It is recognized that well-planned and executed outages are far less expensive and much safer than taking a reactive approach and responding to unplanned failures as they occur.
Tremendous effort typically goes into planning and coordinating the various aspects of a major outage to maximize repairs and preventive maintenance that can only be conducted in “shut down” mode. It is critical that all issues, like industrial hygiene, rescue and safety personnel, are fully addressed in the early phases of outage planning. Playing catch-up in these areas can have a negative impact on worker safety, project budget and schedule.
Industrial Hygiene Management
Assessing risks of chemical and physical exposure for the myriad activities involved in major industrial outages can be daunting for even the most seasoned Industrial Hygiene professional. But a comprehensive IH assessment is an essential part of outage management to assure IH resources are allocated properly, controls are provided and exposures are monitored. Creating a comprehensive list of activities and potential exposures will protect workers, improve safety and reduce costs during the outage process.
From the assessment, the information should then be compiled and prioritized for controls and monitoring. Priorities should be established based on:
Toxicity and immediate risk to workers
Understanding of the work activity
(are exposures related to the activity well understood and documented, or is
this a new or unique potential exposure that is not well understood?)
Emergency and Rescue
Having highly skilled safety personnel on standby to protect workers in emergency situations reduces liability and increases productivity by being able to respond quickly and appropriately. Rescue personnel should provide:
Self-rescue and rescue team training
High angle, hull entry and confined space rescues
Safety supervision and confined space assessment
Space or site rescue pre-planning and pre-entry equipment staging
Proper entry permit documentation
The writing of hull entry procedures and guidelines
Continuous atmospheric monitoring and ambient air testing
Specialized Industrial Safety Personnel
Industrial Safety Technicians and Safety Attendants (holewatch/firewatch/bottlewatch) increase safety and efficiency and reduce costs. By having Specialized Safety Personnel on an
outage provide excellent benefits, like:
More competitive billing rates
Craftsmen are not tied up performing attendant duties
Reducing the number of multiple contractor employees, thus reducing the total man-hour costs of the project
Immediately being able to provide time tickets and head count reports, as well as up-to-the-minute cost reporting
Due to the high cost and loss of production associated with outages, it is essential these are executed as efficiently and safely as possible. Proper management of safety issues during outages can help your company increase profitability and decrease liability during crucial outage and shutdown periods. Outages are hectic, chaotic and stressful by nature. By making your safety list (and checking it twice), you can help ensure the success of your outage!
The time is now! Plan for how your facility will conduct emergency response industrial hygiene (IH) monitoring. What should you be looking for in a provider of this service? Because of the unique challenges surrounding emergency response IH monitoring, choose a provider that is able to develop written protocols/procedures, to deploy teams and equipment quickly, to provide experienced/knowledgeable personnel, quality support staff, and can adapt to ever changing conditions. Some of the more challenging issues arising specific to IH monitoring include but are not limited to mobility, flexibility, proper equipment, documentation, reporting, and site specific training.
Developing written protocols/procedures has to occur first. The protocols set the applicable exposure levels, alarm levels and actions including deployment of respiratory protection, establishment of safe zones, evacuation, shelter-in-place or other personal protective measures. Reporting mechanisms, format and timing of data reports should also be included in the protocol. It is important to remember that reports are often shared not only with the client but others as well including federal, state and local authorities. Therefore, a data management support team must be available 24/7 to provide quality assurance and create a database from which a variety of reports can be prepared quickly. Certified industrial hygienists should be utilized to write the IH sampling protocol and be available to lead project management. Summary reports that pull all of the information together at the end of the event should be prepared and retained just as any other industrial hygiene medical record.
Next comes deployment which includes both necessary equipment and a team of personnel to operate the equipment. Your provider has to have the equipment in inventory or else have connections already in place to get it. Equipment ranges from simple personal monitoring pumps to the more technologically advanced real time wireless monitoring systems with built in GPS and data management software. All of which must be rugged, portable, intrinsically safe and able to collect large quantities of data for the specific contaminant(s) of concern.
One thing often overlooked is the need for an IH Mobile Command Center. It must communicate with both the site’s incident command center and also the outside world. A high speed Internet connection is needed for monitoring data management software. A standalone IH Mobile Command Center will not interfere with the incident command center communication requirements but seamlessly integrate on site.
Training is a valuable component. Your provider should have the ability to train their own responding team and also be available to train other site workers. Monitoring personnel should have completed HAZWOPER, Incident Command, NIMS, respiratory protection and other standard courses. However, prior to deployment, training should occur on the incident IH monitoring protocol, site specific hazards, client’s procedures, reporting requirements, and equipment use.
Support away from the response is required. The provider needs to have a strong support staff provide additional resources to handle issues that may arise during the sampling. Plan now and choose your emergency response IH monitoring provider with these criteria in mind to ensure that your facility is fully prepared for any emergency response.
By Mandy Sunderland, Sr. Industrial Hygienist, Total Safety
One of the biggest challenges facing safety and health practitioners today is ensuring that their companies operate in “proactive,” rather than “reactive,” mode. In reactive mode, an injury occurs, and an investigation is conducted to find out what happened and who to blame. Recommendations are made to address the specific incident, and corrective actions are often taken without understanding or addressing underlying system causes. This is an expensive way to operate, since corrective actions are initiated only after incidents have occurred.
Emergency response, by its nature, is reactive. Early in a response, immediate action is often required in the face of unknowns and uncertainties. The goal in an emergency is to shift from reactive response to systematic management of the incident. Advanced planning addresses a wide range of scenarios, identifies resources, training and drills. It will ensure that the equipment and resources can be obtained as quickly as possible, personnel are prepared with drills and training, and that additional staffing requirements are identified and contracted in advance so that the response effort is less frantic and more systematic.
