Regional Emphasis Program for the Upstream Oil and Gas Industry

U.S. DEPARTMENT OF LABOR Occupational Safety and Health Administration
DIRECTIVE NUMBER: B HM-CPL-04-00-004
SUBJECT: Regional Emphasis Program for the Upstream Oil and Gas Industry
REGION: Birmingham Region
SIGNATURE DATE: July 30, 2026 EFFECTIVE DATE: October 1, 2026
ABSTRACT
Purpose: The purpose of this instruction is to renew a Regional Emphasis Program
(REP) to reduce accidents, fatalities, and catastrophic events in the
upstream oil and gas industry.
Scope: This Instruction applies to all Birmingham Region Federal Offices.
References: See Section III.
Cancellations: This instruction supersedes OSHA Regional Instruction BHM-CPL-04-00-
004, Regional Emphasis Program for the Upstream Oil and Gas Industry,
April 17, 2025.
State Impact: No Impact.
Action Offices: Baton Rouge, Birmingham, Jackson, Little Rock, Mobile, and Nashville
Federal Offices.
Originating Office: Birmingham Regional Office
C
ontact: Assistant Regional Administrator for Enforcement Programs
By and Under the Authority of
Do
rinda Hughes
Regional Administrator

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Executive Summary

This instruction reissues an enforcement initiative to reduce fatalities and catastrophic events
in the upstream oil and gas industry as part of the OSHA regional realignment. The specified
target industries are Drilling Oil and Gas Wells – NAICS Code 213111, Support Activities for Oil
and Gas Operations NAICS Code 213112, Oil and Gas Field Services –NAICS Code 213118, Oil
and Gas Pipeline and Related Structures Construction NAICS Code – 237120, Site Preparation
Contractors - NAICS Code 238910, Geophysical Surveying and Mapping Services - NAICS Code
541360.

Significant Changes
• Birmingham, Mobile, and Jackson Area Offices Added.
• Updated the OSHA Information System inspection numbers.
• Updated Bureau of Labor Statistics charts and information.

Table of Contents

I. Purpose. ................................................................................................................................... 1
II. Scope. ...................................................................................................................................... 1
III. References. .......................................................................................................................... 1
IV. Cancellations. ....................................................................................................................... 1
V. Action Offices. .......................................................................................................................... 1
A. Responsible Office. .............................................................................................................. 1
B. Action Office. ....................................................................................................................... 1
C. Information Offices. ............................................................................................................. 1
VI. Federal Program Change. .................................................................................................... 2
VII. Expiration. ............................................................................................................................ 2
VIII. Significant Changes .............................................................................................................. 2
IX. Background .......................................................................................................................... 2
X. Enforcement .......................................................................................................................................5
A. Hazards ................................................................................................................................. 5
B. Specific Industries ................................................................................................................ 5
C. Scheduling of Inspections..............................................................................................................5
D. Scope of LEP Inspections ..............................................................................................................6
E. Citations...........................................................................................................................................7
F. Interface with Unprogrammed Activity......................................................................................7
G. Inspection Resources....................................................................................................................7
H. CSHO Personal Protective Equipment. ......................................................................................7
I. Relationship to Other Programs..................................................................................................7
XI. Recording in OIS................................................................................................................................7
XII. Outreach.............................................................................................................................................9
XIII. Partnerships and Alliances...............................................................................................................9
XIV. Evaluations.........................................................................................................................................9

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I. Purpose.

This instruction renews an enforcement initiative to reduce accidents, fatalities and
catastrophic events in the upstream oil and gas industry as part of the OSHA region
realignment. The specified target industries are Drilling Oil and Gas Wells – NAICS Code
213111, Support Activities for Oil and Gas Operations NAICS Code 213112, Oil and Gas
Field Services –NAICS Code 213118, Oil and Gas Pipeline and Related Structures
Construction NAICS Code – 237120, Site Preparation Contractors - NAICS Code 238910,
Geophysical Surveying and Mapping Services - NAICS Code 541360.

