Drilling Contractors - Workrite Uniform Company

Drilling ContractorsTechnical Brief

Introduction 1

Introduction OSHA instituted a significant change in the clothing requirements for oil and gas drilling and servicing operations. In March of 2010, OSHA issued a memorandum clarifying their policy of citing CFR 1910.132 for oil and gas well drilling and servicing operations for not providing employees with flame-resistant clothing (FRC) during certain drilling, servicing and production-related operations. OSHA feels there is potential for worker injury due to flash-fire exposure during these operations and, therefore, the employers must provide appropriate FRC.

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Introduction 3

This technical brief will help you understand the basic landscape of this change and what it takes to comply by addressing:

• Why FRC is needed in this industry

• Where it is needed

• The specifics of the OSHA memorandum

• What type of FRC is acceptable to OSHA

Why is FRC Needed? 5

Why is FRC Needed?


Flame-Resistant ClothingAnywhere there is the potential for a release of a fuel, such as flammable gas or vapors of an ignitable liquid, there is the potential for a flash fire. Regardless of administrative and engineering controls, these events have and will likely continue to happen. Typical non-FR work clothes can ignite and burn, and it has been demonstrated that more severe burns are actually caused by clothing igniting rather than the original flame exposure. In fact, clothed areas can be burned more severely than bare skin.


FRC, on the other hand, does not ignite and continue to burn when the flame source is removed. It also provides a barrier from the flames and insulates the wearer from some of the heat. So, FRC provides three basic benefits:

1. It reduces the amount and severity of the burn injuries.

2. It provides the wearer some time to escape the fire area.

3. And it increases the wearer’s chances of survival.


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Surviving Burn Injuries


As this graph from the National Burn Information Exchange shows, the chances of surviving a flash fire increase significantly as the percentage of body burn decreases. Regardless of age, keeping the amount of body-burn injury low helps, which is what FRC is designed to do.

Where is FR Needed? 11

Where is FR Needed?


OSHA has identified specific operations where they feel it is appropriate to provide workers with FRC. These operations include drilling, well-servicing and production-related services.

Drilling OperationsThere is lower potential for a flash fire during rig-up and drilling operations that have not reached gas- and hydrocarbon-producing zones. However, the potential does increase when drilling hits these zones. The flash-fire potential exposure occurs in these zones because the pressure from underground gas or hydrocarbon could send the well fluids up the hole to the drilling rig floor or platform where ignition could occur. If these fluids are not contained or controlled by blowout preventers or engineering controls, OSHA believes there is a high potential for a flash fire. OSHA compliance officers’ (CSHOs) citation guidelines for drilling operations include:


• FRC is usually not needed during initial rig-up and normal drilling operations prior to reaching active hydrocarbon zones, unless other activities warrant their use (e.g., fracking a previously drilled well while rigging a well in close proximity).

• A potential for flash fire exists once active gas or hydrocarbon zones are reached. Appropriate FRC shall be worn by exposed employees working on the well site prior to drilling into identified gas or hydrocarbon zones. CSHOs should verify that employees are wearing FRC in advance of reaching such zones.

• Appropriate FRC should also be worn when there is a history of fluid or gas kicks from underground producing zones.

Once FRC is identified for use as provided above, employees should wear appropriate FRC until the final casing is cemented and the well is effectively closed.


Well-Servicing OperationsDuring servicing operations on oil and gas wells that are active and involve accessing and extracting of oil and gas, there is a potential for a flash fire to occur. CSHOs shall determine whether FRC is provided and worn during well-servicing or workover operations, such as:

• Pulling wet string tubing


• Snubbing tubing

• Swabbing operations

• Fracturing or perforating the well

• Using bridge plugs or packers

• Open hole work

• Flow testing, blowing down or venting the well

• Plugging an abandoned well

• Flowback operations

• Cementing

• Stimulation

• Wireline operations

• Any operation working with wellhead or wellbore under pressure


Production-Related ServicesIn OSHA’s experience, the potential for flash fire also exists in production-related operations that fall outside of drilling and well servicing. During production operations, well fluids are brought to the surface, then separated, stored and otherwise prepared for delivery. CSHOs shall determine whether FRC is provided and worn during production-related operations, such as:

