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February 11, 2015

MEMORANDUM FOR: REGIONAL ADMINISTRATORS
STATE PLAN DESIGNEES

THROUGH: DOROTHY DOUGHERTY
Deputy Assistant Secretary

FROM: THOMAS GALASSI, DIRECTOR
DIRECTORATE OF ENFORCEMENT PROGRAMS

SUBJECT: Inclusion of Upstream Oil and Gas Hazards to the High-Emphasis Hazards in the Severe Violator Enforcement Program (SVEP)

The purpose of this memorandum is to authorize the addition of upstream oil and gas hazards to the list of High-Emphasis Hazards in the Severe Violator Enforcement Program (SVEP). This policy is targeted to upstream oil and gas drilling and well servicing employers based on their industry's significant worker fatality rate over time. Over the last twenty years, upstream operations have experienced a fatality rate that has ranged from five to eight times greater than the national average for all U.S. industries [U.S. DOL BLS]. Therefore, the Agency believes that a change in its SVEP policy related to upstream oil and gas drilling and well-servicing operations is warranted.

Going forward, a non-fatality inspection of an employer with the NAICS code 211111, 213111 and 213112 (Oil and Gas Production Services, Drilling and Well Servicing/ "Upstream Oil and Gas Industry") in which OSHA finds two or more willful or repeated violations or failure-to-abate notices (or any combination of these violations/notices), based on high gravity serious violations related to upstream oil and gas activities, will now be considered a severe violator enforcement case.

This policy is effective for any citations to the upstream oil and gas industry that are issued on or after the date of this memorandum. In the future, Section XI of Instruction CPL 02-00-149, Severe Violator Enforcement Program (SVEP), will be updated to reflect the addition of these High-Emphasis Hazards. If you have any questions regarding this memorandum, please contact the Office of Chemical Process Safety and Enforcement Initiatives at (202) 693-2100.

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