Matthew Navea | Preferred Sands
For those in the oil and gas industry, 2015 might be a year they wish to forget – and for good reason. The price of oil steadily declined over the previous year, a trend that is expected to continue into 2016 due to a surplus of oil caused by increased production overseas. It’s not all bad though.
Despite analysts’ low forecasts, the oil and gas industry is still taking positive steps forward. One of those steps is improving worker safety at the wellsite, which I expect will be a major focus of many oil and gas companies in the coming year.
You might be wondering, why now? Don’t companies always make the safety of their employees a top priority? That answer is yes. However, there is one major change in regulation on the horizon that is sure to impact the way the industry operates moving forward.
Silica sand, a key ingredient in hydraulic fracturing operations, is about to take center stage.
Workers engaged in the frac sand supply chain and in hydraulic fracturing can be at risk for developing silicosis. Silicosis is an incurable but preventable disease, caused by the inhalation and retention of free silica. Once enough silica has been retained within the lungs, inflammation and scar tissue can create lifelong lung damage. For individuals with moderate to severe silicosis, the prognosis is poor – only the symptoms can be treated. Silicosis is one of the oldest occupational diseases that has been researched, and cases can be traced back to ancient Egypt.
Based on recent data from the US Census Bureau and other industry sources, the Occupational Safety and Health Administration (OSHA) reports that nearly two million workers in the U.S. are at risk of silica exposure, and more than 100,000 of those workers are in high-risk jobs.
In 2013, the National Institute for Occupational Safety and Health (NIOSH) published a study1 which found that worker exposure to silica sand in hydraulic fracturing “routinely exceeded occupational criteria, and, in some cases, up to 10 or more times.”
OSHA has focused on reducing the Permissible Exposure Limit (PEL) to crystalline silica for some time. This has culminated in a new proposed rulemaking (NPRM) in September 2013. The NPRM proposes a host of changes to the existing rule as well as a significant reduction to the PEL for crystalline silica to 50 micrograms per cubic meter of air, decreasing PELs by about half. Since the NPRM proposal in 2013, OSHA heard from more than 200 stakeholders and received more than 1,700 comments, which are expected to influence the final rule, projected to be completed in February 2016.
The proposed reduced PEL would be applicable to construction and general industry, which includes companies engaged in hydraulic fracturing. It is widely expected that the Mine Safety and Health Administration (MSHA) will also revise their standard to reduce their exposure limit.
Based on recent data from the U.S. Census Bureau and industry sources, OSHA estimates that roughly 25,000 workers in 444 establishments (operated by 200 business entities) engaged in hydraulic fracturing would be affected by the proposed standards.
The hydraulic fracturing industry is eager to optimize worker safety, and with a national spotlight on the industry and its wellbeing, it is more important than ever that we prioritize silica exposure and keep our employees safe.
NIOSH has identified several ways to control silica dust at the work site, as outlined in the hierarchy of controls. Personal respiratory protection is among the most common controls at the wellsite, though the Center for Disease Control reports that, independently, these will not adequately protect workers from the dangers of silica dust. In fact, OSHA has cited companies in the past for relying on such equipment as a primary protection for workers.
And while engineering controls, such as mechanical ventilation and vacuum systems, are preferred over administrative controls, they are still flawed. For example, mechanical ventilation requires the installation of dust collection units, routine field modifications, which can lead variable effectiveness, tripping hazards and maintenance hassles.
While elimination is the most effective control at reducing silica dust, it is very challenging to implement. Second only to water, frac sand is the most common component in the hydraulic fracturing process. Rather than eliminating frac sand from the recipe, I expect that companies will begin to implement innovative dust-control products, such as treated sands or other types of proppants.
By using dust-control treated proppants, oil and gas companies can meet OSHA’s new regulations and effectively eliminate fugitive dust. These proppants also allow companies to remove unnecessary bulky equipment, which eliminates dozens of unsafe tripping hazards, provides easier access to critical equipment – including the blender and transfer belt areas – and most importantly, increases well-site efficiency.
With OSHA’s final ruling on silica dust set to be handed down in just a few short months, I expect that innovations in 2016 will focus on adhering to the new guidelines and ensuring the safety of workers at the wellsite. In my opinion, bringing treated silica sand to the wellsite is an extremely efficient way to protect our workers, especially during a time when all eyes are on oil and gas.
- Esswein, E.J., Breitenstein M., Snawder, J., Kiefer, M., and Sieber K.,: Occupational Exposures to Respirable Crystalline Silica During Hydraulic Fracturing, Journal of Occupational and Environmental Hygiene, 10:7, 347-356 (2013)