OSHA’s General Duty Clause Steve Delp, Compliance Assistance Specialist, WBAO

2. OSHA’s General Duty Clause Steve Delp, Compliance Assistance Specialist, WBAO Mark Harmon, Compliance Assistance Specialist, EAO September 26, 2012

3. Pennsylvania OSHA Area Directors Mark Stelmack Theresa Naim Jean Kulp Albert D'Imperio Kevin Kilp Robert Szymanski Rev: 14 Aug 2008

4. Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm.

5. Must Be A Recognized Hazard In The Industry • American Petroleum Institute (API) • American National Standards Institute (ANSI) • Association of Energy Service Companies (AESC) • International Association of Drilling Contractors (IADC) • Manufacturers’ Specs

6. Oil and Gas 5(a)(1)’s Twenty 5(a)(1) Violations Issued from the Wilkes-Barre OSHA Office Since January, 2009.

7. Breakdown of 5(a)(1)’s • 5 – Failure To Use Whipchecks on Pressurized Flexible Lines. • 5 – Failure To Ground Portable Generators Or Electrically Bond Equipment. • 4 - Problems With Or Lack Of Geronimo Lines. • 2- Mismatched Hammer Unions. • 2 – Failure To Wear Seatbelts While Operating Heavy Equipment. • 1 – Lack Of Back-up Alarm on Forklift. • 1 – Failure To Post Emergency Contact Numbers. • 1 – Failure To Have Means Of Communication Between Stabber and Tong Operator.

8. Whipchecks Citation Example Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to a struck-by hazard: a) Rig # XX in Susquehanna County, PA: Employees were exposed to struck-by hazards from pressurized air hoses whose whip checks had not been secured, on or about November 18, 2011. ABATEMENT OBSERVED DURING INSPECTION NO CERTIFICATION REQUIRED Among other methods, one feasible and acceptable method to abate this hazard is to: 1) Ensure that all pressured connections are secured by an acceptable means in order to maintain control of the pressurized hoses in case of a failure in accordance with American Petroleum Institute (API) RP 54 Recommended Practices for Occupational Safety of oil and Gas Well Drilling and Servicing Operations Manual, page 20, section 9.13.3.; and 2) Ensure that all critical equipment, including pressurized connections, are inspected periodically as recommended by the manufacturer or in accordance with recognized engineering practices in accordance with American Petroleum Institute (API) RP 54 Recommended Practices for Occupational Safety of oil and Gas Well Drilling and Servicing Operations Manual, page 21, section 9.16.1.

9. Ungrounded Generator Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that, employees were exposed to electrical shock hazards: a) ABC Co./DCNR-xxx/Well xx/Rig #xx/Sweden Twp.,PA: A Wacker G-50, 480 volt portable generator located between the crews quarters trailer and the directional drillers trailer, was not grounded, exposing workers to possible electric shock, on or about 09/17/10. Among other methods, one feasible and acceptable method to abate this hazard is to: 1) Ensure that portable electric generators are properly grounded as recommended by the manufacturer or in accordance with American Petroleum Institute (API) RP 54 Recommended Practice for Occupational Safety of Oil and Gas Well Drilling and Servicing Operations Manual, page 21, section 9.14.11. ABATEMENT CERTIFICATION REQUIRED

10. Geronimo Lines Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that, employees were exposed to struck-against hazards: a) ABC Inc./XYZ xx/Rig xx/Springfield, PA: A 480 volt portable generator located behind the company man's trailer was positioned in the path of the derrick escape line, exposing anyone using the escape line to the hazard of striking against the generator and trailer, on or about 05/27/10. Among other methods, one feasible and acceptable method to abate this hazard is to: 1)Ensure that derrick or mast auxiliary escape lines and devices are clear of obstructions as recommended by the manufacturer or in accordance with American Petroleum Institute (API) RP 54 Recommended Practice for Occupational Safety of Oil and Gas Well Drilling and Servicing Operations Manual, page 13, section 6.10.1. ABATEMENT CERTIFICATION REQUIREDATION

