Compliance

Emergency Action Plans and Fire Prevention on Oilfield Locations

An oilfield location can go from routine to emergency in minutes: a diesel leak near a heater treater, a tank fire, a compressor line failure, or an H2S alarm. Under OSHA 29 CFR 1910.38 and 1910.39, employers must have an emergency action plan and a fire prevention plan in place when those standards apply. This article covers what the plans must contain and how to make them fit a remote drilling or production location.

When an emergency action plan is required

29 CFR 1910.38 requires an emergency action plan (EAP) whenever another standard in Part 1910 requires one. In practice, the most common trigger on an oilfield location is portable fire extinguishers: when extinguishers are provided for employee use, the emergency action plan and fire prevention plan requirements come into play. Nearly every rig, workover unit, and tank battery carries extinguishers, so both plans apply to most locations.

The plan must be in writing, kept in the workplace, and available for employee review. An employer with 10 or fewer employees may communicate the plan orally and does not need a written copy. Whatever form it takes, the plan has to match the actual location, not a boilerplate document from the office.

What the emergency action plan must cover

Under 29 CFR 1910.38, the emergency action plan has to address the full sequence of an emergency, from the first alarm to the head count. At a minimum it must include:

• Procedures for reporting a fire or other emergency.
• Evacuation procedures and escape route assignments.
• Procedures for employees who remain to operate critical equipment before they evacuate.
• Procedures to account for all employees after evacuation.
• Rescue and medical duties for employees assigned to perform them.
• The name or job title of every employee who can be contacted for more information about the plan or an explanation of duties under it.

The location must also have an employee alarm system that meets the requirements of 29 CFR 1910.165, so the crew knows an emergency is underway. Escape routes on a lease need to be more than lines on a map: they have to stay clear of tank dikes, flare stacks, and the path of a potential release.

Training and keeping the plan current

The written plan alone does not meet the standard. Before the plan takes effect, the employer must designate and train enough people to assist in a safe and orderly evacuation. The plan must be reviewed with each covered employee when the plan is first developed, when the employee is initially assigned to a job under it, when the employee's responsibilities change, and when the plan changes.

If the plan does not work in a real emergency, it must be revised and the crew retrained. On a location where crews rotate every tour or every hitch, training is not a one-time event: new crew members need the same briefing, and relief crews need to know the muster point and their assigned routes.

The fire prevention plan under 29 CFR 1910.39

The fire prevention plan is the companion document. It must be in writing, kept in the workplace, and available to employees, with the same oral option for employers of 10 or fewer employees. The plan has to list:

• All major fire hazards on the location and proper handling and storage procedures for hazardous materials.
• Potential ignition sources and how they are controlled.
• The type of fire protection equipment needed to control each major hazard.
• The names or job titles of employees responsible for controlling fuel source hazards and for maintaining fire protection equipment.

Housekeeping is part of the standard: accumulations of flammable and combustible waste must not be allowed to build up where they can feed a fire. Equipment and systems on heat producing equipment must be regularly maintained to prevent accidental ignition. Employees must be told about the fire hazards of the materials and processes they work with, and the parts of the plan they need to know in an emergency.

On a drilling or production location, the major hazards list writes itself: diesel storage and refueling points, produced fluids and tank batteries, chemical skids and mud additives, and compressed gas cylinders. Hot work is one of the most common ignition sources on location, which is why it is controlled through permits and fire watch duties; see the separate guide to hot work and welding permits.

Making the plans work on an oilfield location

An emergency action plan written for an office building does not transfer to a remote lease. On many locations the fire response is the crew's own until mutual aid or the nearest volunteer department arrives, and that can be a long way off down a dirt road. The plan has to be site specific: where the extinguishers and fire water are, where the escape routes run, where the muster point is, and who stays on the pump or the drawworks long enough to shut it down safely.

The location's plan should tie into the emergency documents already on site. An H2S alarm changes how evacuation works, since the crew may have to move crosswind to a safe breathing area rather than follow the usual route; the H2S contingency planning guide covers how those plans connect. Rehearse the plan: walk the routes, run the drills, and time the head count. A plan nobody has practiced is paperwork, not protection.

Keeping the emergency contact list, muster point map, and evacuation plan with the location's documents, in software like OpsFlo, means the current version is the one the crew sees, and relief crews can find it from a phone without hunting for the binder.

Sources and further reading

• 29 CFR 1910.38, emergency action plans
• 29 CFR 1910.39, fire prevention plans