American Pipeline Contractors Association

OSHA Interim Enforcement Guidance

Interim Enforcement Guidance for the Respirable Crystalline Silica in Construction Standard

Last month OSHA shared a memorandum announcing that for the first 30 days of enforcement of the Respirable Crystalline Silica in Construction Standard, employers making a good faith effort to comply with the standard were offered compliance assistance in lieu of enforcement. As the 30 days come to a close, OSHA has issued a memorandum with interim enforcement guidance while a compliance directive is under review. The memorandum provides inspection and citation guidance for Compliance Safety and Health Officers (CSHOs), and it includes flow charts to assist compliance officers with evaluating employers’ control methods.

APCA Safety Meeting Minutes - February 28, 2019

APCA Safety Committee Meeting

February 28, 2019

Sheraton North Houston at George Bush Intercontinental

Houston, Texas

1. Welcome

Committee Chair Ron Oakley, Sunland Construction, welcomed attendees and shared information on the location of the room's emergency exits and where everyone should meet in case of an emergency.

The following representatives from APCA-member companies were in attendance:

Charles Bush, T&C Rentals

Ricky Dyess, M.G. Dyess, Inc.

David Evans, R Construction

Miles Hester, Progressive Pipeline Construction, LLC

Todd Johnson, Strike LLC

Jerry Kuhn, TWS Drilling

John Lohman, Sterling

Richard Moe, WB Pipeline, LLC

James T. Roberts, Pumpco, Inc.

Jose Ruiz, Sunland Construction, Inc.

Chuck Simpson, EPIC Brokers

Cameron Strother, Southland Safety

Nick Tarquinio, Holloman Corp

Doug Warner, Troy Construction

Clint Wilson, WHC Energy Services

APCA Staff: Mike Ancell

2. APCA Executive's Opening Comments

APCA Board member Ricky Dyess thanked attendees for coming to the Safety Committee meeting and for their involvement. He said that the APCA Board strongly supports the committee's efforts. He feels that the open-shop side of the pipeline industry has been lagging behind in promoting itself and that safety provides a great opportunity to get our message out. He said that the Best Practices put together by this committee are used industry-wide, including by INGAA in many of their safety materials. He also reported that the APCA Board is looking at developing an operator-assessment program and will be meeting with a company at the upcoming APCA Convention to discuss the program.

3. Safety Moments

Being a foggy day in Houston, the group discussed driving safety and the importance of focusing on driving rather than holding conversations or messing with one's phone. One attendee compared driving to aviation, saying that drivers should use checklists to get into the mindset of a pilot. Another attendee had a recommendation for alleviating tripping hazards around the house at night or early morning: little LED lights.

4. Introductions

All participants introduced themselves and shared their company name, years in the industry, and something good that had recently happened to them or their family.

5. OSHA Alliance Meetings

Ron Oakley reported that the next OSHA Alliance event is April 4, 2019, in Washington, D.C., and an APCA-OSHA Alliance teleconference is scheduled for April 17, 2019. Oakley will attend the April 4 meeting.

6. Best Practices Review and Update on Assignments

Ron Oakley updated the committee on the Best Practices review process that was begun at the last meeting. In November, committee members volunteered for specific Best Practices to review and update. Oakley said that most people had returned their sections and that some were combined. There are still a few outstanding. The completed Best Practices will be posted for committee members to review before the May 9 Safety Committee meeting. If anyone sees an issue in one of the documents, alert the committee and it will be discussed in May. Oakley said that one topic was added to the list, Heat-related Illness, and since he was already reviewing the Cold Weather document, he took on the new topic. After the committee approves the Best Practices in May, they will be sent to OSHA for their review.

7. Develop New Best Practices

It was suggested that the committee develop Best Practices for vacuum excavation because most everyone is doing it. Jim Roberts from Pumpco volunteered to create a draft on vacuum excavation. It was noted that fatigued driving is a big deal in the pipeline industry and a major problem across all industries. Mark Beisecker of Cobbs Allen agreed to create draft Best Practices for Fatigued Driving. The committee discussed adding the topic of General Vehicle Safety, maybe taking the Distracted Driving Best Practices and adding Fatigued Driving and General Vehicle Safety. It was noted that it might make the document too long. Miles Hester, Progressive Pipeline, will draft Driver Best Practices, and Ron Oakley will look at them to see if it works better as one document or two. Oakley will also create draft Best Practices for Job Safety Analysis. Once the committee approves the Best Practices, Jose Ruiz of Sunland Construction will translate them into Spanish.

8. Common New-Hire Orientation for APCA Members

The group continued its discussion on the possibility of creating a common new-hire orientation for APCA members. Staff had been tasked with researching the cost of a video and learned that we need much more information to get a useful estimate, including length of video, number of days of shooting, how audio would be handled, and where the video would be shot. Committee members had a variety of ideas and opinions on those subjects. It was asked if Caterpillar's safety orientation video might be publically available. This is a subject to be taken up at the APCA Board level to determine if there is actually a need among contractor members and if there is a budget for it.

9. Lessons Learned Repository on APCA Safety Zone Site

The committee continued its discussion about creating a repository of safety-related lessons learned on the Safety Zone section of the APCA website, similar to what the INGAA Foundation does on its website. The submissions would be anonymous and reviewed by the subcommittee of the Safety Committee before being posted. APCA members would receive an email alert when new lessons learned become available. It was asked if APCA lawyers should be consulted. This is another subject to be taken up at the APCA Board level to determine if there is actually a need among contractor members and if there is a budget for it.

10. Creating a Merit-Shop Safety Message

Moving along its goal of creating a safety message to promote the safety accomplishments of the merit-shop pipeline industry, the committee tabbed John Lohman of Sterling to lead the effort to plan the message, create a draft message, and explore best methods for delivering the message. Cobbs Allen's Mark Beisecker will work with him. They were also tasked with creating the form/survey that will go out to APCA contractor members to collect safety data. The message will ultimately be delivered at client meetings, safety seminars, etc.

11. Guest Speakers for Future Quarterly Meetings

Looking to add value to APCA's quarterly safety meetings, the committee further discussed possible guest speakers and topics. The committee was interested in hearing from a speaker from U.S. Industrial Certifications who does strength testing for chains, slings, etc., and Clint Wilson, WHC Energy Services, said he will look into getting him for the May 9 meeting. Attendees were also interested in a speaker on cognitive behavior, which we will try to schedule for the August 15 meeting. Jose Ruiz, Sunland, said he would look into a speaker from VeriForce on operator qualification, and Todd Johnson, Strike LLC, said he would look into a speaker on DOT trucking regulations.

12. Next APCA Safety Committee Meeting - May 9

The committee will meet next on May 9, 2019, at the Sheraton North Houston at George Bush Intercontinental in Houston, Texas. The Q3 meeting is on August 15, and Q4 is on November 7 at the same hotel. Ron Oakley said that next year's dates will closely mirror this year's, still on Thursdays and at the same hotel.

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