ASSE & OSHA Concentrate Collective Efforts on Risk-Based Approach in Oil, Gas Industry

The American Society of Safety Engineers applauded a group of five federal agencies, including the Occupational Safety and Health Administration, for their recent collaboration on a risk-based approach to safety in the oil and gas industry.

“If a risk-based approach to safety works for the best U.S. employers, every employer should be given the opportunity to achieve workplace protections far above the minimum requirements set by prescriptive standards,” Richard Pollock, ASSE president, said in an Oct. 22 letter to David Michaels, assistant secretary of labor for occupational safety and health. “We are heartened that these regulatory agencies have accepted that a largely risk-based approach is appropriate to meet the risks found in the oil and gas industry.”

Along with OSHA, the Environmental Protection Agency, Pipeline and Hazardous Materials Safety Administration, Bureau of Safety and Environmental Enforcement, and Coast Guard participated in the Sept. 20-21 meeting in Texas City, Texas.

OSHA said the meeting was convened to “gather information from experts and stakeholders to help inform the consideration of future applications of performance-based regulatory approaches in the oil and gas sector,” but that none of the agencies were at the time contemplating specific regulatory changes (77 Fed. Reg. 50,172).

ASSE Calls for Risk-Based Approach.

In its letter to Michaels, Pollock wrote that risk-based regulation is already widely accepted in the oil and gas industry, notably in the case of OSHA’s process safety management (PSM) standard.

“Freed from concentrating on efforts that simply comply with prescriptive standards, owner/operators are able to look beyond compliance and take responsibility for risk assessment and active management of risks,” Pollock wrote. “By taking responsibility, they then find ways to elevate an organization’s commitment to safety and health and achieve positive bottom line results.”

Some mixture of performance-based and prescriptive is nevertheless appropriate and possible in the oil and gas industry, he said. For example, ASSE members have noted that engineering requirements for drilling and industrial hygiene sampling protocols may be cases in which prescriptive standards should be used to ensure consistency with sample results.

ASSE also encouraged the five agencies to eliminate redundant regulatory effort wherever possible.

“Nothing frustrates our members more and keeps them from doing safety more than having to meet different requirements of different agencies with the good intention of eliminating the same or similar risk,” Pollock said.

OSHA Hailed for Collaborative Approach.

Dave Heidorn, ASSE’s manager of government affairs and policy, told BNA Oct. 22 that he was struck by OSHA’s decision to bring BSEE, which has adopted risk-based regulation in the offshore oil and gas industry, into the discussion.

“A big part of OSHA’s work in the industry is PSM, which is also risk-based,” Heidorn said. “And risk-based is what the world is doing outside of the U.S., and doing it well. There’s an old Russian proverb that goes, ‘If everyone is telling you you’re drunk, it’s time to go to bed.’ It’s time OSHA get in the risk-based game and stop the dance with prescriptive approaches that don’t raise the level of commitment to safety above compliance.”

Heidorn also praised Michaels for bringing together the five agencies for the meeting.

“We keep saying, ‘Be a leader and bring people together to talk about these issues’,” Heidorn said. “He did it, and should be commended for that leadership.”


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