11. Mismatched Hammer Unions Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that, employees were exposed to a struck-by hazard: a) 1234 Road, Some State Park, Somewhere, PA, Rig xx: A hammer union under approximately 600 p.s.i. of pressure, was not properly secured to prevent unsafe movement. The 3/16" steel cable used on the union broke under pressure, allowing the hose connection to separate violently , on or about 06/02/10. b) 1234 Road, Some State Park, Somewhere, PA, Rig xx: A hammer union on an air manifold under approximately 600 p.s.i. of pressure was mismatched in that the halves did not have the same pressure ratings, exposed a floor hand to possible serious injury when a violent separation occurred, on or about 06/02/10. Among other methods, one feasible and acceptable method to abate this hazard is to: 1) Ensure that each section of flexible high pressure hose is properly secured to prevent unsafe movement in accordance with American Petroleum Institute API RP-54, Recommended Practice for Occupational Safety of Oil and Gas Well Drilling and Servicing Operations Manual, page 20, section 9.13.3. 2) Ensure that each hammer union is made up of like halves with the same pressure ratings and thread type in accordance with American Petroleum Institute API RP-54, Recommended Practice for Occupational Safety of Oil and Gas Well Drilling and Servicing Operations Manual, page 20, section 9.13.5. ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED

12. Seatbelts Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that, employees were exposed to a struck-by hazard: a) ABC well site, 1456 Road, Somewhere, PA: The operator of a all terrain forklift truck did not wear his seat belt while traveling with a load on a fully extended boom, and sustained serious head, neck and chest injuries when the truck overturned and the boom struck him as he exited the cab and was running away, on or about 08/22/10. Among other methods, two feasible and acceptable methods to abate this hazard is to: 1) Ensure operators wear seatbelts as recommended by the Industrial Truck Standards Development Foundation/ITSDF B56.6-2005, Safety Standard for Rough Terrain Forklift Trucks, page 9, section 6.2.1(a), and 2) Ensure operators wear the seatbelt provided as recommended by the manufacturer's operations manual. ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED

13. Backup Alarm Section 5(a)(1)of the Occupational Safety and Health Act of 1970: The employer did not furnish a place of employment which was free from recognized hazards that were causing or likely to cause death or serious physical harm to employee(s) in that employee(s) were exposed to being struck by earth moving equipment: a) ABC Twp./Well xxxx/Rig #xxx: The windshield of the caterpillar forklift was cracked in several places while being operated, on or about 08/19/09. b) ABC Twp./Well xxxx/Rig #xxx: The back-up alarm on the caterpillar forklift was defective and did not emit any audible alarm when the forklift traveled in reverse, on or about 08/19/09. ABATEMENT NOTE: Among others, one feasible and acceptable method of abatement is to repair the loader's windshield and back-up alarm. ABATEMENT CERTIFICATION REQUIRED

14. Emergency Contact Numbers Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that, employees were exposed to aggravated injuries and/or death due to emergency contact numbers not posted at a remote job site: a) 1234 Road, Some State Park, Somewhere, PA, Rig #x: Telephone numbers, location, and other relative information pertaining to availability of medical personnel, transportation, and medical facilities was not posted and available at the drilling site when a subcontractor was severely injured by a hammer union that blew off a manifold as he operated a valve, on or about 06/02/10. Among other methods, two feasible and acceptable methods to abate this hazard is to: 1) Ensure telephone numbers, location, and other relative information pertaining to availability of medical personnel, transportation, and medical facilities are available and posted at all drilling and well servicing sites, in accordance with American Petroleum Institute, API-54, Recommended Practice for Occupational Safety of Oil and Gas Well Drilling and Servicing Operations Manual, page 7, Section 4.2.1. 2) Ensure prompt medical attention is available in case of serious injury at each work area, in accordance with American Petroleum Institute, API-54, Recommended Practice for Occupational Safety of Oil and Gas Well Drilling and Servicing Operations Manual, page 7, Section 4.2.2. ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED

15. No Means of Communication Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to a struck-by hazard: a) Rig xx. No positive communication was used by the stabber and the tong operator to ensure personnel were clear before rotating the casing pipe, as a result the employee was struck by the pipe, on or about May 11, 2010. AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD IS TO: Follow the American Petroleum Institute (API) 54 Recommended Practice for Occupational Safety for Oil and Gas Well Drilling and Servicing Operations, Section 12.3.1, Communications, All equipment should be located so that equipment operators can see personnel involved in the operations, or alternate specific arrangements should be made to assure adequate communication. ABATEMENT CERTIFICATION AND DOCUMENTATION REQUIRED

16. Questions???????

17. Steve Delp Compliance Assistance Specialist 570-826-6538 www.osha.gov