Oilfield HSE compliance: using science in strategies for health, safety, and the environment.

• Author: McKay, Brian
• Position: OIL & GAS

Compliance is a hard word to write about. If you don't believe me, try to define it. The online version of the Merriam Webster's dictionary offers a couple of versions; "(1) the act or process of doing what you have been asked to do along with the act or process of complying to a desire, demand, proposal, regimen or coercion, and (2) the ability of an object to yield elastically when a force is applied." These two definitions seem to contradict each other where the former is begging for rigidness and rules and the latter seems a bit more flexible. Regardless of the semantics, when it comes to matters of health, safety, and the environment (HSE), there should be little doubt as to the context of the definition; follow the rules and nobody gets hurt.

Little Doubt

In the Alaska oil and gas industrial sector, there should be little doubt as to what is meant by compliance when it comes to the health and safety of the workforce and the environmental considerations when working in the Arctic. There is tremendous effort expended in the development and deployment of HSE related materials "on the slope" and "in town" from awareness campaigns, hazard hunts, and signs to compulsory training, root cause analysis, and contractual or personal consequences related to contracts, or even employment, if someone is found to be "non-compliant."

Company specific new hire orientations and awareness campaigns are a constant feature in presenting expectations. In an attempt at consistency, those who want to work on the North Slope for one of the majors need to have attended the North Slope Training Cooperatives (NSTC) eight-hour Unescorted Class, which they get from their employer or a third party provider. The Unescorted Class covers working conditions and safe work process (work at height, confined space, hot work, etc.) that can be applied throughout the participating companies' working areas and covers the minimum information needed to comply with both company policies and HSE related regulations.

The regulations governing the minimum safety and health standards at work can be found in the Code of Federal Regulations (CFR): 29 CFR 1910 for General Industry and 1926 for Construction. These CFRs describe the minimum standards for training and performing work in the field at various locations and are the product of what is known now as the OSH A Act.

At times, this act is very prescriptive, for example, in describing in great detail the minimum height and width specifications for guardrails, while other times there is room for interpretation in the standard. In addition, since the OSHA Act is a federal...