This memorandum is intended to clarify OSHA’s policy for citing the general industry standard for personal protective equipment (PPE), 29 CFR 1910.132(a), for the failure to provide and use flame-resistant clothing (FRC) in oil and gas well drilling, servicing, and production-related operations. For the purpose of this memo, FRC includes both flame-resistant and fire retardant treated clothing. Clarification of the need to provide and use FRC during certain drilling, servicing, and production-related operations is necessary to resolve its inconsistent use among drilling contractors, well servicing contractors, and oil and gas companies that employ thousands of workers in these operations. OSHA inspection history and current information, including consensus standards, scientific evidence, and accident and injury data, indicate a potential for flash fires during certain well drilling, servicing, and production-related operations.
Where FRC is not being used by workers in these operations, a citation under 29 CFR 1910.132(a) requires evidence that the employer had actual notice of a need for protective equipment, or that a reasonable person familiar with the circumstances, such as facts unique to the industry, would have recognized a hazardous condition warranting the use of that equipment.

Flash Fire Hazards

While the oil and gas industry has worked to reduce the risk of flash fire incidents, these efforts have not eliminated the occurrence of flash fires, nor the resulting burn injuries and fatalities. The use of FRC greatly improves the chance of a worker surviving and regaining quality of life after a flash fire. FRC can significantly reduce both the extent and severity of burn injuries to the body.

A flash fire is a fire that spreads rapidly through a diffuse fuel, such as dust, gas, or the vapors of an ignitable liquid, without the production of damaging pressure. The intensity of a flash fire depends on the size of the gas or vapor cloud. Hydrocarbon (oil and gas) flash fires generate temperatures of 1,000 to 1,900 degrees Fahrenheit. See NFPA 2112, National Fire Protection Association Standard on Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, 2007 Edition. The duration of a flash fire can last up to five seconds. NFPA 2112 and NFPA 2113 (Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, 2007 Edition) apply to general industry workplaces, including drilling, well servicing, and production-related operations. Inherent flash fire hazards are associated with oil and gas well drilling, servicing, and production-related operations. Additionally, the industry has a history of burn-related injuries and fatalities due to flash fire hazards when engineering and administrative controls have failed. Therefore, OSHA has concluded that employers are required to provide and ensure the use of FRC during certain operations as discussed below.

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