U.S. Department of Labor
Occupational Safety and Health Administration
Dallas Regional OSHA Office
And the
Association of Energy Service Companies (AESC)

1. Alliance Background

   1. Date Signed

      Original Alliance signed on September 24, 2013, and renewed on February 17, 2016, and April 17, 2018.

   2. Evaluation Period

      September 24, 2017 to September 24, 2018

   3. Overview

      Through the OSHA and AESC Alliance, the organizations are working together to provide AESC members and affiliates in the well servicing industry with information, guidance, and access to training resources to protect employees' health and safety. OSHA Region VI and AESC continue to successfully partner together to achieve consistent improvements in the safety and health of workers in the well servicing industry. AESC has approximately 600 member companies who employ between 350,000 to 400,000 workers.

   4. Implementation Team Members

      OSHA
      
      Eric Harbin, OSHA Region VI Acting Regional Administrator
      Josh Flesher, OSHA Region VI Assistant Regional Administrator – Cooperative and State Programs
      Doug Huddleston, OSHA Region VI Alliance Coordinator
      
      AESC

      Kenny Jordan

      Executive Director

      Kevin Northcutt

      HSE Committee Chair

      Matt Daniel

      HSE Committee Past Chair

      Danny Thomas

      HSE Committee Vice Chair

      Nick Messersmith

      HSE Committee Secretary/Treasurer

      Eric Rosemann

      HSE Committee member

      Lonnie Neitermayer

      HSE Committee member

      Thomas Francis

      HSE Committee member

      David Etchelecu

      HSE Committee member

      Ian Spahr

      HSE Committee member

2. Implementation Team Meetings

   The executive committee members and officers meet in person, and via conference call to plan for upcoming events. The executive committee members assist the officers with lining up sponsors and speakers at the bimonthly meetings as well as facilitate the meetings. OSHA Region VI personnel meet with executive committee members to discuss and plan upcoming events.

