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July 20, 2020
One of OSHA’s benchmarks for protecting employees from COVID-19 requires employers to assess their workplaces and determine whether job tasks place their employees at one of four levels of risk exposure: very high, high, medium, and lower risk. The agency recommends that employers conduct a hazard assessment to identify whether and how often workers may be in close contact (i.e., within six feet) to coworkers, supervisors, or other individuals at the job site.
The good news for the oil and gas industry is that OSHA does not anticipate a very high or high risk of exposure. According to the guidance, “[m]ost oil and gas drilling, servicing, production, distribution, and/or processing tasks are associated with lower or medium exposure risks.” Examples of oil and gas work activities with a medium or lower risk include the following:
Use Cloth Face Coverings
Regardless of the exposure risk level, OSHA advocates that all workers in the oil and gas industry wear cloth face coverings. The agency also recommends that workers wear face coverings “in common areas such as the drill deck, doghouse, control rooms, and office spaces in the trailers.”
Controls to Mitigate Medium Risk Activities at the Worksite
OSHA emphasizes social distancing as the primary method of mitigating worker exposure to COVID-19. This includes a recommendation to “[c]onfigure communal work environments (such as control rooms, jobsite trailers and/or doghouses) so that workers are spaced at least six feet apart, if possible.” If the nature of work makes social distancing infeasible, then the use of physical barriers between workers (such as strip curtains, plexiglass, or other impermeable dividers or partitions) are acceptable, so long as the barrier “does not create additional safety hazards (e.g., reduced visibility in/around work vehicles or other equipment).”
OSHA recommends that employers pay special attention to pedestal or hard-mounted fans to ensure they do not blow air directly from one employee to another. The agency also suggests that personal cooling fans be removed from the worksite to help reduce the spread of COVID-19.
Other suggestions from OSHA include the following:
Carpooling or Use of Company Vehicles
Under the guidance, employers should “[e]ncourage workers to avoid carpooling to and from work and job sites, when possible. However, this can be a challenge due to the nature of the oilfield industry, which often requires employees to travel to worksites far away from their homes. For example, traveling to a worksite 100 miles from a local yard is not uncommon for oilfield work in West Texas. Recognizing this reality, OSHA recommends the vehicle’s windows remain open to circulate air. The agency also suggests the following:
“[P]ractice proper hand hygiene, such as hand washing or, if soap and water are not readily available, use hand sanitizer that contains at least 60% alcohol, before entering the vehicle and when arriving at the destination.”