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Category Archives: Occupational Health and Safety

Industrial Hygiene Planning for Successful Turnarounds

By Mandy Sunderland, Senior Industrial Hygienist , Total Safety

 Turnarounds can be expensive in terms of lost production while the process unit is offline, and in direct costs for labor, tools, heavy equipment and materials used to execute the project.

A well planned and executed turnaround helps ensure the project is conducted safely and efficiently, so the unit can be returned to operation as quickly as possible.  Tremendous effort typically goes into planning and coordinating the various aspects to ensure all necessary repairs and maintenance are conducted during the turnaround, so the unit doesn’t have to be shut down again until the next planned turnaround.  However, far too often industrial hygiene issues are not adequately addressed in the early phases of turnaround planning.  Playing catch-up in this area can have a negative impact on worker safety, project budget and schedule.

To help ensure turnaround success, the following industrial hygiene items should be considered during planning:

  • DETERMINE potential exposures to chemical agents well in advance and identify requirements for trained personnel and equipment.  Based on potential exposures, the project may require IH devices such as real time direct reading instruments to measure agents such as total hydrocarbons or H2S. Personal and area air samples for laboratory analysis may also be required to measure specific agents in welding fumes or catalyst. 
  • DEVELOP clear guidelines for PPE (personal protective equipment) use throughout the project, including respiratory protection, hearing protection, gloves, coveralls and safety shoes. Access control plans should be developed to ensure workers aren’t exposed to hazards unnecessarily. Special attention should be given to any jobs involving confined space entry. Defining and communicating PPE requirements in advance helps ensure that contractors will provide proper equipment and trained personnel.
  • DEFINE the types and numbers of worker and activities to be monitored. An IH sampling strategy should be developed which sets requirements for full shift TWA (time weighted average) sampling or activity specific STEL (short term exposure limit) sampling. Some operators monitor their own company employees, but require contractors to monitor their own workers. Coordinating these plans will help prioritize resources to better protect workers.
  • UNDERSTAND the full scope and length of the turnaround. Determine if IH monitoring will be required during the preparation phase, actual shutdown, line breaks, vessel entries or start up and commissioning. Ensure adequate and appropriate IH materials, supply and support are available throughout the project.
  • DECIDE which analytical laboratories will be used for IH samples.  Agree on the types of reports needed (e.g. full report with specific recommendations or rough data only). Consider who will need to see results in order to keep the project running smoothly and maximize worker protection. 
  • ANTICIPATE the unexpected. Don’t get caught off guard by unexpected exposures to NORM (naturally occurring radioactive material), asbestos or PCBs. If you don’t have a clear picture of potential exposures, bring in an IH expert to conduct a survey of the project area and a review of the turnover plan.

In summary, a comprehensive industrial hygiene strategy will help ensure your next turnaround project is completed safely, within budget and on schedule. Therefore during your next turnaround planning cycle be sure to thoroughly examine industrial hygiene issues in your decision making process.  It can save you bucks!

To learn more about Total Safety or our complete line of industrial hygiene services, contact us at 888.44.TOTAL (888.448.6825).

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Spill Response: Can Industry Supply the Goods?

By Mandy Sunderland, Industrial Hygiene Specialist, Total Safety

For the quickest response, go Total Safety.The Oil Pollution Act (OPA) was signed into law in August 1990, largely in response to rising public concern following the Exxon Valdez spill, now the second largest oil spill in U.S. waters. The intent of the law is to improve the nation’s ability to prevent and respond to oil spills. OPA 90 regulations cover many areas and include requirements for industry handling oily materials to establish contracts for spill response services ahead of time, and to conduct table top and large scale drills to test the capabilities of these services.

History shows that the speed and effectiveness of a spill response depends on the availability of equipment, resources and trained personnel. And it pays to be well prepared because response costs can be very high. Since the early days of the recent Gulf of Mexico oil spill, response personnel have been working round the clock to support containment and clean up operations.  Crews worked to protect hundreds of miles of beaches, wetlands and estuaries along the northern Gulf coast using skimmer ships, floating containment booms, anchored barriers and sand-filled barricades along shorelines. It has been reported that as of August 9, 2010, skimming operations had recovered over 826,000 barrels of oily liquid and 411 controlled burns had been carried out. Approximately 30,800 personnel were deployed, more than 5,050 vessels were at work, and dozens of aircraft were engaged in the response effort. Estimated direct response costs had already reached $6.1 billion, including the cost of containment, clean-up, relief well drilling, static kill and cementing, grants to the Gulf States, claims paid and federal costs. On June 16 2010, an agreed package of measures was announced, including the creation of a $20 billion escrow account to satisfy certain obligations arising from the oil and gas spill.1

Businesses on contract to oil companies affected by the spill scrambled to locate equipment and trained personnel, balancing the immediate needs of these customers with the needs of other customers to maintain adequate levels of response capability. Existing staff worked lots of overtime, while new employees were recruited, trained and deployed to the Gulf as quickly as possible.

