BEST PRACTICES BY SAMMIE DABBS, ADVANCED WORKPLACE STRATEGIES, INC. Contractor Compliance in the Oil and Gas Industry C
ontractors account for a large percentage of the workforce in the oil and gas industry. In fact, up to 80
percent of safety sensitive workers on site are provided by contractors. Companies supplying contractors are likely to be work- ing for multiple oil and gas operator orga- nizations and this is where problems with standards arise: each operator has unique drug and alcohol testing requirements that contractors must meet. Contractor organi- zations must ensure their workers comply with each operator’s standards and doing so can be a compliance headache. Never- theless, there are substance abuse program best practices that can remove many of the compliance challenges contractors face.
Why Operators Mandate Drug and Alcohol Testing Oil and gas industry-related incidents cou- pled with a fatality rate seven times greater
than any other industry in the United States1 makes it clear that the work performed by oil and gas employees can be dangerous. Operators recognize the high-risk nature of the oil and gas industry and, as part of their environmental and health responsibility, make worksite safety a priority. As each operator’s safety expectations
globally increase due to the safety- sensitive functions in the oil and gas industry, their contract workers are subject to the same safety requirements as direct employees. Data collected by one operator, between 2008 and 2012, supports the need for global safety requirements for contractors and direct employees. Contractors had three times more job-related injuries, a 0.35 TRR2 (Total Recordable Rate), in comparison to their direct employee counterparts who had a 0.11 safety performance TRR (demonstrated in Diagram 1.1).
Diagram 1. 1—Workforce TRR Employees
■ 2012 ■ 2011
Contractor Compliance Challenges Contractors must navigate many compli- ance obstacles to satisfy the standards of each operator. Some contractors must administer multiple programs just to com- ply with operator-mandated requirements. “We strive to comply with all of our clients’ requirements. We want to work for them and we want to meet their standards,” said Andre Galatoire, Baker Hughes Drug and Alcohol Program Coordinator. “Te ques- tion is, ‘how do we comply without having to run multiple programs and without having to duplicate efforts in managing our program?’” Many contractor organizations are anx-
■ 2010 ■ 2009 ■ 2008
0.11 0.11 0.12 0.17 0.24
Contractors
0.35 0.41 0.43 0.49 0.73
Combined
0.29 0.32 0.32 0.37 0.59
14 datia focus
ious to see if standardization will come about in the oil and gas industry. The first step is to understand the different requirements among the operators. Some of the differences between current opera- tor substance abuse programs include: • Drug Test Panel and Cut-off Lev- els: Drugs to be tested for and the thresholds for initial and confirmation screenings;
• Type of Testing and Frequency of Testing: Pre-access, random, annual, reasonable suspicion and post-accident;
• Required Specimens Tested: Urine, hair, oral fluid, and breath alcohol;
• Auditing Agencies: Statistical and employee information submitted to multiple auditors. Without question, a single, universal
set of guidelines would make compliance much easier for contractors working for multiple operators. In the meantime, there are steps a contractor can take to simplify the compliance process.
fall 2013
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