On February 11, 2016, the National Institute for Occupational Safety and Health (NIOSH) and the Occupational Safety and Health Administration (OSHA) announced newly identified health and safety risks to workers who manually gauge or sample fluids on production and flowback tanks. These risks stem from these workers’ exposure to hydrocarbon gases and vapors, exposure to oxygen-deficient atmospheres, and the potential for fires and explosions. NIOSH and OSHA’s health alert follows the release of new research showing that workers could be exposed to hydrocarbon gases and vapors when they work on or near production and flowback tanks. NIOSH and OSHA identified nine worker fatalities from 2010-2014 that occurred while workers manually gauged or sampled production tanks. All fatalities occurred at crude oil production tanks and involved employees either working alone or not being observed by a co-worker. The published hazard alert explains that air purifying respirators are ineffective against light hydrocarbon gases so supplied air respirators (e.g., air-line or self-contained breathing apparatus [SCBA] should be used to protect workers from toxic exposures and oxygen-deficient atmospheres.
NIOSH and OSHA noted that these newly-identified risks are in addition to the risk of exposure to hydrogen sulfide (H2S), a well-recognized chemical exposure hazard in the oil and gas extraction and production industry. NIOSH and OSHA gave a list of recommendations to employers to ensure that workers are properly aware of the hazards and protected from exposure. These recommendations include, among others: (1) implementing alternative tank gauging and sampling procedures that enable workers to monitor tank fluid levels and take samples without opening the tank hatch, (2) training workers on the identified hazards associated with gauging tanks, including reduced oxygen environments, flammability hazards, and the potential for concentrations of hydrocarbons that can approach and exceed IDLH concentrations when thief hatches are opened, (3) ensuring workers are trained on and correctly and consistently use calibrated multi-gas monitors that measure percent LEL and oxygen concentration, (4) prohibiting workers from working alone when tank gauging or working around tanks, thief hatches, or other areas where they may encounter process fluids, and (5) where remote gauging is not feasible or has not yet been implemented, use of respiratory protection may be needed to protect workers. Although NIOSH and OSHA do not explain in the Alert what constitutes remote gauging, it is done by inserting a sensor inside the tank to take measurements of the gases and pressures inside without requiring a worker to lift the hatch.
OSHA will likely use the Alert as a basis for issuing General Duty Clause violations under the Occupational Safety and Health Act of 1970. As such, the regulated community should examine their tank gauging and sampling procedures in light of the Alert and revise those procedures accordingly.