• Equipment openings (e.g., line breaking or valve changes)

• Gauging

• Transfer of hydrocarbons

• Maintenance operations on production equipment

• Hot work operations

• Tank heating

• Using open flame

• Start-up operations


Each of these operations typically has engineering controls to reduce the occurrence of an accidental release, but these controls do not entirely eliminate the possibility of a release and a subsequent flash fire. Therefore, OSHA requires the use of FRC unless a detailed hazard assessment can show that FRC is not needed.

The Specifics of the OSHA Memorandum 19

The Specifics of the OSHA Memorandum


OSHA On March 19, 2010, OSHA issued a memorandum to clarify their policy for issuing citations to oil and gas well drilling, servicing and production-related operations, under the general industry standard for personal protective equipment (PPE) 29 CFR 1910.132. They referenced a history of burn-related injuries and fatalities due to flash fires in these operations, and thus concluded that employers of these operations are required to provide and ensure the use of FRC. OSHA noted that the oil and gas industry has worked to reduce the risk of flash-fire incidents, but these efforts have not eliminated the occurrence of flash fires, nor the resulting burn injuries and fatalities. They stated the use of FRC greatly improves the chance of a worker surviving and regaining quality of life after a flash fire; and FRC can significantly reduce both the extent and severity of burn injuries to the body.


OSHA suggests that employers utilize NFPA 2112, the Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, to assist them in understanding the minimum requirements for the FRC used by industrial personnel. OSHA’s reference to this standard is to provide employers guidance and is not a requirement. OSHA also suggests employers utilize NFPA 2113, the Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, for guidance on hazard assessments and garment selection.

Where appropriate, CSHOs shall cite 29 CFR 1910.132(a) for failure to provide and ensure the use of FRC in oil and gas drilling, well-servicing, or production-related operations when there is potential for flash-fire hazards.


What Type of FRC is Acceptable to OSHA? This OSHA memorandum, like most OSHA rules, states the general environment or hazard where PPE and, in this case, FRC, is needed, but does not outline the detailed performance requirements for that PPE/FRC. It is the employer’s responsibility to conduct a hazard assessment either per NFPA 2113 or some other method to determine the need for wearing FRC as protection against flash fire hazards. OSHA CSHOs will evaluate the adequacy of the hazard assessment in determining whether to issue citations where employees are not provided with or wearing FRC during drilling, well-servicing and production-related operations. OSHA expects employers’ hazard assessments to be comprehensive and robust. If an employer conducts a hazard assessment and determines that FRC will not be provided during these operations,


the hazard assessment should identify the underlying reason for the determination not to use FRC.

Although FRC that has been certified to meet NFPA 2112 may be suitable to any given operation, certification to NFPA 2112 is not an OSHA requirement. NFPA 2112 and 2113 are useful guides to assist in the FRC evaluation process. However, OSHA expects the employer to supply FRC that provides suitable protection based on their own hazard assessment, not simply on the minimum performance requirements of a consensus standard like NFPA 2112.

The bottom line is this: Since 2011, OSHA has been looking for oil and gas drilling, servicing, and production-related operations to have performed a hazard assessment and to have their employees in the appropriate FRC based on this assessment. OSHA feels this provides proven supplemental protection against burn injuries by offering a last line of defense, greatly reducing burn injuries and improving a worker’s chances of surviving exposure to a flash fire.


For questions regarding drilling operations and the implementation

of a proactive FR clothing program, please contact:

Mark Saner

Technical Manager

Workrite Uniform Company

800-521-1888 ext. 236

[email protected]

Our mission is to protect today’s workers by delivering trusted, innovative

and market-leading, flame-resistant branded apparel solutions.

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Drilling Contractors - Workrite Uniform Company

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