OSHA Issues Guidance For Oil and Gas Industry Workers And Employers

Vinson & Elkins LLP

Vinson & Elkins LLP

On July 8, 2020, OSHA issued guidance specific to the oil and gas industry for mitigating occupational exposure risks to COVID-19. Some of the key considerations arising from that guidance, which can be found here, are below:

Employers Should Assess Exposure Risks. While OSHA’s guidelines classify most oil and gas work tasks as low or medium risk for COVID-19 exposure, the agency encourages employers to conduct their own job hazard assessment to identify the level of risk exposure each position faces, and which work tasks will require close contact between people.

Engineering Controls. The guidelines embrace the need for social distancing and other protective measures within oil and gas worksites, and provide an illustrative list of engineering controls that employers in the oil and gas industry should consider, including:

  • re-positioning workstations so that workers are at least six feet apart in all directions;
  • using physical barriers (e.g., plexiglass) to separate workers from each other, where safe and feasible; and
  • consulting with heating, ventilation, and air conditioning engineering experts to ensure adequate ventilation in work areas, and opening windows when possible.

Administrative Controls. Employers can also reduce or eliminate the risk of COVID-19 exposure in the worksite through administrative controls. These controls include:

  • staggering workers’ arrival and departure times to avoid the congregation of workers in parking areas or other common areas;
  • providing disposable cups or individual water bottles at hydration stations, and disposable plates and bowls in break and dining areas;
  • encouraging workers to avoid carpooling to and from worksites;
  • cohorting workers into shifts and shared shuttle vehicle assignments (where necessary) to further minimize contact during work-related activities;
  • establishing a system to screen for COVID-19; and
  • providing training on COVID-19-related safety protocols.

Face Coverings. The guidelines state that oil and gas workers should wear cloth face coverings, especially where social distancing is not feasible due to working conditions. The guidelines also recognize that it may not be practical for workers to wear a single face covering for the full duration of a shift (i.e., eight or more hours). Accordingly, the agency recommends that employers be prepared to provide replacement face coverings as needed.

Consider possible additional hazards that may require PPE. The guidance does not contemplate that oil and gas workers will need PPE beyond that already used for protection for routine job tasks. However, OSHA instructs employers to “consider whether [employers’] hazard and risk assessments warrant the use of items such as gloves or eye and face protection.” The guidelines also recommend that employers keep any hazards that may be created by introducing new PPE in the work environment in mind as they consider the issue (e.g., PPE catching in machinery).

Monitor continued guidance from governmental agencies. No matter how employers plan to address COVID-19 risks within the workplace, OSHA reminds employers of the need to remain aware of evolving guidance from the CDC and other local, state and/or federal agencies.

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