Safety in the Marcellus Shale
EKT Interactive provides custom training solutions to the Oil & Gas industry. Our activities in the Marcellus and Utica Shale regions include the development of first responder and well site safety training programs. As part of our commitment to being up to date with the latest developments in this important market, we contribute to local chapters of industry groups including PIOGA, STEPS of PA, AADE, Marcellus Shale Coalition, PA Fire Commissioner and more.
Our representatives in the area regularly attend and contribute to great meetings such as the PIOGA Safety Committee. If you can’t make it or are just keeping an eye on developments in the shale, we’ll be passing on our insights to our subscribers and followers.
Feel free to get in touch, and we hope to see you around!
OSHA – Hazard Communication Standards, General Duty Clause, MSHA Interchangeability
• Loren Anderson, an independent HSE consultant with 26 years previous HSE experience at PPG, spoke about the new OSHA Hazard Communication Standards. This change is part of the Globally Harmonized System that will publish and implement standards for the uniform labeling and handling of hazardous chemicals and other industrial hazards worldwide. Their goal is to define, classify and communicate all industrial hazards.
All employees must be trained by Dec 31, 2013 to recognize the new pictogram type hazard labels, while suppliers must completely implement the new standards by the end of 2015 or all items sold or shipped after that date. Also, MSDS sheets will be replaced by SDS sheets which have similar information but in a new format. Someone observed that we now have many standards for labeling and managing hazards:
- Globalizing Harmonizing Standards
- US DOT
- FIFRA (EPA)
- Consumer Product Safety Commission
Someone asked about how to label a water flowback tank at a well site that may contain some
combination water, oil, condensate, and natural gas. It was agreed it should be labeled for the worst case and that multiple hazard labels were acceptable.
• The recent STEPS of PA meeting was brought up which included a discussion of OSHA’s use of the general duty clause which states that employers have a duty to provide a workplace safe from all known hazards and must follow the recommendations of major industrial standards groups and usage instructions from all their equipment manufacturers.
• An attendee raised questions about how to deal with an incident where an employee driving acompany-owned pickup truck ran off the road and demolished the vehicle. He claimed he had blacked out, and HIPPA regulations prevented the company from getting any medical information about the driver or the incident. They suspected the driver may have been using his cell phone to talk or text but were unable to examine the cell phone. The company was unsure if this was a personal medical issue or an OSHA reportable industrial accident. The consensus was that it should be listed on the company’s OSHA records unless and until it was determined to be a personal medical situation.
• Another issue was raised about employees wanting to use previous MSHA training courses and
certifications to avoid OSHA training. The group agreed there are major differences between MSHA and OSHA and they are definitely not interchangeable.
• Discussion about FEMA revising their NIMS regulations – National Incident Management System, see http://www.fema.gov/national-incident-management-system
• An issue from a small trucking company who asked if there is (or could be) a
common safety training course so their drivers don’t have to sit through very similar 1-2 hr training course at each site where they deliver equipment. Doug Mehan, the chair of the group, said this question has come up numerous times before. Each time they have decided that each site is unique in at least the following ways:
- Some Unique Hazards
- Some Unique Equipment
- Site Layout, Areas to Avoid
- Traffic Flow Patterns
- When Spotters are Required
- Security Procedures
- Site Evacuation Procedures
- Handling Medical Emergencies
- Organizational Structure – Who is in Charge
Local Regulatory Issues – PA Act 9 and fracking in NY State
• Jean Mosites from the Babst Culland law firm talked about the revision of PA’s pipeline regulations (Section 192 and 195). It will cover liquid and gas lines, both gathering lines and intra-state transport pipelines. Also the PA Act 9 regulations for emergency response at well sites are almost ready for legislative approval.
[Related Link: EKT Interactive’s coverage of the STEPS of PA meeting o PA Act 9]
• Discussions continue on lifting the NY moratorium on fracking. The 80,000 comments submitted at public hearings have now been referred to the NY Dept of Public Health to determine the effects of fracking on nearby residents so a decision may be several more years away.
November PIOGA Safety Committee Meeting Preview
Next month’s PIOGA safety committee will include a presentation and discussion of electric safety and appropriate grounding / bonding procedures. EKT Interactive will be there so look out for our continued coverage of this group. Be sure to Subscribe to our blog if you want our free coverage sent to your email address.
The ASSE‘s next meeting will be a tour of the American Eagle warehouse in Wexford, PA.
About EKT Interactive
EKT Interactive, Inc is a leading provider of customized, large-scale, interactive safety and operations training programs for the oil & gas industry. Our web-based e-learning program, accessible at your convenience, saves time away from the job and travel costs. Online learning modules are developed by field-experienced oil and gas instruction experts using proven web learning applications that closely match classroom effectiveness.