Stay Up to Date With Hazardous Location Safety for 2024
A safe and healthy working environment is a top concern for employers in hazardous locations and relevant regulatory agencies. In January 2023, OSHA released an aggressive new workplace safety program to cut workplace injuries and fatalities. Industries with dangerous environments have also witnessed a wave of new environmental legislation to reduce global emissions and their carbon footprint. As workplace safety and environmental regulations become more apparent in 2024, it can get confusing for players to keep track of all the recent laws. This article provides all the updates and predictions for hazardous location safety in 2024, including relevant OSHA regulations, environmental legislation, and EPA guidelines to be aware of.
OSHA Updates for 2023
With workplace safety taking center stage, the Biden Administration is focusing on enhancing investigation and enforcement activities against companies violating regulations. In this regard, OSHA has developed new workplace safety plans in 2023 to improve employees' health and well-being across industries. These initiatives include:- Strengthening enforcement: OSHA is set to increase the level of inspections and the number of citations issued for workplace violations. The agency announced it will deploy its subpoena powers during investigations.
- Targeting hazardous industries: OSHA announced it will target hazardous industries, such as construction, manufacturing, mining, and oil and gas to help reduce the high number of injuries and fatalities in these sectors.
- Emphasizing prevention: OSHA announced it would place greater emphasis on the prevention of accidents and injuries in the workplace. In this regard, employers have a duty to identify and address potential hazards that may contribute to injuries and illnesses.
Environmental Regulations for 2024
Undoubtedly, climate change has been a trending topic throughout 2022, with global emissions rising to alarming levels. The International Energy Agency revealed that global emissions rose by 6% in 2021 and 0.9% in 2022, reaching a new high of more than 36.8 billion tons. This unsustainable growth trajectory calls for more decisive action to move the world toward meeting its energy and climate goals. In an effort to curb emissions and protect the environment, the U.S. has established several environmental regulations targeting industries across all niches, including the oil and gas industry. Let's take a look at the environmental regulations targeting hazardous locations:- Clean Air Act: The Clean Air Act is an environmental regulation aimed at addressing runaway air pollution and rectifying the quality of air impacted by excessive carbon and methane emissions. In 2023, the act called for states and the EPA to solve pertinent air pollution problems by leveraging the latest science and technology information.
- Clean Water Act: This regulation protects freshwater systems, such as rivers, lakes, and streams. The act has helped rectify freshwater systems impacted by oil spills. With several amendments, the environmental regulation addresses today's climate change issues. On January 18, 2023, the EPA and the Army Corps of Engineers issued the Final Rule redefining Waters of the United States (WOTUS) subject to the Clean Water Act. The rule came into effect on March 20, 2024.
- SEC disclosure requirements: One of the biggest environmental regulations to come in 2023 in the U.S. is the requirement for the Securities and Exchange Commission to demand that companies disclose financial information related to the use of oil and gas production. These disclosures aim to increase transparency on the use of finite resources. It also helps protect investors from investing in companies that continue harming the environment by failing to curb their emissions.
EPA Guidelines
The EPA has already projected an aggressive rulemaking agenda. The agency is promulgating several Clean Air Act rules as part of its plan. The following are some of the EPA guidelines to watch:- Reconstruction of Particulate Matter (PM) Final Rule: The EPA recently released a proposed rule that lowers the existing PM 2.5 NAAQS Annual Standard from 12.0 ug/m3 (current) to 9.0 ug/m3 or 10.0 ug/m3. The proposed rule ended in March 2024, with the final rule expected for release in August 2024. A lower PM NAAQS will impact all industries by making it harder to pass ambient modeling, which is a requirement to seek a project permit. New and expanding facilities are required to undertake ambient modeling to obtain an air permit.
- The Good Neighbor FIP Final Rule: This rule applies to several power sector and manufacturing sector companies. It provides ozone season to run from May 1 to September 30. Utility units subject to the rule have to lower their NOx rates during the ozone season. The program has also added new concepts to tighten allowable NOx emissions.
- Section 111(b) and Section 111(d) Greenhouse Gas Rules (2024: TheSection 111(b) rule helps regulate greenhouse gases from new or modified fossil fuel generators. And the Section 111(d) rule provides greenhouse gas emission guidelines for fossil-fired units currently in operation.
Methane Mitigation Updates
On November 11, 2022, the EPA announced plans to strengthen proposed methane emissions and other air pollutants standards. If implemented as proposed, the plans will significantly impact oil and gas operations. Let's look at some of the more impactful aspects of proposed regulations that the EPA aimed to finalize in 2023.Routine Leak Monitoring at Each Well Site
All oil and gas companies, regardless of their size, are required to have routine leak monitoring at each well site and compressor station. The following is a breakdown of the new requirements:- Single wellhead-only well sites must undertake audio, visual, and olfactory (AVO) inspections every quarter, while those with a minimum of two wellheads must conduct quarterly AVO and optical gas imaging (OGI) inspections after every six months.
- Well sites with large-scale production and procession equipment must conduct bimonthly AVO and OGI inspections.
Updated Methane Reduction Mechanisms
Additionally, the EPA released a comprehensive approach to reducing methane pollution. The following are the updated elements:- New documentation on abandoned wells: Players must provide documentation that shows they appropriately decommissioned abandoned well sites and plugged them before monitoring can end.
- New super emitter requirement: The EPA requires a new super emitter program that leverages third-party expert monitoring to identify super emitters for urgent mitigation. The provision empowers authorized third parties to monitor oil and gas facilities and report detected leaks.
- New flares requirement: The EPA has proposed new requirements to ensure properly operated flares to reduce emissions. It has also prohibited natural gas flaring unless the operator submits a certified demonstration that alternatives aren't feasible for safety reasons.
- Adoption of new technologies: The agency has proposed innovative technologies, such as those provided by Aegex Technologies, for detecting leaks and monitoring leaks.
