The Occupational Safety and Health Administration (OSHA) has issued COVID-19 guidance for workers and employers in the oil and gas industry. While this guidance is specifically geared to the oil and gas industry, the guidance is not unlike other best practices OSHA has recommended for other workers in the general industry.

Since each drilling and production site is not identical, employers should initially conduct a risk assessment of their worksites and then consider implementing some of the following engineering and administrative controls, where feasible, recommended by OSHA:

• Stagger workers’ arrival and departure times to avoid congregations of workers

• Provide visual cues (e.g. floor markings, signs) as a reminder to maintain social distancing of 6 feet

• Designate workers to monitor and facilitate distancing

• Limit the number of personnel allowed in dog houses, control rooms and other operating areas

• Stagger break times or provide temporary break areas, including for water breaks, and restrooms to avoid groups of workers gathering during breaks

• Encourage workers to avoid carpooling to and from work and job sites

• Provide workers with hand washing stations as well as alcohol-based hand sanitizers in multiple locations

The extend of implementation of these measures will depend, in part, on the level of risk exposure (lower, medium, high or very high) that accompany a worker’s task. While the measures listed above do not constitute binding regulatory standards, OSHA will likely refer to these administrative and engineering controls when deciding whether or not to issue COVID-19 related citations under their catch-all provision, the General Duty Clause. Accordingly employers should be well versed in the specific guidance provided by OSHA. Complete guidance recommended by OSHA can be viewed on OSHA’s coronavirus webpage. For further information about the coronavirus, please visit the Centers for Disease Control and Prevention.