Accepted Practices for Hydrogen Sulfide (H 2 S) Safety Training Status of the ANSI Z390.1 And Impact on the Oil, Gas, and Petrochemical Industry.

Accepted Practices for Accepted Practices for Hydrogen Sulfide (HHydrogen Sulfide (H22S) Safety S) Safety

TrainingTraining

Status of the ANSI Z390.1Status of the ANSI Z390.1

And Impact on the Oil, Gas, And Impact on the Oil, Gas, and Petrochemicaland Petrochemical

IndustryIndustry

What Is Hydrogen Sulfide?

Toxic substance – normal state is gas

Disagreeable odor similar to rotten eggs

Kills sense of smell at higher concentrations (IDLH 100 ppm)

Concentrations above 500 ppm will render you unconscious almost immediately

Concentrations about 1000 ppm will kill with a single breath

H2S is about 20% heavier than air

The gas is flammable

Historically Hydrogen Sulfide Training:

Was deficient in content and conduct;

Length varied from one course to another;

Importance of the technical aspects was lost in the instruction;

And annual recertification certificates could be purchased without training

History of Standard Development

Course curriculum developed mid-1980s followed by instructor training course

ANSI ASC chartered October 5, 1992

Z390.1 approved 1995

Z390.1 reaffirmed 2001

Z390.1 was revised in 2006 (6/7/2006)

Scope of the Revised Scope of the Revised Z390.1Z390.1

This standard sets forth accepted This standard sets forth accepted practices for hydrogen sulfide (Hpractices for hydrogen sulfide (H22S) S) safety training and instruction of affected safety training and instruction of affected personnel .personnel .

The purpose of this standard is to The purpose of this standard is to establish minimum requirements for site-establish minimum requirements for site-specific Hspecific H22S safety training programs S safety training programs that will enhance safety in occupational that will enhance safety in occupational settings where hydrogen sulfide is settings where hydrogen sulfide is present, or is recognized as being present, or is recognized as being potentially present, above the TLV-TWApotentially present, above the TLV-TWA..

The “Guts” of Z390.1The “Guts” of Z390.1

Section 3 – Training CriteriaSection 3 – Training Criteria

Section 4 - Instructor Qualification Section 4 - Instructor Qualification & Proficiency& Proficiency

Section 5 - Section 5 - Documentation and Documentation and RecordkeepingRecordkeeping

The “Guts” of Z390.1 The “Guts” of Z390.1 (continued)(continued)

Section 6, Section 6, Student Competency and Student Competency and QualificationQualification

Section 7, Section 7, Training Techniques, Training Techniques, Language and Literacy FactorsLanguage and Literacy Factors

Section 8, Section 8, Protection Requirements for Protection Requirements for VisitorsVisitors

What Drove the What Drove the Revision/Changes???Revision/Changes???

By procedure ANSI Standards must By procedure ANSI Standards must be reaffirmed, revised, or withdrawn be reaffirmed, revised, or withdrawn every five years.every five years.

Technology and training Technology and training methodologies have changed since methodologies have changed since the first version of the standardthe first version of the standard

Key Changes to Z390.1Key Changes to Z390.1

Acute and Chronic exposure redefinedAcute and Chronic exposure redefined

Boiling Point changed to Flash PointBoiling Point changed to Flash Point

Respiratory protection references Respiratory protection references changed from Z88.2-1991 to 29CFR changed from Z88.2-1991 to 29CFR 1910.134 as amended in 19981910.134 as amended in 1998

Dispersion modeling section to be Dispersion modeling section to be covered “if applicable”covered “if applicable”

Key Z390.1 Changes Key Z390.1 Changes (continued)(continued)

Physiological effects of chronic Physiological effects of chronic exposureexposure

““No course is ever to be abbreviated….” No course is ever to be abbreviated….” removedremoved

Certification cards Certification cards may may be issued by the be issued by the instructorinstructor

Computer-Based Training issue was Computer-Based Training issue was addressedaddressed

ACGIH – Impact on ACGIH – Impact on Z390.1???Z390.1???

ACGIH Notice of Intended Change of ACGIH Notice of Intended Change of TLV/TWA for HTLV/TWA for H22S in 2004S in 2004

TLV from 10 ppm to 1 ppmTLV from 10 ppm to 1 ppm

STEL from 15 ppm to 5 ppmSTEL from 15 ppm to 5 ppm

NIC was published and ACGIH NIC was published and ACGIH Board action was to be reported Board action was to be reported February 2008February 2008

The TLV / TWA IssueThe TLV / TWA Issue ACGIH proposing dramatically lower safe exposure limit for HACGIH proposing dramatically lower safe exposure limit for H22S - 10 S - 10

PPM to 1 PPMPPM to 1 PPM

Likely to be adopted as law, at some point, by state and Federal Likely to be adopted as law, at some point, by state and Federal agenciesagencies– OSHAOSHA– EPAEPA– ??

