APPLYING OSHA S WALKING & WORKING SURFACES STANDARDS TO FIELD GAS COMPRESSION Joe Avila, HSE Supervisor, JWPC
OBJECTIVES Introduction, Latest Standards and Data Assessments and Inspections The Location Challenges, Solutions The Equipment Challenges, Solutions Summary
WHAT IF THIS WAS YOUR OFFICE?
OR THIS?
INTRODUCTION WWS safety practices have become part of normal life in an office or shop environment. At field sites? Not always Organizations such as the BLS, AESC and NSC list slips, trips and falls as leading causes of injury in the U.S. onshore Oil & Gas industry. Most production locations have numerous types of equipment present. Surface piping and other hazards contribute to a high level of slip, trip and fall injuries. Field gas compression requires constant service and maintenance, often above surface height.
A DAY AT THE OFFICE Field Gas Compressor Service Technicians Emissions Specialists Lease / Station / Plant Operators Component Specialists, such as Caterpillar or Ariel Installation crews (welders, roustabouts, equip. operators) Sales, Engineering, HSE
STATISTICS - NATIONWIDE 2014: Falls on same level ranked #2 leading cause of disabling injuries. Direct costs to U.S. industry $9.19 Billion Slip or trip without fall ranked #7. Direct costs of $2.17 Billion (Liberty Mutual Workplace Safety Index)
STATISTICS INDUSTRY SPECIFIC 2012 2015 OSHA Data for NAICS 211111, 213111 and 213112 Fatal Incidents (211 Total) Asphyxiation, 5.7% Chemical Exposure, 0.9% Drowning, 0.5% Electric Shock/Electrocutio n, 5.2% Field Gas Compression is NAICS 213112 Fall related injuries caused 12.3% of all fatalities during a 3-year period Struck by Against & Caught In Between, 49.8% Heat Stress, 4.3% Fall Same Level, 0.9% Fall From Elevation, 11.4% Unknown/Natural Causes, 7.1% Explosion/Fire, 14.2% About 1/3 of non-fatal injuries are slip/trip/fall incidents The Stats Do Not Always Reflect the Whole Picture
STATISTICS INDUSTRY SPECIFIC DIRECT RESULTS OSHA Recordables, First Aid, Lost Work Days Short or even Long Term Disability Quality of Life Higher TRIR and Severity Rate Higher EMR INDIRECT RESULTS Competitiveness and Profitability Issues Lower Scores in ISN, PEC, Veriforce, etc. Morale Issues: Set Up to Fail, then penalized for being Unsafe
LATEST REQUIREMENTS Reducing slips, trips, and falls in the oilfield. What covers gas compression sites and equipment? August, 2017. GMRC High Speed Compressor Package Guideline for Field Gas Applications. Voluntary industry standard. October, 2018. GCA Guidelines for Compressor Package Safety, Installation and Siting Considerations.? 2019. API 11P, Specification for Packaged Reciprocating Compressors, for Oil and Gas Production Services, Third Edition. January, 2017. OSHA s Revised CFR 1910, Subpart D, Walking and Working Surfaces.
WALKING/WORKING SURFACES Proper work surfaces are required where employees are performing frequent work, as free of hazards as possible Clear path of travel; clean, dry and free of holes, objects or other hazards Non-slip platforms/work surfaces in routine maintenance areas on the compressor package (beside engines, at valves, filtration cylinders, etc.) Proper stairways/steps or ladders are required to access any work platform/surface where a step up of 19 inches or more is present* A guard rail system or other acceptable form of fall protection is required for all work platforms where an employee could fall 48 inches or more to the surface below (on top of coolers, beside engines) When fixed ladders, stairs and platforms are not practical, other acceptable methods of access must be used* (*not part of Revised 1910 Subpart D)
EVALUATIONS AND INSPECTIONS Now Required: WWS Inspections WWS Equipment Assessments and Forms (Not required, but good practice) Document existing compliance, needed improvements, measurements General site and equipment both Before/after photos
EVALUATIONS AND INSPECTIONS Regular Inspections On a schedule adequate enough to identify hazards As Needed Inspections When conditions, circumstances, or events occur that warrant an additional check to ensure that WWS are safe for use Existing Tools Field audits by HSE/ Supervision, PM/Service Reports, JSAs, BBS Observations
Industry Specific Challenges General Weather / Nature / Working Outdoors Working Solo, Human Nature Geography, Remote Areas Market Stability, Boom or Bust
Common Challenges - Location Contractor vs. Customer Relationship: A work environment controlled by the customer, not by workers affected by hazards. Piping, tubing, hoses run along surface of location (#1 Cause of many incidents)
Common Challenges - Location Uneven terrain, holes/trenches, wheel ruts Spill containment walls liners Raised or sunken compressor foundations Tie-downs/guy wires, stakes, tarps, ground rods and other objects in pathways Lack of lighting
SOLUTIONS LOCATION HAZARDS Establish Safety as a Shared Core Value! Contractor Vs. Customer Relationship -Develop minimum industry standards (GCA, GMRC) -Share standards with customers and agree to follow (leverage) -Hold customers accountable (audits, assessments) Train workers to own observed hazards. Report and follow-up, or correct on-the-spot when appropriate. Require Supervision/Account Manager be on-site during installation, routine site visits. Maintain direct line of communication to customer. Share site inspection data with customers. Prioritize improvements and work together.
