Guidance on Developing an Effective and OSHA Compliant

Guidance on Developing an Effective and OSHA Compliant

Health and Safety Training Program

For the Four Corners Oil and Gas Service Industry

This guidance document is designed to assist a company or an individual assigned health and safety responsibility within a company in developing and implementing an effective Health and Safety Training Program. An effective training program not only complies with OSHA training requirements, but it is also effective in training workers to recognize occupational hazards and how these hazards will be controlled by the company to prevent occupational illnesses and injuries. This guidance document is not designed to be a “cookbook” solution that provides a list or matrix from which the company or the person assigned health and safety responsibility can simply pick what training applies to each worker. Instead, this guidance document will provide a step-wise process that will allow company owners or their health and safety designee to develop and implement training programs for their employees, thereby fulfilling OSHA training requirements and, more importantly, preventing occupational illnesses and injuries in the workplace.

There are three fundamental steps in this process that will help your company or the health and safety designee develop and implement your company’s health and safety training program. They are:

1)  Providing all employees who will work on oil and gas field well sites, pipelines, or other oil and gas facilities with the San Juan Basin Orientation and Core Awareness training;

2)  Understanding OSHA health and safety training responsibilities and the need to perform Hazard Assessments for your company work activities

3)  Developing a comprehensive health and safety training program and becoming knowledgeable of the available training resources within the Four Corners area.

The following sections will cover these three steps in more detail.

It is important for you to recognize that training is just one element of a comprehensive health and safety program (i.e., a program designed to anticipate, recognize, evaluate, and control occupational health and safety hazards in the work place). Other elements include, but are not limited to the following:

·  Implementation of feasible engineering and/or administrative controls

·  proper and timely incident and hazard reporting

·  PPE hazard assessments

·  Industrial hygiene hazard assessments

·  Fire prevention and control measures

·  Safe materials handling

·  Confined space entry program

·  Hazardous energy control program (LOTO)

·  Managing “hot work” activity

·  Fall prevention and protection

·  Electrical safety measures for both qualified and non-qualified workers

·  Hazard communication and right-to-know programs

·  Respirator protection program

·  Emergency response and preparedness

·  Hearing Conservation program

Although this guidance document is specifically designed to address health and safety training needs, the resources identified in steps 2 and 3 can also be of assistance in understanding and implementing the above and other elements of a comprehensive health and safety program.

Step 1

San Juan Basin Orientation and CORE Awareness Training

In this step of the three (3) step process, you and your company must provide all workers who will work at oil and gas field well sites, pipelines, or other oil and gas facilities with at least the orientation and core awareness before they work in the field. This orientation and CORE awareness training does not suffice in fulfilling your company’s overall health and safety training requirements. It merely provides your workers with the basic minimum to even be considered for field oil and gas service work. Beyond this orientation and CORE awareness training, oil and gas operators and service companies will expect your employees to be adequately training in the areas and activities in which they will be working. Steps 2 and 3 of this process will provide you guidance in developing and implementing that training.

San Juan Basin Orientation

This slide presentation covers material developed by some of the larger operators within the San Juan Basin that orients new workers to the key health, safety, and environmental (HSE) requirements of the various oil and gas operators. As an orientation, it does not provide any “awareness” or “skill level” training on the topics covered. It is a basic requirement on a “one time basis” by most operators and each worker successfully completing this orientation will receive a “purple” hard had sticker designating that they have fulfilled this orientation.

Basic Awareness Training

This training provides new workers with a basic “awareness” level of training on several key HSE topics that are viewed in the San Juan basin critical for new workers to have before they begin working. These topics include but not limited to:

1)  Personal Protective Equipment

2)  Hazard Communication/Right-To-Know

3)  Lockout and Tagout (LOTO)

4)  Confined space recognition and hazard awareness

5)  Fire prevention and protection

6)  Electrical safety (basic awareness)

7)  Hydrogen Sulfide (basic awareness)

8)  Ground Disturbance and excavations

9)  Fall prevention and protection

10) Walking and Working Surfaces

11) Driving Safety

For both the orientation and basic awareness training, the resources below may provide these items.

