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Contractor and Host Employer Relations on Oil and Gas Sites

Contracted Employee

Wednesday, Apr 17th, 2019

Contract EmployeeWork in the oil and gas industry requires several different lines of work, so oil and gas companies often hire contractors to perform specialized work tasks. These host companies rely on the contractors to work safely and abide by their own company policies, as well as federal, state, and local laws. Contractor employees need to be aware of their responsibilities to their contract employer and their host employer, as well as how to perform their job duties safely. Contractor companies and their host employers work together to ensure that all personnel are properly trained on the hazards in their work area, and that all operations on the site operate together without creating hazards or causing confusion.

Company Roles

Oil and gas contractors often work with personnel from multiple companies, so it’s important to know how companies and employees work together on an oil and gas site. Contract employers should provide their employees with general training over the work the company does, and common hazards associated with their job duties. Host employers are familiar with the equipment and hazards on their sites, so they’ll usually be responsible for in-depth training on site-specific hazards. They’ll also be responsible for training contractors on their own policies, including emergency procedures and site remediation.

Determining which company is responsible for a specific task depends on the relationships between employers on the work site. For example, a full inventory of all chemicals must be kept on work sites, but the employer who maintains that inventory can vary. A staffing agency that only provides temporary workers won’t generally keep a chemical inventory, but a subcontractor bringing on a whole team of its own people and providing its own supplies probably will maintain its own inventory.

Hazard Communication (HAZCOM)

The Occupational Safety and Health Administration (OSHA) requires workplaces to have a HAZCOM program when workers are exposed to hazardous chemicals. A HAZCOM program evaluates chemical hazards in the workplace, trains employees over the chemicals they’ll use and provides employees with information about the hazards of those chemicals. As part of a HAZCOM program, each hazardous chemical on a work site must have a safety data sheet (SDS). An SDS contains information about a chemical, including safe handling instructions, potential health effects, and cleanup and disposal instructions. If an SDS is missing from a work site with multiple employers, the company maintaining the chemical inventory must request a new SDS from the chemical manufacturer or distributor.

Job Preparation and Hazard Analysis

Employees Performing JHABefore beginning work on a site, employers will generally perform a job hazard analysis (JHA). Some companies refer to it as a job safety analysis (JSA). A JHA or JSA identifies the major steps of a job or work task, as well as any potential hazards associated with the work. A JHA also generally includes controls for those hazards, the personal protective equipment, or PPE, that workers need, chemical handling information for all chemicals on site and emergency preparedness and response information. JHAs are formal written plans, and employers must provide documentation of the JHA to employees. Depending on company or work site procedures, a JHA may be performed by contractor personnel, host employer personnel, or both.

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Incident Reporting and Prevention

Many oil and gas host and contractor companies follow formal incident prevention and reporting procedures. Depending on the nature of the work, contractor employees may follow their own internal procedures, the host company’s procedures, or a combination of both. Incidents can include chemical spills, injuries or illnesses, fires, property damage, motor vehicle accidents, criminal activity and near-misses. A near-miss, also known as a near-hit, is an incident that almost occurred and could happen if the issues that caused the near-miss aren’t corrected. All incidents must be reported to appropriate personnel, and incident scenes should only be disturbed to treat injuries or control damage. All personnel on the site should have the responsibility to stop work when they notice hazards or other risks to personnel, equipment, or the environment.

Host Employer Policies and Procedures

Welder Working on PipeSome host companies have policies designed to make sure site changes and multiple operations work smoothly. A management of change (MOC) program, establishes procedures to identify and control potential hazards because of work or process changes. An MOC process should include a risk assessment conducted by all impacted personnel, a work plan that addresses the time of the change and any control measures, and authorization of the work plan by responsible personnel. Simultaneous operations (SIMOPS) refer to two or more operations in the same location at the same time that don’t normally overlap, such as drilling and well completion on the same pad. Contractor and host companies should discuss SIMOPS procedures and changes to a JHA or specific work tasks involved with SIMOPS.

Compliance and Training Requirements

Contractor companies may have to show host employers their own policies and training documentation to ensure contractor employees are trained in line with host employer policies. Host companies who use contractors for regulated or permit-required tasks may also require contractors to have a written training program. These training programs often include specific requirements for authorized and affected personnel, verification of training and certifications and any other required documentation for federal, state and local regulatory agencies. All contractor employees must be able to understand and follow all work site and company policies. If a company has any employees who aren’t able to read or speak English, at least one other person should be available to translate policies for those employees.

Conclusion

Contractors are important personnel on many oil and gas sites. However, contractor personnel must be properly trained on their roles and how their duties interact with other operations on the site. When all contractor personnel are on the same page, they can work together to extract resources safely and efficiently.

For more information on OSHA’s HAZCOM requirements, click here. OSHA also has additional information and sample worksheets for performing a job safety/hazard analysis.

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