SOLUTIONS LOCATION HAZARDS Bury piping/hoses shallow, or cover with gravel and route to avoid hazards. Ensure a clear path around equipment. Address location hazards during installation: Reps for all parties on-site, plus construction crews, equipment Hot Work, 811 call, LO/TO, etc., already done. Much easier to correct up-front!
SOLUTIONS LOCATION HAZARDS Fluid supply tank hoses replaced with sub-surface piping. Piping routed or covered to provide clear path of travel and painted bright color. Suction line routed at height of ~6.5 ft., to aid safe path of travel. Light poles present, not visible in photos.
SOLUTIONS - LOCATION HAZARDS Install cross-overs, stairways, raised grating where needed. Keep clear access paths to the unit wherever possible! Provide lighting.
Common Challenges - Equipment Safe access to engine service platform, platform dimensions, lack of protective railing Safe access to elevated components valves, level kills, coolant surge tanks, exhaust catalysts Safe access to the compressor frame On-skid piping, conduit/wiring, etc. obstructing access Oil, antifreeze, chemicals on skid; weather, for outdoor units Special situations
Common Challenges - Equipment Engine service platforms
Common Challenges - Equipment Elevated components
Common Challenges - Equipment Special situations units in buildings or under sheds; trailer-mounts
SOLUTIONS EQUIPMENT HAZARDS WHY SUCH HAZARDS? Age of units, large number of compressor unit packagers Units bought/sold, acquisitions/mergers Modifications in the field, requirements of End Users Engineering requirements, such as catalyst temps Items lost during unit moves Need to maintain portability WHAT ARE OUR GOALS? Make our equipment safer for employees, then OSHA-compliant. What is safest may not always be required by OSHA Analyze tasks, identify hazards, speak with Service Techs Determine the safest, most cost-effective solutions. Then utilize across the board. Use hazard controls hierarchy: Engineering, Administrative, PPE Balance highest level of safety with responsible use of resources Upgrades in the shop vs. field (Shop is easier!)
SOLUTIONS EQUIPMENT HAZARDS Use engineering to eliminate the need to climb up, access elevated surfaces Provide OSHA WWS-compliant access where needed Maintain leaks, fluid drains to keep oil on skid to a minimum Guardrails best practice for exposed edges, even if <48 in. Toeboards may/may not be required Stairs with 4 or more risers need handrails Ladders need self-closing gate or offset landing Ladder to platform distance <12 in. Ladder cages/rails extend 42 in. above work surface Ladders reaching 24 ft. or higher need cage or other fall protection* *OSHA has a series of dates phasing out ladder cages as the sole method of fall protection Fall arrest or ladder safety systems after 11/19/2018 If ladder already has cage, okay to leave it
SOLUTIONS EQUIPMENT HAZARDS Cooler access - fully enclosed all-in-one removable basket Cooler access fold-down rails Cooler access removable rails, medium horsepower
SOLUTIONS EQUIPMENT HAZARDS SPECIAL SITUATIONS In buildings, explore options: cooler outside, higher roof/remove roof, PPE vs. railing, etc. Above all, Plan Ahead! For trailer-mounts, install platforms/railing when skid height at or above 4 ft.
SOLUTIONS EQUIPMENT HAZARDS Platforms for Coalescing Filter Access First one (right) ~6 ft. floor height Bottom, >4 ft. height
SOLUTIONS EQUIPMENT HAZARDS OSHA allows PPE anchor points for non-routine tasks Fall Restraint typically more feasible Use SRLs or double-leg lanyards Engineered anchor points, first within reach of ladder
SOLUTIONS EQUIPMENT HAZARDS Temporary Options for critical units on location Purchase pre-fab, bolt on Aerial Work Platforms Portable ladders
WHAT DOES SUCCESS LOOK LIKE? OSHA TRIR 4.00 3.50 3.00 2.50 2.00 1.50 1.00 0.50 0.00 TRIR for North American Service Operations (Composite) 3.40 2.46 3.09 1.88 2.74 1.18 2.07 1.09 0.00 2009 2010 2011 2012 2013 2014 2015 2016 2017
WHAT IS SUCCESS, REALLY?
SUMMARY Slip, Trip and Fall hazards are a leading cause of workplace injury within field gas compression. New Federal Regulations and Industry Standards address these. Both Location and Equipment hazards need to be assessed. Numerous solutions exist for upgrading these to safer WWS standards. Modifying locations at installation, and compressors in the shop, is best. Temporary options can be used for critical units awaiting retrofit. Safety is a Shared Responsibility, By and For All Involved!
? QUESTIONS?