Policy for Wearing of Flame-Resistant Clothing in Oil and Gas Drilling, Well Servicing/Workover, Well Abandonment, and Production-Related Operations

IM 2012-029
Instruction Memorandum

UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
http://www.blm.gov/

November 23, 2011

 

In Reply Refer To:  

1310 (310) P         

 

EMS TRANSMISSION

Instruction Memorandum No. 2012-029

Expires:  09/30/2013

 

To:                   All Field Officials

From:               Assistant Director, Minerals and Realty Management

Subject:           Policy for Wearing of Flame-Resistant Clothing in Oil and Gas Drilling, Well Servicing/Workover, Well Abandonment, and Production-Related Operations

Program Area:  Fluid Minerals.

Purpose:  This Instruction Memorandum (IM) provides field offices (FO) with guidance and direction for selecting and wearing Flame-Resistant Clothing (FRC). 

Policy/Action:  All employees must wear FRC under the conditions/operations and as stated in the 2010 Occupational Safety and Health Administration (OSHA) letter of interpretation; http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27296 and:

  • Immediately upon arrival on all active drilling locations;
  • Immediately after drilling the surface casing shoe until rig down operations begin;
  • When independently gauging or witnessing gauging operations on any storage tank or pit;
  • When witnessing the transfer of liquids between tanks, trucks, pits, or pipelines;
  • When witnessing gas meter calibrations, orifice plate inspections, primary element inspections, or collection and analysis of gas samples;
  • When witnessing meter provings;
  • Immediately upon arrival of all active locations where well servicing/workover, completion or plugging operations are occurring;
  • Immediately upon arrival on any location where venting or flaring operation are occurring;
  • Immediately upon arrival any location to inspect, witness, or investigate any oil spill; and
  • During any other hazardous operations identified as requiring its use and noted on a Risk Assessment.

The FRC must cover the upper and lower body, and the outer most layer of clothing must always be flame resistant.

When a company has a written policy that exceeds the above minimum requirements for FRC, we encourage BLM employees to comply with company policy in order to demonstrate our concern for safety.  All BLM employees must comply with the minimum requirements stated above.  Attachment 1 provides additional guidance for the selection of FRC and required training in its use.

Timeframe:  Effective immediately.

Budget Impact:  If the BLM has not already purchased FRC for individuals, estimated costs associated with the initial purchase are $800 - $1,000 per person.  For FY2011, the WO provided cost codes to cover costs not already absorbed by the States.  We estimate annual replacement/maintenance costs at $300 - $600 per person.

Background:  On March 19, 2010, OSHA issued a memo clarifying the need for personal protective equipment (PPE), specifically FRC, on oil and gas well drilling, servicing, and production operations due to the potential for flash fires.  Recently, operators have denied access to some field inspectors for operations on which drilling was at or near a gas zone because they lacked the required PPE.  The BLM is responsible for the safety of our employees and must provide the required safety equipment to ensure their protection while conducting field work.

Manual/Handbook Sections Affected:  The BLM Handbook 1112-1, Safety and Health Management will be amended during the next update.

Coordination:  The Fluid Minerals Division, Washington Office of Human Capital, State Office Inspection and Enforcement Coordinators, and FO personnel coordinated preparation of this IM.

Contact:  If you have any questions concerning the content of this IM, please contact me at 202-208-4201, or your staff may contact Michael Wade at 303-236-1930 (mwade@blm.gov).

 

 

Signed by:                                                                   Authenticated by:

Michael Nedd                                                             Robert M. Williams

Assistant Director                                                       Division of IRM Governance,WO-560

Minerals and Realty Management

 

 

1 Attachment

      1- Conditions under Which Flame-Resistant Clothing Must be Worn (4 pp)

Fiscal Year

2012