ArticlesGuidance on Handling Cases Developed Pursuant to the FRC Enforcement Policy Memorandum
This is to provide guidance on application of the Enforcement Policy for Flame-Resistant Clothing in Oil and Gas Drilling, Well Servicing, and Production-Related Operations (March 19, 2010) ("FRC memorandum"). As discussed below, the FRC memorandum identifies specific operations in the oil and gas industry where there is a potential for flash fires. Where employees engaged in such operations are not using FRC, compliance staff should carefully evaluate available information to determine whether a hazard requiring use of FRC is present. FRC cases in these industries are novel issue cases under the National Framework for Workload Agreements and the Procedures for Significant or Novel Enforcement Cases, which means that early consultation between OSHA and SOL is necessary. |
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