In this revised memo, OSHA clarified that its 2010 memo that suggested employers would be cited for a violation of the PPE standard whenever workers were not wearing flame-resistant and fire-retardant clothing was not the intent of the 2010 memo.
OSHA stated that employers would only be cited if OSHA could additionally prove that a reasonable person would recognize the existence of a hazardous condition that would require the use of PPE. Although this is not a change from the typical case law analysis for the PPE standard, it is a shift in OSHA's enforcement position regarding the use of PPE specific to the oil and gas industry.
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