San Juan Basin Orientation

San Juan College/School of Energy

DXP/Safety Alliance

Advanced Safety

You can also check with your Operator sponsor for guidance

Basic Awareness Training

San Juan College/School of Energy

DXP/Safety Alliance

Advanced Safety

Your companies Insurance Company

Networks (ASSE and the 4-Corner Safety)

Internet

Step 2

Developing and Implementing an Effective Health and Safety Training Program

In this step of the three (3) step process, you will seek to develop the knowledge and skills to develop and implement an effective Health and Safety Training Program, training being an important part of an overall effective Health and Safety Program.

OSHA Requirements and Industry Best Practices

In order to become knowledgeable on the topics and content of the necessary health and safety training for your employees, you need to develop a good understanding of both your responsibilities under OSHA requirements and of the recommended practices for the oil and gas producing and servicing industry. Provided below are some suggested references and professional development sources where you can find this information.

Free Resources

API Recommended Practice 74 – Occupational Safety for Onshore Oil and Gas Production Operations (Initially approved in October 2001 and Reaffirmed, March 2007)

Recommends practices and procedures for promoting and maintaining safe working conditions for personnel engaged in onshore oil and gas production operations, including special services. With respect to training, it provides a good general guide on how to set up training programs in Section 4. Pages: 23

http://www.api.org/Publications/epstandards/index.cfm

Training Requirements in OSHA Standards and Training Guidelines (OSHA Publication 2254 – 1998 Revised)

This informational booklet is intended to provide a generic, non-exhaustive overview of a particular standards-related topic. This publication does not itself alter or determine compliance responsibilities, which are set forth in OSHA standards themselves, and the Occupational Safety and Health Act of 1970. Moreover, because interpretations and enforcement policy may change over time, for additional guidance on OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts.

http://www.osha.gov/Publications/2254.html

OSHA Consultative Services

The major cooperative program offered by New Mexico OSHA is a free and confidential consultation service operated separately from the Compliance Program. A group of highly qualified occupational safety and health professionals are available to help employers

a) Detect potential hazards

b) Establish safe and healthful workplaces.

The consultation program does not issue citations or propose penalties. Employers are required to correct any identified hazards as a condition of receiving program services.

http://www.nmenv.state.nm.us/Ohsb_Website/Cooperative/index.htm#Consultation

Fee Paid Services

OSHA OTI Education Centers

Provides courses addressing various aspects of effective Health and Safety Programs, including training. Will better prepare new administrators of health and safety programs understanding their overall responsibilities under OSHA and a general awareness of OSHA standards. Cost of courses vary and will involve some travel to the education center.

http://www.osha.gov/dte/edcenters/course_list.html

ANSI/ASSE Z490.1-2009 - Criteria for Accepted Practices in Safety, Health, and Environmental Training

This standard establishes criteria for safety, health, and environmental training programs, including development, delivery, evaluation and program management. Cost = $69.

http://webstore.ansi.org/RecordDetail.aspx?sku=ANSI%2fASSE+Z490.1-2009

Hazard Assessments

In order to get a better understanding on what training you should provide to your employees, it is a best practice to conduct a hazard assessment for the various work activities that your company and its workers provide and to assess the hazards associate with these activities. Each job will present different hazard, first attempts should always be to eliminate the hazard, though most jobs will need the same basic protection from hazards. The reason for the assessment is due to the basic need to keep all employees safe and free from harm. Provided below are some suggested references and resources to performing hazard assessments.

Free Resources

OSHA PPE Standard 29 CFR 1910 Subpart I, Appendix B – Non-Mandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection.

Although this guide is for the purpose of PPE selection, it provides an overall guide for performing hazard assessments which can also be used to determine what training is necessary.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10120

University of Rochester Powerpoint on Conducting Hazard Assessments

Good PowerPoint guide that outlines how to prepare hazard assessments and to control hazards, including training.

http://www.safety.rochester.edu/offsite/jha.pdf

OSHA Job Hazard Assessment Guide, OSHA Publication 3071 (2002 Revised)

This booklet is for employers, foremen, and supervisors, but we encourage employees to use the information as well to analyze their own jobs and recognize workplace hazards so they can report them to you. It explains what a job hazard analysis is and offers guidelines to help you conduct your own step-by-step analysis.

http://www.osha.gov/Publications/osha3071.pdf

OSHA Consultative Services

The major cooperative program offered by New Mexico OSHA is a free and confidential consultation service operated separately from the Compliance Program. A group of highly qualified occupational safety and health professionals are available to help employers

a) Detect potential hazards

b) Establish safe and healthful workplaces.