II. Scope.

This instruction applies to all Birmingham Region Federal Offices.
III. References.
A. OSHA Instruction CPL 02-00-025, Scheduling System for Programmed
Inspections, January 4, 1995, or current update.
B. OSHA Instruction CPL 02-00-170, Enforcement Exemptions and Limitations under
the Annual Appropriations Act, July 18, 2024, or current update.
C. OSHA Instruction CPL 02-00-155, Inspection Scheduling for Construction,
September 6, 2013, or current update.
D. OSHA Instruction CPL 02-00-164, Field Operations Manual (FOM), February 9,
2026, or current update.
E. OSHA Instruction CSP 03-02-004, OSHA Strategic Partnership Program for
Worker Safety and Health, May 13, 2025, or current update.
F. OSHA Instruction CPL 04-00-002, Procedures for Approval of Local Emphasis
Programs (LEP), November 13, 2018, or current update.

IV. Cancellations.
This instruction cancels OSHA Regional Instruction BHM-CPL-04-00-004, Regional
Emphasis Program for the Upstream Oil and Gas Industry, April 17, 2025.
V. Action Offices.
A. Responsible Office.
Birmingham Regional Office
B. Action Offices.
Baton Rouge, Birmingham, Jackson, Little Rock, Mobile, and Nashville Federal
Area Offices.
C. Information Offices.
Baton Rouge, Birmingham, Jackson, Little Rock, Mobile, and Nashville Federal
Area Offices.

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VI. Federal Program Change.
None.
VII. Expiration.
This Instruction expires five years after effective date but may be renewed as necessary.
VIII. Significant Changes.
A. Update OSHA Information System statistical data.
B. Update Bureau of Labor Statistics Industry information.
IX. Background.

Inspections under this REP include activities such as, but not limited to, drilling,
exploration, well workover, and servicing. Since OSHA has no national program to
address hazards in this industry, a local emphasis program is necessary to address the
fatalities/catastrophes and severe injuries and illness occurring within this jurisdiction.
Throughout the United States, workers in construction and extraction occupations had
the second most fatalities (1,034) in 2024 compared to other occupation groups. Falls,
slips, or trips were the events precipitating 844 of these fatalities. The fatality rate for
this occupation group increased from 13.0 deaths per 100,000 FTE workers in 2022 to
13.8 in 2024.
Number and rate of fatal work injuries, by selected private industries, 2024
Industry
Number of fatal
work injuries
Fatal work injury rate (per 100,000
full-time equivalent workers)
Construction 1,034 9.2
Transportation and warehousing 865 12.2
Agriculture, forestry, fishing, and hunting 475 20.9
Manufacturing 353 2.4
Leisure and hospitality 273 2.4
Retail trade 258 1.8
Other services (exc. Public admin.) 236 3.3
Educational and health services 160 0.7
Wholesale trade 145 4.6
Mining, quarrying, and oil and gas
extraction
92 13.8
https://www.bls.gov/charts/census-of-fatal-occupational-injuries/number-and-rate-of-fatal-work-
injuries-by-industry.htm

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https://www.bls.gov/charts/census-of-fatal-occupational-injuries/fatal-occupational-injuries-
private-sector-mining.htm

Fatal occupational injuries in private sector mining, quarrying, and oil and gas extraction industries
Year
Total mining, quarrying, and oil
and gas extraction industries
All other mining Oil and gas extraction industries
2020 78 34 44
2021 95 37 58
2022 113 30 83
2023 113 35 78
2024 92 27 65
Oil and gas extraction industries include oil and gas extraction (NAICS 211), drilling oil and gas wells (NAICS
213111), and support activities for oil and gas operations (NAICS 213112).
https://www.bls.gov/charts/census-of-fatal-occupational-injuries/fatal-occupational-injuries-private-sector-
mining.htm

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OSHA will employ several tools to address this issue, including enforcement, outreach,
training, onsite consultation, partnerships, alliances, and the Voluntary Protection
Program (VPP).
Activities involving the processing of the product which might come under the purview of
Process Safety Management (PSM) are excluded from this program.