In response to the spill four major oil companies (Exxon Mobil, Chevron, ConocoPhillips and Shell) launched a non- profit joint venture called the Marine Well Containment Company. It can be mobilized within 24 hours of an incident, used in deepwater depths at up to 10,000 feet, and has a capacity to contain up to 100,000 barrels of oil per day.     

The recent spill was an advanced course in spill management that industry can use as a guide to assist all of us in our quest for continuous improvement.  As we have learned, spill response is expensive and resources can be tenuous and elusive. There are many lessons to be learned from this event including, but not limited to, exercising our response plans to their greatest extent possible and more accurately assessing our ability to provide services as depicted in contracts. Ultimately though, we must be diligent in the way we conduct our daily business, as noted in a statement released by Exxon CEO Rex Tillerson, “the extensive experience of industry shows that when the focus remains on safe operations and risk management, tragic incidents like the one we are witnessing in the Gulf of Mexico today should not occur.”   In summary, with significant effort to improve safety, prevention and response, the oil  industry’s motto of ‘Action before Reaction’ is the way to go.

  1. BP Press Release, 09 August 2010

The HazCom World is Changing

By John Baker, CIH, Industrial Hygiene Support Services Manager, Total Safety

Back in 1983, the OSHA Hazard Communication Standard, 29CFR1910.1200, was born. This important worker right-to-know standard was well founded on a three legged stool: (1) labels on containers, (2) accurate and complete Material Safety Data Sheets (MSDS) and (3) training of employees.

In that year, most personal computers still used the MS-DOS operating system and didn’t have a mouse; the last episode of M*A*S*H was aired, and President Ronald Reagan called the Soviet Union the “Evil Empire,” while we were still in the throes of the Cold War. We were on the threshold of major changes in our international relationships as a suicide bomber destroyed the US Embassy in Beirut, Lebanon killing 63 people.

Since then, the world has continued to change as a result of “globalization.” We are exporting products to and importing products from countries, which may use hazard classifications that differ from ours. These differing classifications could impede trade and the accurate communication of safe practices to employees, customers and the general public. For example, a liquid with a flash point of 120º F would have been considered “Flammable” in Germany, but OSHA would consider it “Combustible.”

Under the leadership of the U.S. Department of State, OSHA, along with EPA, CPSC, FDA and DOT, are considering whether our approach to informing and protecting workers and the public should conform to the Globally Harmonized System for Classification and Labeling of Chemicals (the GHS) established by the United Nations in 2003 with the current 3rd edition released in 2009. Regarding employee safety and health, OSHA published a proposed rule in 2009 to implement the GHS, with public hearings to be held this year. For transportation purposes, DOT has already revised the Hazardous Material Regulations to harmonize classification of toxic materials and flammable liquids with UN Model Regulations. Regardless of whether the rest of the U.S. government formally adopts the GHS, we, in industry, must become knowledgeable about the system because most of our important trading partners, including Canada, Mexico, the UK and the other members of the European Union, China, Japan, Korea and Australia, have committed to aligning their hazard communication requirements with the GHS.

So what will change under GHS?

For one thing, Material Safety Data Sheets (MSDS) will be known as “Safety Data Sheets (SDS),” and they must adhere to a 16 section format similar to ANSI Z400.1 developed through the leadership of the American Chemistry Council. But under GHS, Section 2 will be “Hazard identification” and Section 3 will give “Composition/information on ingredients” instead of the other way around.

Also Section 2 must list the GHS hazard class and category, such as Flammable Liquid, category 1, and specific label elements including “signal words,” e.g., “Danger” or “Warning;” standardized hazard statements and code, such as “H224, Extremely Flammable Liquid and Vapor,” standardized precautionary statements and codes, such as “P210, Keep away from heat/sparks/open flames/hot surfaces – No smoking” and new graphic symbols called “pictograms.” For example, the three pictograms below indicate that the material may pose various types of toxicity. The proper pictogram to use will depend on the GHS hazard class and category.

For the latest in occupational health and safety, go Total Safety.

At this time, it is expected that after the public hearings this year, and a post-hearing comment period, OSHA will draft and adopt a final rule in 2011, with a transition period for adoption through 2014. There is a wealth of information at the OSHA web site, which should be checked regularly to keep posted on changes.