Complacency also leads to being reactive. Well designed exposure monitoring plans fall out of date and are not refreshed. Recommendations from exposure surveys or incident investigations are not closed out and, over time, possibly forgotten. New employees don’t receive adequate training not only on equipment, but on risks and protective measures. Experienced workers take shortcuts and develop bad habits, which become normalized as “how we get it done here.” Operating processes change and new exposure hazards that are introduced to the workplace are not recognized and addressed. Failure to recognize these gaps and take proactive steps to refresh plans, knowledge, skills and training, leaves little choice but to operate in a reactive mode.
Leading an organization to a proactive approach The ultimate goal of industrial hygiene (IH) professionals is to successfully guide their organizations into operating in a proactive made, but that’s not always easy to do. One of the biggest obstacles is the lack of knowledge and understanding by management of the risk associated with operations, and the appropriate steps needed to mitigate these risks. Given a full understanding of risks and consequences, most managers will make good, proactive business decisions to prevent incidents.
In a proactive mode, IH professionals devote their time and energy into understanding hazards and risks, and taking actions to prevent injuries and exposures. Potential exposures should be analyzed to determine risk and identify which controls can be used to prevent incidents. Resulting recommendations related to corrective actions and system improvements should be implemented prior to an injury or illness occurring. In a proactive mode, all incidents are considered preventable, as opposed to being random and unavoidable.
Getting the biggest bang for your IH monitoring bucks All too often, facility management has fallen back on the same old IH sampling plan year after year. A facility without a clearly thought out, up-to-date plan to assess their workplace exposures, may sample unnecessary materials, bringing with it a false sense of security. This can occur when changes in operations, processes or materials are not recognized and evaluated. Monitoring the wrong exposures increases cost and decreases true exposure knowledge. In addition, it may become difficult to maintain compliance with regulatory standards, including ACGIH and OSHA regulations.
Sometimes a facility will opt to require respirators or personal protective equipment (PPE) to reduce or control worker exposures. These types of measures far too often become a permanent control measure, but, in the long run, are expensive and difficult to maintain. Often an experienced industrial hygienist can suggest permanent simple fixes that are inexpensive and easy to maintain.
Furthermore, other programs that depend on the results of your IH monitoring, such as medical surveillance, hazard communication, respiratory protection and PPE, and exposure control (ventilation) programs, may also suffer.
Including IH in your turnaround planning During a typical plant turnaround, a large number of people work together to repair and recharge complex equipment against a tight schedule and budget. Turnarounds require a high degree of planning, scheduling and coordination, so that the right combination of equipment and personnel are available when needed.
Many turnaround plans focus on mechanical and maintenance aspects and neglect to include critical support services that help to keep activities on schedule. These support items may include safety training and management, industrial hygiene monitoring, lead and asbestos testing, perimeter monitoring and environmental monitoring. Inadequate planning for HSE support can cause unanticipated delays, resulting in increased cost, anxiety and setbacks.
Turnarounds often present significant exposure potential to hazardous chemicals not encountered during normal operations. When normally closed vessels are opened up, bundles and exchangers may be pulled, and catalysts replaced. As these jobs are not routine, sometimes only inexperienced workers are available, who require more training and supervision that are potential costs and delays of the critical path.
Protecting your employees’ hearing High noise levels on the job can result in hearing loss, as well as physical and psychological stress in the workforce. Excessive noise exposures also take a bite out employers’ pocketbooks, as they financially compensate workers. If worker exposure data and audiometric test records are not well managed and maintained, it can be difficult to make connections between exposures and symptoms of hearing loss. It is always preferable to reduce noise at the source through engineering controls, but lack of a “comprehensive hearing conservation program,” as required by OSHA, can make it difficult to analyze and implement appropriate controls.
Protecting your employees from NORM Exposure to radiation can result from natural sources, such as Naturally Occurring Radioactive Materials (NORM), and not just from industrial equipment, such as material level and thickness gauges, testing equipment that contain radioactive isotopes or X-ray inspection devices, and electron microscopes.
Certain industrial processes tend to concentrate NORM and bring workers into situations of more direct or prolonged exposure and increase risk from ingestion, inhalation or absorption of radioactive materials. In the oil and gas business, NORM often flows to the surface as a by-product of oil and gas production and concentrates as scale, sands and sludge on production strings, flowlines, pipelines and production equipment.
NORM materials may then be encountered during routine maintenance, refurbishment activities and replacement operations. Disposal, reuse and recycling of NORM can cause occupational exposures as well. Improper handling and maintenance of industrial radiation sources can also lead to elevated exposures. Health effects from exposure to radiation may occur shortly after exposure or may be delayed for months or even years, which can make it difficult to track.
Ensuring health protection during an emergency Natural and man-made disasters present costly challenges for industry today. A large scale disaster can disrupt or shut down business operations, cause physical or environmental damage and release hazardous materials that threaten the health of employees and the public.
Lack of proactive IH sampling plans during emergencies for exposures, both inside and outside the fence, can result in workforce and public anxiety and increase potential liability and unwanted media attention. Failure to communicate a clear understanding of what happened, what the potential exposures are, related exposure standards and potential health effects can destroy credibility.
With all the challenges that we face as leaders in the HSE field, we understand the importance of focusing energy on key issues in the workplace today and taking steps toward working in the proactive mode as regular operating practice. Once accomplished, we can provide leadership and direction to the workplace, bring vitality to the practice of IH, facilitate industry to adapt to ever challenging situations and save money!