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900 Oil and Gas Safety Management
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900 Oil and Gas Safety Management

Recognized and Foreseeable Hazards

When conducting the wellsite analysis, it's important to look for hazards that are generally recognized within the oil and gas industry. OSHA will require that recognized hazards which are generally foreseeable on the wellsite are properly eliminated or controlled.

"Recognized" Hazards

As described in OSHA's Field Operations Manual, recognition of a hazard is established on the basis of industry recognition, employer recognition, or "common sense" recognition criteria.

  • Industry Recognition: A hazard is recognized if the employer's industry recognizes it. Recognition by an industry, other than the industry to which the employer belongs, is generally insufficient to prove industry recognition. Although evidence of recognition by the employer's specific branch within an industry is preferred, evidence that the employer's industry recognizes the hazard may be sufficient.
  • Employer Recognition: A recognized hazard can be established by evidence of actual employer knowledge. Evidence of such recognition may consist of written or oral statements made by the employer or other management or supervisory personnel
  • Common Sense Recognition: If industry or employer recognition of the hazard cannot be established, recognition can still be established if it is concluded that any reasonable person would have recognized the hazard. This argument is used by OSHA only in flagrant cases. Note: Throughout our courses we argue that "common sense" is a dangerous concept in safety. Employers should not assume that accidents in the wellsite are the result of a lack of common sense.

Develop a Jobsite Safety and Health Program

OSHA's oil and gas standards require oil and gas employers to have accident prevention programs that provide for frequent and regular inspection of the jobsites, materials, and equipment by competent persons designated by the employers. See 29 CFR 1926.20(b).

NOTE: OSHA's Oil and gas Focused Inspection Policy recognizes the efforts of responsible contractors who have implemented effective safety and health programs, and encourages other contractors to adopt similar programs. Contractors who have implemented effective programs are eligible for focused inspections, should they be visited by an OSHA inspector. Focused inspections, which are narrower in scope than comprehensive inspections, target the leading oil and gas hazards. See Focused Inspections in Oil and gas.

For help in developing a program:

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