Recommendations

2013-01-I-NJ-1

Add North American Industry Classification System (NAICS) Code 325910, Printing Ink Manufacturing, to the list of industries in Appendix D-1 or Appendix D-2 of Combustible Dust National Emphasis Program (NEP), Directive CPL 03-00-008.

2013-01-I-NJ-2

Communicate with all OSHA Area Offices to encourage appropriate application of the following existing provisions of the Combustible Dust NEP, Directive CPL 03-00-008:

• Paragraph IX, Section A2, indicates that area offices may add to their Combustible Dust NEP establishment lists those facilities in their jurisdictions with a Standard Industrial Classification System code, NAICS code, or both (other than those listed in Appendices D-1 and D-2 of the Combustible Dust NEP directive) if those facilities have a known pattern of combustible dust hazards.
• Paragraph IX, Section B4, indicates that if a fatality or catastrophe investigation is performed at a facility because of a combustible dust deflagration or explosion, the inspector shall use the guidelines in Fatality/Catastrophe Investigation Procedures, Directive CPL 02-00-137, and in the Combustible Dust NEP, Directive CPL 03-00-008.

2021-01-I-TN-1

Promulgate a standard or modify existing standards to require employers to ensure the coordination of simultaneous operations (SIMOPs) involving multiple work groups, including contractors. Ensure that the requirements of this standard or standards apply to both general industry and construction activities and are not limited to activities occurring within confined spaces. Include in the standard requirements for Employers to ensure that the following activities occur:

a. Identification of potential SIMOPs;

b. Identification of potential hazardous interactions;

c. Evaluation and implementation of necessary safeguards to allow for safe SIMOPs;

d. Coordination, including shared communication methods, between the SIMOPs; and

e. Inclusion of emergency response personnel or services in the planning and coordination of the SIMOPs.

(Superseded 2020-7-I-NC-R2 from the Evergreen report)

2021-01-I-TN-2

Develop a safety product providing guidance on the coordination of simultaneous operations (SIMOPs) involving multiple work groups, including contractors, that is not limited to confined space or construction. Provide guidance on the following activities:

a. Identification of potential SIMOPs;

b. Identification of potential hazardous interactions;

c. Evaluation and implementation of necessary safeguards to allow for safe SIMOPs;

d. Coordination, including shared communication methods, between the SIMOPs; and

e. Inclusion of emergency response personnel or services in the planning and coordination of the SIMOPs.

2020-04-I-TX-3

Remove the exemption for oil and gas drilling and well servicing from the Control of Hazardous Energy standard (29 CFR 1910.147) and expand its applicability to cover oil and gas production and workover operations.

2020-04-I-TX-4

Promulgate a new standard with prescriptive requirements, similar to the Control of Hazardous Energy Standard, as well as a performance-based safety management system framework, similar to the OSHA Process Safety Management (PSM) Standard, that applies to the drilling, production, and servicing/workover activities surrounding onshore oil and gas wells. At a minimum, this standard should include the following:

1. Prescriptively address requirements for primary and secondary barriers for well control;

2. Detailed written drilling, production, and servicing procedures with specified steps and equipment alignment for all operations;

3. Management of change requirements (except replacements in kind) that, at a minimum, address procedures, the well plan, and equipment;

4. A risk assessment of hazards associated with the drilling, production, and servicing/workover plans;

5. A requirement to follow Recognized and Generally Accepted Good Engineering Practices (RAGAGEP);

6. Development of a Well Construction Interface Document between the operator and the drilling contractor prior to the commencement of drilling and servicing activities and an equivalent document for production and workover contractors which, at a minimum, includes a bridging document and well plans specifying barriers and how to manage them;

7. The performance and documentation of flow checks using acceptable methods at defined points during the operation for a specified duration;

8. A requirement for employee participation, similar to the Employee Participation requirement in the OSHA PSM standard;

9. A requirement for maintaining critical well information, similar to the Process Safety Information requirement in the OSHA PSM standard, which at a minimum includes well history and documented well control methods during workovers;

10. A requirement for analyzing and assessing the hazards during all phases and steps for well servicing, similar to the Process Hazard Analysis requirement in the OSHA PSM standard;

11. A requirement for developing, executing, communicating, and maintaining procedures for drilling, production, and servicing operations on a well, similar to the Operating Procedures requirement in the OSHA PSM standard; and

12. The documentation of well control plans for drilling, production, and servicing/workover operations for a well utilizing acceptable methods for monitoring the effectiveness of well control methods.

2013-02-I-TX-4

Develop and issue a Regional Emphasis Program for Section (i) of the Explosives and Blasting Agent standard, 29 CFR 1910.109(i), in appropriate regions (such as Regions IV, VI, and VII) where fertilizer grade ammonium nitrate (FGAN) facilities similar to the West Fertilizer Company facility are prevalent.  Establish a minimum number of emphasis program inspections per region for each fiscal year.  Work with regional offices to communicate information about the emphasis program to potential inspection recipients. 

2013-02-I-TX-5

Implement one of the following two regulatory changes, either option (a) or (b) below, to address

FGAN hazards:
a. Add FGAN to the OSHA Process Safety Management (PSM) standard List of Highly Hazardous Chemicals, Toxics and Reactives in 29 CFR 1910.119, Appendix A, and establish an appropriate threshold quantity.  Identify National Fire Protection Association (NFPA) 400 as a source of Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) for PSM-covered FGAN equipment and processes.
b. Revise the OSHA Explosives and Blasting Agents standard, 29 CFR 1910.109, to ensure that the title, scope, or both make(s) clear that the standard applies to facilities that store bulk quantities of FGAN.  Revise 1910.109(i), “Storage of Ammonium Nitrate,” to include requirements similar to those in NFPA 400, Hazardous Materials Code (2016

Edition), Chapter 11.  Ensure the following elements are considered:
i. For new construction, prohibit combustible materials of construction for FGAN facilities and FGAN bins. For existing facilities, establish a phase-in requirement for the replacement of wooden bins with bins made of noncombustible materials of construction within a reasonable time period (e.g., 3 to 5 years from the date standard revisions are enacted), based on feedback from the fertilizer industry.

ii. Require automatic fire sprinkler systems and fire detection systems for indoor FGAN storage areas.

iii. Define adequate ventilation for FGAN for indoor storage areas.

iv. Require all FGAN storage areas to be isolated from the storage of combustible, flammable, and other contaminating materials.

v. Establish separation distances between FGAN storage areas and other hazardous chemicals, processes, and facility boundaries.

2008-01-I-CO-1

Amend the OSHA Permit-Required Confined Spaces Rule for general industry (29 CFR 1910.146) to establish a maximum permissible percentage substantially below the lower explosive limit (LEL) for safe entry and occupancy in permit-required confined spaces.

2008-01-I-CO-2