By Brent I. Clark and Craig B. Simonsen
OSHA has just released a new Safety Bulletin on “Hydraulic Fracturing and Flowback Hazards Other than Respirable Silica” (OSHA 3763-12 2014).
Hydraulic fracturing involves pumping large volumes of fluid blended with proppant and chemicals at pressures necessary to fracture a “hydrocarboncontaining formation.” According to OSHA, each year, an estimated 35,000 wells are hydraulically-fractured in the U.S. Since the oil and gas extraction industry as a whole has a relatively “higher fatality rate compared to most of the U.S. general industry” OSHA has prepared and published this Safety Bulletin for hydraulic fracturing and flowback operations to “educate and protect workers.”
The Safety Bulletin provides this “Simplified Flow Sheet for Hydraulic Fracturing and Flowback Processes”:
Appendix A, Safety Bulletin at page 35.
The Safety Bulletin sets out and divides the primary tasks and issues associated with hydraulic fracturing and flowback, listing hazard information, and provides suggestions for “prevention strategies.” Analysis is provided for:
- Hazards during transport, rig-up, and rig-down
- Hazards during mixing and injection
- Hazards during pressure pumping
- Hazards during flowback operations
- Hydrogen sulfide (H2S) and volatile organic compounds (VOCs)
- Employer responsibility to protect workers
The Appendix D is especially interesting, providing a chart analysis of “Potential Hazards Related to the Job Steps of Hydraulic Fracturing.” Safety Bulletin at page 38-41.
Employers in these industries are encouraged to review this new OSHA publication. You may be sure that OSHA inspectors that visit your projects sites will have an active knowledge of this information, and will be looking to see if “prevention strategies” have been implemented. Employer policies and training materials may need to be updated to ensure that liabilities may be minimized.