OSHA issued a new guidance document in December regarding the use of personal protective equipment (PPE) by oil and gas well workers. This document was posted this month on OSHA's website. 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. Read on at from Carla J. Gunnin Author
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