Not every hour on an oilfield carries the same flash fire risk, and OSHA has said so in writing. Its March 19, 2010 enforcement memo for oil and gas sorts the work into drilling, well servicing and production-related operations, and names the tasks where FR clothing is expected.
This guide walks through that list in plain language, explains why controls on site don't remove the need for FR, and ends with a gear plan built from NKE Safety Apparel pieces. Your employer's hazard assessment, not this article, decides what your job requires.
The short answer
FR clothing is expected wherever there is a potential for flash fire. OSHA's memo points to drilling once active gas or hydrocarbon zones are reached, to a long list of well servicing tasks, and to production work such as line breaking, gauging and hot work. It also says FR is usually not needed during early rig-up and routine drilling before those zones, unless other activities nearby call for it.
What a flash fire is, per OSHA
OSHA's memo describes a flash fire as a fire that spreads rapidly through a diffuse fuel such as gas or the vapors of an ignitable liquid, without producing damaging pressure. Hydrocarbon flash fires reach roughly 1,000 to 1,900 degrees Fahrenheit and can last up to five seconds. A flash fire needs fuel, oxygen and an ignition source. The memo lists common oilfield ignition sources: electrical systems, handheld electrical tools, motors, generators, hot work and static electricity.
Drilling: when the FR clothing goes on
The memo draws a line at the formation:
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Before active zones: FR is usually not needed during initial rig-up and normal drilling prior to reaching active hydrocarbon zones, unless other activities warrant it. The memo's example is fracturing a previously drilled well while rigging up a well nearby.
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At the zone: exposed employees on the well site should wear appropriate FR clothing before drilling into identified gas or hydrocarbon zones.
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With a kick history: FR should also be worn where there is a history of fluid or gas kicks from producing zones.
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Until the well is closed: once FR is called for, workers wear it until the final casing is cemented and the well is effectively closed.
The reasoning: when drilling reaches an active zone, pressure from below can push well fluids up the hole to the rig floor. If the blowout preventer or other engineering controls don't contain it, ignition sources nearby create a high potential for flash fire.
Well servicing: a long list
OSHA's memo says well servicing and workover operations on active or producing wells involve accessing and extracting oil and gas, and that work on inactive wells such as stimulating, plugging or capping also presents potential. The tasks it names include:
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Pulling wet string tubing and snubbing tubing
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Swabbing
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Fracturing or perforating the well
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Using bridge plugs or packers
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Open-hole work
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Flow testing, blowing down or venting the well
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Plugging an abandoned well
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Flowback operations
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Cementing and stimulation
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Wireline operations
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Any operation working with the wellhead or wellbore under pressure
Production-related operations: the tasks people forget
Production operations bring well fluids to the surface and separate, store, gauge and prepare them for delivery. The memo says the potential for flash fire also exists here, and lists:
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Equipment openings such as line breaking or valve changes
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Gauging
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Transfer of hydrocarbons
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Maintenance on production equipment
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Hot work
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Tank heating
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Using open flame
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Start-up operations
These are routine tasks, not emergencies, which is why FR clothing is worn as standard kit rather than saved for rare events.
Quick reference
|
Operation |
When OSHA's memo points to FR |
Examples named in the memo |
|
Drilling |
Before drilling into identified gas or hydrocarbon zones, and where kicks have a history, until the final casing is cemented and the well is effectively closed |
Rig-up and routine drilling before active zones usually don't need it unless other activities do |
|
Well servicing and workover |
The memo tells inspectors to check for FR during the listed tasks |
Flowback, swabbing, wireline, cementing, flow testing, plugging, any pressurized wellhead work |
|
Production-related |
The memo tells inspectors to check for FR during the listed tasks |
Line breaking, gauging, hydrocarbon transfer, hot work, start-up |
Why site controls don't remove the need
One reasonable objection is that blowout preventers and procedures already control the risk. OSHA's answer is that engineering and administrative controls reduce but do not eliminate flash fire potential. The memo gives examples of how they fail: BOP malfunction, hydraulic failure, gauge or indicator error, power disruption and valve failure on the engineering side, and deviating from procedures, failing to close valves or failing to activate the emergency shutdown system on the administrative side. FR clothing is the layer that still works when those fail.