X. Enforcement.
A. Hazards. Explosion, fire, fall, struck-by, caught-in, caught between, and electrocution
hazards will be addressed because past inspection evidence suggests that these hazards
are the leading causes of death within the oil and gas industry. Additionally, potential
health hazards, such as but not limited to silica, noise and hydrogen sulfide, and other
recognized health hazards will be evaluated. If necessary, a health referral will be made.
B. Specific Industries. This Instruction is provided because of the continued need to
address unsafe working conditions in the upstream oil and gas industry that contribute
to workplace fatalities and injuries.
The specified target industries are:
• Drilling Oil and Gas Wells – NAICS Code 213111,
• Support Activities for Oil and Gas Operations - NAICS Code 213112,
• Oil and Gas Field Services – NAICS Code 213118,
• Oil and Gas Pipeline and Related Structures Construction - NAICS Code 237120,
• Site Preparation Contractors - NAICS Code 238910, and
• Geophysical Surveying and Mapping Services - NAICS Code 541360.
C. Scheduling Inspections.

1. Each Area Office having upstream oil and gas operations within its
jurisdiction will divide the jurisdiction into geographic sectors. The office
area will create no less than four sectors. If it is not possible to divide the
area into four sectors, the Area Office will discuss this with the Regional
Office, and they will agree on the number of sectors. This will be noted by
the Area Office. Each geographic sector will be numbered consecutively,
and a random number table applied to create a list. The list will be sorted
in ascending order of random numbers assigned resulting in a list of
geographic sectors for inspection. The sectors will be inspected in the
order in which they appear on this list. The Area Office will ensure that
each geographic sector is selected for inspection activity during the fiscal
year.
The time allocated to conduct inspections within the geographic sector
will depend on the number of sectors identified by the Area Office. For

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example, if there are four sectors – a sector will be open for 90 days
before a new sector can be opened.
2. Inspections under this Regional Emphasis Program will be initiated
through either of the two following systems:
a. Compliance Safety & Health Officer (“CSHO”) observation of oil and
gas activity as outlined in paragraph 3 below; or
b. Development of a list of known worksites where active drilling is
taking place. The list can be generated through local media, internet
searches, Railroad Commission website, etc. Inspections will be
scheduled in accordance with the sector system as defined in
paragraph 1 above.

3. Once the Area Office selects a sector for inspection, the Area Director will
instruct CSHOs to be alert to oil and gas activity during their travels
throughout the selected sector. Upon observing oil and gas activity at a
work site, the CSHO will call the Area Director or Supervisor and provide
as much information about the site as possible (e.g., the employer’s
name, location, and any other available information) without entering
the work site.
4. The Area Director or Supervisor will review the information to determine:
1. whether the identified rig has been inspected within the selected
sector during the previous 45 days; and
2. whether the owner/operator of the rig has been inspected four (4) or
more times under this REP during the sector timeframe established by
paragraph X. C. 1.
If either condition applies, the Area Director or designee will direct the
CSHO not to conduct an inspection. Otherwise, the Compliance Officer
will conduct a comprehensive inspection of the rig.

5. For each sector, the Area Office will maintain a list of all rigs that have
been identified.
The list will include the rig number, site location, and the employer’s
name with a notation as to whether or not the rig was inspected. If the
rig was not inspected, the Area Office will note the reason(s) why an
inspection was not conducted.
6. During the opening conference, the CSHO will determine the number of
employees employed during the last twelve months to determine if an

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inspection is limited by the Enforcement Exemptions and Limitations
under the Appropriations Act.

