeping.

    Guest speakers included three members of the Oklahoma Highway Patrol. Discussion topics included: Truck safety inspection issues; Issues with ELDs; Carrying weapons in commercial trucks (legal to do, but inform law enforcement if stopped). CAS Delucca asked about referrals when OSHA receive calls from truck drivers about safety concerns with trucks or driving hours. CAS Delucca mentioned OSHA whistleblower program includes DOT regulations. David Bates clarified that fatalities and injuries in over-the-road accidents are recordable but not reportable.

    Tank Gauging Discussion: Tank gauging techniques and testing for H2S; Securing valves (two fatalities this year in Oklahoma-Bates mentioned OSHA successful in citing "should" in API standards

    Rory, from Southern plains, discussed aspects of "Safety Minute" regarding the importance of reporting safety hazards and "Stop Work" authority. The group indicated concern that workers believe they would be disciplined if exercising "stop work" authority. CAS Delucca reminded the group of the Whistleblower protection program.

    Oscar demonstrated how the new MCEPS web site works.

    David Bates gave OSHA Update on latest oil and gas (fall ) fatality; activities for Stand down to Prevent falls, this May; and Workers Memorial Day on April 26.

    Scott Schaeffer from Oklahoma Center for Poison and Drug Information gave a presentation about Spiders, Snakes and Ticks in Oklahoma.

    A representative from Hazard Scout talked about coaching and the concept of "industrial athletes" doing the right "safety thing."

    David Bates provided the group a presentation about fall protection with current statistics of fall-related fatalities in Oklahoma.

    Jeff Kleber from Miller Fall Protection provided a presentation / demonstration of the use of Personal Fall Arrest Systems.

    Group discussion regarding fall protection from heavy & tractor-trailers and trucks.

    Joyce Riels, Association of Energy Service Companies (AESC) Regional Representative provided an update on the on-going revision of API RP-54.

    David Bates provided a presentation on the OSHA Multi-Employer Citation Policy and the Appropriations Act Enforcement Exemptions and Limitations.

    Kenny Jordan, National STEPS Network, provided a presentation on safety statistics on behalf of the National AESC.

    Chris Haynes from Roan Resources presented a "Safety Minute" topic;

    Steven Kirby, OSHA Assistant Area Director, provided an OSHA Update;

    Tom Bergman from ODEQ presented the Integration of Hazardous Material Information into a single platform;

    Susan Lobsinger from Lobdock Impairment Detection and Paul Ross employment law attorney from McAfee and Taft led a panel discussion on medical marijuana in Oklahoma (SQ 788).

    Jody Reinhart provided an overview of the Environmental Federation of Oklahoma;

    Jorge Delucca, CAS, gave presentation about the Safe & Sound Campaign;

    Betsey Kulakowski, Oklahoma Safety Council and Stacey McAndrews, OSHA, gave a presentation about recordkeeping Incident Recordability / Reportability.
    9/20/2018: David Bates provided an OSHA Update that addressed 5(a)(1) violations.

    M.G. Govia and Tyler Dunlap, OKIE811 gave presentation on "Utilization of GIS Technology for OKIE811"
    Oil and gas


















    Activity Type Activity Name/Summary OSHA Areas of Emphasis Supported Number Reached


  4. Evaluations

    The alliance is effectively attracting members from major oil and gas companies and related organizations to its monthly meetings. Attendees to the meetings are receiving high quality presentations with lessons learned from other companies plus updates from the OSHA Area Director.

  5. Upcoming Milestones: None