What your employer owes you
The memo also lists the other parts of OSHA's PPE standard that inspectors may cite for FR clothing:
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1910.132(b): employee-owned FR clothing must be properly maintained and sanitary.
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1910.132(c): FR clothing must be of safe design and construction for the work. Employers may consult NFPA 2112 and 2113.
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1910.132(d): the employer must assess the burn hazard from flash fire.
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1910.132(e): defective or damaged FR clothing must not be used.
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1910.132(h): the employer must provide, at no cost to employees, FR clothing used to comply with the standard.
The memo also notes that, for its purposes, FR clothing includes both flame-resistant and fire-retardant-treated clothing.
The memo is from 2010. Check OSHA's current guidance and your employer's policy, and confirm the cost rules for your situation with your employer or OSHA.
Turn the list into a gear plan
Crews often move between task types in one shift, so a practical approach is a full FR kit worn for every listed task, with weather layers that are FR too. Check each product page for the standard your site names (oil and gas sites typically work from NFPA 2112) before ordering. The listings below give fabric details only.
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Shirts: the NKE FR Edge Ripstop Snap Shirt (6.5 oz 100% cotton ripstop) and the NKE FR Long Sleeve T-Shirt (6.5 oz 100% cotton), in the FR shirts collection.
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Base layer: the NKE FR Baselayer Tee (5.5 oz modacrylic-blend knit with spandex).
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Pants: the NKE FR Flex Canvas Stretch Work Pants (10 oz, 87% cotton, 12% nylon, 1% spandex) or the NKE FR Maverick Denim Jeans (12 oz 100% cotton), in the FR pants collection. Our guide to FR pants for oil and gas workers compares them.
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Cold-weather layers: the NKE FR Full Zipper Hoodie (12 oz 100% cotton) and the NKE FR Insulated Bib Overall, in the FR outerwear collection.
Two extras for specific tasks on the memo's list: if your production work includes hot work, read our guide to the best FR gear for welding. If you also work near energized equipment, arc flash is a separate hazard evaluated under different standards, covered in our NFPA 70E FR clothing requirements post.
Clean clothing matters as much as the right clothing. See how to wash FR clothing without ruining its flame resistance.
Build your crew's FR kit
Start from your hazard assessment, match the task list to your site's operations, then outfit the crew with clean, intact FR layers. Browse the NKE Safety Apparel FR clothing collections, or if you are outfitting a team, see the distributor program, our guide to buying FR clothing in bulk, or email Onlinestore@nkesafetyapparel.com.
FAQs
1. Do you need FR clothing during rig-up? OSHA's memo says FR clothing is usually not needed during initial rig-up and normal drilling before active hydrocarbon zones, unless other activities nearby warrant it. Your employer's hazard assessment makes the call for your site.
2. When should FR clothing be worn while drilling? Per the memo, exposed workers on the well site should wear it before drilling into identified gas or hydrocarbon zones, and where there is a history of kicks, until the final casing is cemented and the well is effectively closed.
3. Which well servicing tasks need FR clothing? The memo names tasks including pulling wet string tubing, swabbing, fracturing or perforating, flowback, cementing, stimulation, wireline work, flow testing and any work with a pressurized wellhead or wellbore.
4. Does the employer pay for FR clothing? OSHA's memo says inspectors may cite employers that fail to provide, at no cost to employees, FR clothing used to comply with the PPE standard. Confirm the details for your situation with your employer or OSHA.
5. Is treated FR clothing allowed in oil and gas work? For purposes of OSHA's memo, FR clothing includes both flame-resistant and fire-retardant-treated clothing. Your hazard assessment and site policy decide which suits your work.
6. Is FR clothing only for emergencies? No. The memo looks at the potential for flash fire during routine tasks such as gauging, line breaking and flowback, because controls can fail. FR clothing is worn for those tasks, not just after something goes wrong.