The consultation program does not issue citations or propose penalties. Employers are required to correct any identified hazards as a condition of receiving program services.

http://www.nmenv.state.nm.us/Ohsb_Website/Cooperative/index.htm#Consultation

Step 3

Developing Comprehensive Health and Safety Training Plans

And

Available Training Resources for the Four Corners Area

In this final step of the three (3) step process, you will develop a comprehensive health and safety training plan for your employees and become aware of external training resources that are available to assist you in fulfilling the training needs of your company. There is nothing in this document or in OSHA rules that prohibit you or others within your company with providing this training yourself as long as you or the trainer obtain competency in the subject being taught. Some subjects have “train the trainer” courses available through various colleges or OSHA OTI education centers.

Developing a Comprehensive Health and Safety Training Plan

Once you have completed the Hazard Assessment(s) identified in Step 2 of this process for the work activities provided by your company, you can now develop a comprehensive health and safety plan for each employee. This process can be done by one of two methods:

1)  Answering a series of questions such as those listed in Attachment A of this guide; or,

2)  Reviewing the Hazard Assessment(s) and the following list of likely health and safety topics.

In both of these methods, you should review either individual employees or job classes (e.g., welders) to develop the training plan for that employee or job class and then develop a schedule to fulfill that training plan over the course of the year.

Alphabetical List of Health and Safety Training Topics

A-Asbestos, abatement (e.g., asbestos, lead, NORM)

B – Benzene, behavior based safety, BOPs (i.e., well control)

C- Chemical safety (HAZCOM), critical lifting, chains/slings (i.e., lifting), compressor safety, confined space (awareness), confined space entry (entrant), confined space entry (entry supervisor), crane safety (awareness), crane safety (operator), crane safety (inspector)

D-Driving safety

E-Excavations (awareness), excavations (competent person), electrical safety (non-qualified), electrical safety (qualified) ergonomics, emergency response (awareness), emergency response (HAZMAT spill response), emergency response (basic spill response), HAZWOPER (incident commander), earth moving equipment,

F- Fall prevention/protection (awareness), fall protection (user), fall protection (competent person), fire prevention/protection (awareness), fire extinguishers (user), flame cutting safety (see welding safety)

G-Gloves (user), good neighbor policy

H-Hazard communication, hydrogen sulfide (awareness), hydrogen sulfide (qualified worker), hazardous energy/LOTO (awareness), hazardous energy/LOTO (authorized workers), hot work (awareness), hot work (permit writer), hot tapping, hydraulic tool safety

I – Incident reporting, ionizing radiation (those who work with radioisotopes)

L-lifting/rigging (awareness), lifting/rigging (competent person), labeling (see HAZCOM), lanyards (see lifting), lift trucks, lead safety, LEL meters, LOTO (see hazardous energy control)

M – Meters (LEL, O2, H2S, CO), MSDS (see HAZCOM)

N – Non-ionizing radiation (welders, laser users), noise/hearing conservation (awareness), noise/hearing conservation (those in HCP)

O – One call (see excavations), oxygen meters, office safety

P – Personal Protective Equipment (basic), PPE (specific equipment), pressurized vessels and piping

R – Respiratory Protection (awareness), respiratory protection (users), road blading (see excavations), rigging (see lifting)

S – Slings (see lifting/rigging), SCBA (see respiratory protection), spray painting, spill response and cleanup

T – Toxic gas meters, toluene (see HAZCOM), trenching (see excavation)

V – Ventilation systems (painters, welders, etc who use systems)

W – Welding safety, well control,

X – Xylene (see HAXCOM)

Z – Zinc fumes (see welding safety)

Training Resources in the Four Corners Area

Provided below are a list of resources available that provide some level of Health and Safety training. Each resource listed may not provide one or more of the topics listed in the alphabetical list above so you need to check with each resource to determine their capabilities.