D. Scope of REP Inspection. The inspections under this emphasis program will be
comprehensive in nature covering the entire job site, in accordance with the
FOM. All apparent potential safety and health hazards will be evaluated. If
necessary, a health referral will be made. The inspection will evaluate the
measures used by all employers at the site to manage the hazards associated
with the oil and gas industry.
The CSHO will evaluate all on-site employers through inspection, observation,
photographs, video footage, measurements, and interviews of management and
employees.
E. Citations. Citations for violations will be issued in accordance with FOM.
F. Interface with Unprogrammed Activity. Reports of imminent danger, fatalities,
catastrophes, complaints, and referrals will be scheduled as unprogrammed
inspections, and shall be inspected in accordance with the applicable provisions
of the FOM.
G. Inspection Resources. Only trained CSHOs who have attended the OTI Oil and
Gas course or who have experience in the oil and gas industry will be assigned to
conduct inspections under this REP. All OSHA personnel participating in this REP
must be familiar with the policies and procedures described in this instruction.
H. CSHO Personal Protective Equipment (PPE). CSHOs will use personal protective
equipment suitable for the target industry. PPE will include, at a minimum,
respiratory protection (as necessary), a hard hat, safety glasses with side shields,
safety shoes/boots (with metatarsal guards as necessary), hearing protection,
and high visibility apparel/vest. CSHOs will wear non-sparking clothing such as
natural fiber (e.g., cotton) and flame-resistant clothing (FRC). CSHOs will use
direct reading monitors to ensure safe environments for conducting the
inspection and use of non-intrinsically safe equipment such as cameras and cell
phones. Employer’s onsite policies and equipment will be referenced. All
monitoring equipment employed by employer and OSHA, such as gas monitors
for lower explosive limits (LEL) and personal alarms for H₂S and/or LEL will be
verified as having current calibration and bump testing in accordance with the
manufacturer’s recommendations.
XI. Recording in OIS.
A. Enforcement Inspections: Enforcement inspections completed under this
initiative will be coded as follows in OIS under the Inspection Type sub-tab:

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1. Initiating Type will be coded “Programmed Planned” except that any
inspections conducted as a result of a complaint, referral, or
fatality/catastrophe will be coded as the appropriate unprogrammed activity.
2. Regional Emphasis Program will be coded OILGAS for all programmed and
unprogrammed inspections.
3. Additional Codes will be coded with any applicable additional codes.

B. Enforcement Interventions: Enforcement Interventions completed under this
initiative, including partnerships, alliances, Voluntary Protection Programs,
SHARP, and other interventions, will be coded:

In OIS in the Task sub tab, Task Details, Emphasis Areas as follows:
1. Local Emphasis Programs will be coded OILGAS.
2. Other Emphasis Areas will include any applicable additional codes and the
codes specific to the activity covered by the inspection per XI.A.3.

C. Consultation Visits: Consultation Visits completed under this initiative will be
coded:
1. In OIS on the Request Form:
a. Regional Emphasis will be coded OILGAS.
b. Any applicable additional codes and the codes specific to the
activity covered by the visit.
2. In OIS on the Visit Form:
a. Regional Emphasis will be coded OILGAS.
b. Any applicable additional codes and the codes specific to the
activity covered by the visit.
D. Compliance Assistance Activities: Compliance Assistance Activities completed
under this initiative will be coded:
In OIS on the Compliance Assistance Activities Form:
1. Local Emphasis will be coded OILGAS.
2. Any applicable additional codes and the codes specific to the general
industry activity covered by the outreach activity.
3. Area Offices, Consultation Projects, and the Regional Office shall
periodically check their OIS databases to verify accuracy of the data for
the initiative.

XII. Outreach.
All REPS must contain an outreach component that must be ongoing throughout the
effective period of the program. These outreach efforts should be coordinated with or

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include the consultation program for that area. The method of outreach is at the Area
Directors discretion and can consist of one or more of the following components.
1. Broadcast mail-outs, emails, or program information
2. Stakeholder meetings
3. Targeted training sessions
4. Presentations to the affected group(s)
Before the Birmingham, Mobile, and Jackson Area Offices may initiate enforcement
under this program, each will implement outreach programs supporting the goals of this
program. The outreach efforts should occur at least three months before the initiation
of inspections and continually after.
XIII. Partnerships and Alliances.
In the event outreach efforts result in the interest in developing an alliance or
partnership the Area Director will ensure that these efforts conform to current National
and Regional policy.
XIV. Evaluation.
The Regional Office will evaluate the impact of the REP at the midpoint of the program as
well as at the expiration. Information and data from OIS along with input from the
Area Directors will be used in program reports. Elements to be considered in the program
report are contained in OSHA Instruction CPL 04-00-002 Procedures for the Approval of
Local Emphasis Programs (LEPs).