OSHA Instruction STD 1-2.1 October 30, 1978

OSHA Program Directive #100-67

TO: REGIONAL ADMINISTRATORS/OSHA

THRU: Acting Field Coordinator

Subject: 29 CFR 1910.36(b)(8) Means of Egress; Fundamental Requirements Relative to Workover Rigs Used to Service Oil Wells

1. Purpose

The purpose of this directive is to provide guidance to the field on the applicability of 29 CFR 1910.36(b)(8) to workover rigs used to service oil wells.

2. Documentation Affected

None.

3. Background

a. The term "workover rigs" as used in this directive means telescoping derricks permanently attached to trucks which are used to service oil wells. Several recent legal decisions have vacated citations issued for violations of 29 CFR 1910.36(b)(8) on workover rigs. Basically, the standard provides for at least two means of egress remote from each other.

b. The citations were vacated on the basis of the exemption in 29 CFR 1910.36(a), which provides:

Exits from vehicles, vessels, or other mobile structures are not covered by this subpart (on means of egress).

4. Action

a. The standards in Subpart E - Means of Egress, Part 1910, shall not be applied to workover rigs because they are mobile structures and parts of vehicles within the exemption set forth in 29 CFR 1910.36(a).

OSHA Instruction STD 1-2.1 October 30, 1978

b. Section 5(a)(1) of the Act shall be cited when workover rigs have no means of egress or the means of egress is inadequate, when such conditions present recognized hazards causing or likely to cause death or serious physical harm. The determination whether such conditions pose such hazards must be made on a case-by-case basis.

5. Effective Date

This directive is effective upon receipt and will remain in effect until canceled or superseded.

Richard P. Wilson Deputy Director, Federal Compliance and State Programs

DISTRIBUTION: A-1 E-1 B-2 HEW-1 C-1 NIOSH Regional Program Directors-1 D-4&5 NACOSH-l Training Institute-4

(Originator:OCCS)