   Training and Education

   • 10/01/2017 – AESC participated with South Texas Exploration and Production Safety Network (STEPS) in the development of the Hot Work Hazard Alert that was originally released on September 30, 2017. AESC was instrumental in the distribution of the alert was to all membership, and distribution to industry through an advertisement in their Well Servicing Magazine.
   • 10/01/2017 – AESC participated in the development of the "Limitations on Monitors" Hazard Alert, which ran through September 2017. The Hazard Alert document was released for circulation in early December 2017.
   • 10/01/2017 – AESC continues to participate along with other industry leaders, OSHA, and the American Petroleum Institute (API) in the revision of the API RP 54 Standard, which is titled "Recommended Practice for Occupational Safety for Oil and Gas Well Drilling and Servicing Operations." The committee meets monthly to coordinate and affect any recommended changes to the document. The revision project is ongoing and was scheduled for consensus voting and release in the second quarter (Q2) of 2018.
   • 02/22/2018 – 02/23/2018 – AESC Annual Winter Meeting - AESC hosted their Annual Winter Meeting at the Hilton Palaci del Rio located in San Antonio, Texas. On February 21, 2018, members met for an opening Executive Committee Meeting, followed by a day of golfing at the Republic Golf Course located in San Antonio, Texas. The Annual Winter Meeting featured various panel discussions, including analysis of industry trends, regulatory issues, as well as the Health, Safety and Environmental Committee Safety Awards Presentation. Additionally, Alex Porter, San Antonio Area Office, Area Director, provided an OSHA industry update, that provided statistics on incidents, accidents and trends observed regarding safety and health in the oil and gas industry.
   • 03/27/2018 – A quarterly planning meeting was scheduled and held via teleconference with AESC executive committee members for the purpose of discussing upcoming events, such as the Alliance renewal, the Oil & Gas Safety and Health Conference in December, the proposed service rig orientation training for OSHA Compliance Safety and Health Officers (CSHO), as well as other planned activities during the quarter.
   • 04/17/2018 – The AESC – OSHA Alliance was renewed and signed by the Regional Administrator, and Joe Freeman, President, AESC during the AESC Safety/Wireline Trucking Tradeshow & Conference. Additionally, personnel from the Fort Worth Area OSHA Office, along with personnel from the Texas Department of Insurance OSHA Consultation (OSHCON) staffed a booth at the Conference, distributed DOL/OSHA Quick Cards and Fact Sheets, and answered Conference participants' questions. There were approximately 115 attendees at the Conference.
   • 05/24/2018 – OSHA Region VI Alliance Coordinator drafted an article for the Well Servicing magazine "Work Smart, Avoid Heat Injuries" as continuing support of the AESC Alliance. The draft article provided statistical data showing workers at risk for heat related injuries, risk factors that subject workers to greater risk of injury, recognition and avoidance techniques, as well as tools available, such as the OSHA-NIOSH Heat Safety Tool App that can be utilized out in the field environment. The article was provided to the AESC executive committee members for review.
   • 08/22/2018 – Rig Orientation and H2S Hazard Awareness Training - AESC member companies PEC Safety, Pioneer Energy Services, Accurate Safety Compliance, Shebester Bechtel and other companies hosted a one day training event at the Canadian Valley Technology Center, located in El Reno, Oklahoma. The training focused on the safety and health procedures used in industry, and methods of compliance with OSHA regulations. Approximately 18 OSHA Compliance Safety and Health Officers from the Oklahoma City, and Little Rock OSHA Area Offices, along with their Assistant Area Directors, and four representatives of the Oklahoma Department of Labor OSHA Consultation Division participated in the training. Additionally, Richard Emberling, PEC Safety representative provided a four-hour H2S hazard awareness training to attendees.
   • 04/05/2018 through 10/10/2018 – Planning efforts continued for the purpose of providing support for the Oil & Gas Safety and Health Conference that is scheduled for December 4th and December 5, 2018, and will be held at the Hilton Americas – Houston. Representatives from University of Texas Arlington (UTA) OSHA Training Institute Education Center, AESC, STEPS Network and OSHA Region VI participated in a series of planning and update teleconferences.
   • 06/11/2018 – Kenny Jordan, AESC Executive Director, provided Mid Continent Exploration and Production Safety Network (MCEPS) members a presentation on "2012 – 2015 Incidents and Citations in Upstream Oil and Gas Industry." The presentation provided MCEPS members with a history of AESC organization, as well as safety statistics tracking programs for Industry and Well Servicing organizations. Additionally, Kenny provided information on "Safe Land" training, which provides workers in the oil and gas servicing industry safety and health training that is crucial to maintaining a safe workplace. The presentation also included an overview of various NAICS codes prominent hazards and current challenges to worker safety. Included in the comparison of various industries was NAICS 2113112, Support Activities for Oil and Gas Operations. Kenny also highlighted important information on leading and lagging indicators, including representative comparisons of each, and their impact on managing a company's safety and health program.
   • 10/10/2018 – Planning began to host the fourth annual AESC "Well Servicing Rig Orientation and Training" which is tentatively scheduled to be held in Corpus Christi, Texas. The event will focus on the safety and health procedures involved in oil and gas well servicing and how the industry complies with OSHA regulations, and afford OSHA Compliance Safety and Health Officers (CSHO) the opportunity to interface with leading industry well-servicing employees and safety professionals, as well as receive instruction on rig operation, and a detailed overview of hazards. Additionally, well-servicing employees and safety professionals are offered the opportunity to speak directly with OSHA representatives to discuss current safety and health issues. The training is scheduled to be held on November 1, 2018.

   Raising Awareness of OSHA's Rulemaking and Enforcement Initiatives

   • 07/19/2018 – Kenny Jordan, AESC Executive Director and the AESC Safety Committee Staff have proved instrumental in the revision and update of the OSHA Oil & Gas Well Drilling & Servicing e-Tool. As an active Alliance partner, AESC provided OSHA with the assurance that our Oil & Gas Well Drilling & Servicing e-Tool was a viable tool that would assist others in the industry with important safety and health information. AESC continues to participate in the post-review process of the Oil & Gas Well Drilling & Servicing e-Tool revision.

   Outreach and Communication

   AESC continues to work with the South Texas Exploration and Production Safety Network (STEPS), North Texas Exploration and Production Safety (NTEPS), Mid Continent Exploration and Production Safety Network (MCEPS), and other networks involving exploration and production companies to promote the National Dialogue on Workplace Safety and Health. Through their work on the revision and improvement of the OSHA Oil & Gas Well Drilling & Servicing e-Tool, development of Hazard Alert Letters, and revision of the API RP 54 standard, AESC continues to advance safety and health hazard awareness, and is instrumental in communicating these hazards throughout the oil and gas industry.

   Projects and Workgroups

   Throughout 2018, AESC Health and Safety Executive Committee members continue to play a key role in supporting OSHA, and raising safety and health awareness throughout the industry. Significantly, AESC was instrumental in providing their submission to improve the "Plug and Abandonment" portion of OSHA's Oil & Gas Well Drilling & Servicing e-Tool. AESC continues to participate along with other industry leaders, OSHA, and the American Petroleum Institute (API) in the revision of the API RP 54 Standard, which is titled "Recommended Practice for Occupational Safety for Oil and Gas Well Drilling and Servicing Operations." Additionally, AESC plays a key role, along with other groups, such as the South Texas Exploration and Production Safety Network (STEPS) as well as Mid Continent Exploration and Production Safety Network (MCEPS) to produce and disseminate safety and health hazard information throughout the oil and gas industry.

3. Results

   Activity	Number of Individuals Reached or Trained
   AESC Safety/Wireline Conference & Tradeshow	115
   Well Servicing magazine articles on the following:
   Oil & Gas Conference	9,000
   AESC Safety/Wireline Conference	9,000
   "Work Smart, Avoid Heat Injuries"	9,000
   CSHO and AESC Joint Rig Training	9,000
   "AESC Safety Statistics for 2017"	9,000
   "Safety for the Field Hand Rookie"	9,000
   "Safety in Lone Worker Scenarios"	9,000
   "Railroad Safety"	9,000
   Hydrogen Sulfide (H2S) Training	34
   Total	72,149

4. Upcoming Milestones

   • AESC and OSHA continued participation in the upcoming Oil & Gas Safety and Health Conference - (December 2018)
   • AESC and OSHA continued participation in the upcoming Oil & Gas Safety and Health Conference - (December 2018)
   • Continued emphasis on Oil & Gas Hazards training – Corpus Christi Area Office located in Region VI.
   • Continued emphasis on collaborating and assisting OSHA participants through AESC's Service Rig Orientation Training (November 2018)
   • AESC Safety/Wireline Conference & Tradeshow (August 2019)

   Well Servicing magazine articles (10)

   • Drugs in the Workplace (Sept/Oct edition Well Servicing Magazine) – Kenny Jordan
   • Life Behind the Wheel in the Oilfield (Sept/Oct edition Well Servicing Magazine) – Paul Shouse
   • OSHA New Recording Keeping Reporting Rules (July/Aug edition Well Servicing Magazine) – Rick Ingram
   • What's New in Lockout/Tagout (July/Aug edition Well Servicing Magazine) – Total Safety
   • How to Handle Universal Waste (May/June edition Well Servicing Magazine) – Al Pickett
   • BLS/OSHA Fatality Statistics Released; Trying to Make Some Sense of It All (March/April edition Well Servicing Magazine) – Kenny Jordan
   • Publication of 2017 AESC Safety Statistics Results (March/April 2018 edition Well Servicing Magazine) – Kenny Jordan
   • DOT and FMCSA Update (March/April edition Well Servicing Magazine) – Central Analysis Bureau
   • Accidents and Health Issues…Are You Ready (Jan/Feb edition Well Servicing Magazine) – Joyce Ryel
   • Updated Recordkeeping/Reporting Regulations (Fall 2017) – Doug Huddleston
   • Heat Stress (Spring 2018) – Doug Huddleston

   Alliance Progress Meetings:

   Quarterly progress meetings were held on March 17, 2018 and April 17, 2018 with AESC executive committee members to assess the Alliance effectiveness and to facilitate coordination for upcoming events, such as the service rig orientation and H2S hazard awareness training for OSHA CSHO's, Oil & Gas Safety and Health Conference scheduled to be held December 4th through December 5, 2018, as well as other planned activities during the quarter.

   Summary:

   This Alliance continues to provide a means for OSHA and AESC to collaborate on important safety and health issues affecting the oil and gas industry, improve OSHA's ability to provide compliance assistance to industry companies and their workers. AESC was instrumental in the revision and improvement of OSHA's Oil & Gas Well Drilling & Servicing e-Tool. This e-Tool has, and will continue to be utilized throughout the industry and will help make oil and gas operations safer. The Alliance continues to provide a means for AESC to share information through articles published in their publications, and affords OSHA a voice, greatly augmenting and expanding OSHA's capability to reach workers throughout the industry.

   Report prepared by: Doug Huddleston, OSHA Region VI Alliance Coordinator, October 30, 2018.