Oil, gas, and petrochemical operations frequently result in Time Oil, gas, and petrochemical operations frequently result in Time Weighted Average exposures of 1-3 PPM to personnel in operational Weighted Average exposures of 1-3 PPM to personnel in operational areas, instantaneous exposures is excess of 5-10 PPM are commonareas, instantaneous exposures is excess of 5-10 PPM are common

Reducing worker Reducing worker exposureexposure to 1 PPM technologically/economically to 1 PPM technologically/economically difficultdifficult– Almost continuous use of respiratory protection in operational areas; Almost continuous use of respiratory protection in operational areas;

and /orand /or– Vapor recovery equipped tanks, trucks, barges, railcars, loading/unloading Vapor recovery equipped tanks, trucks, barges, railcars, loading/unloading

racks, racks, re-engineering the entire oil, gas and petrochem infrastructure!re-engineering the entire oil, gas and petrochem infrastructure!

TLVTLV®®  - Threshold Limit   - Threshold Limit

ValueValue ““An occupational exposure value recommended by An occupational exposure value recommended by

ACGIH® to which it is believed nearly all workers can be ACGIH® to which it is believed nearly all workers can be exposed day after day for a working lifetime without ill exposed day after day for a working lifetime without ill effect.”effect.”

By itself, TLVBy itself, TLV®® simply indicates an exposure limit simply indicates an exposure limit established by the ACGIH.established by the ACGIH.

TLVsTLVs®® are frequently incorporated into law and cited in are frequently incorporated into law and cited in litigationlitigation

ACGIH position – don’t blame us were just scientists ACGIH position – don’t blame us were just scientists objectively reviewing researchobjectively reviewing research

ACGIH Statement of ACGIH Statement of Position Regarding the Position Regarding the TLVsTLVs®® and BEIs and BEIs®®

The ProblemThe Problem

A 1PPM TLVA 1PPM TLV® ® -TWA is likely to be imposed on industry -TWA is likely to be imposed on industry through regulation or litigationthrough regulation or litigation

Worker exposure in operational area of oil, gas, and Worker exposure in operational area of oil, gas, and petrochem facilities often have a TWA exposure of 1-3 petrochem facilities often have a TWA exposure of 1-3 PPM, with frequent instantaneous exposures of 5-10 PPMPPM, with frequent instantaneous exposures of 5-10 PPM

Personal Protective Equipment or Engineering Controls Personal Protective Equipment or Engineering Controls only options to limit worker exposureonly options to limit worker exposure

Reducing exposure to 1 PPM or less does not appear to Reducing exposure to 1 PPM or less does not appear to be technologically / economically feasiblebe technologically / economically feasible

Atmospheric MonitoringAtmospheric Monitoring

Instruments designed for continuous Instruments designed for continuous monitoring are not particularly accuratemonitoring are not particularly accurate– Electrolytic cells Electrolytic cells ± 15%± 15%– Semiconductor ± 5 PPMSemiconductor ± 5 PPM– Colorimetric tubes ± 25%Colorimetric tubes ± 25%

Many instruments currently used are not data Many instruments currently used are not data logging and cannot calculate TWAlogging and cannot calculate TWA

Respiratory Respiratory ProtectionProtectionAir Purifying RespiratorsAir Purifying Respirators

Acceptable between TLV/TWA - IDLHAcceptable between TLV/TWA - IDLH

APRs potentially dangerous to use for HAPRs potentially dangerous to use for H22S S – unanticipated spikes above IDLH when performing certain unanticipated spikes above IDLH when performing certain

work (gauging, unloading, etc.)work (gauging, unloading, etc.)– Poor warning characteristics of HPoor warning characteristics of H22S can prevent detection of S can prevent detection of

breakthroughbreakthrough

APRs uncomfortable due to weight on head & high APRs uncomfortable due to weight on head & high breathing resistancebreathing resistance

APRs expensive over long termAPRs expensive over long term– Approx. $10.00 / set of cartridges / personApprox. $10.00 / set of cartridges / person– 1-2 sets used / day1-2 sets used / day

Respiratory ProtectionRespiratory ProtectionSelf Contained Breathing ApparatusSelf Contained Breathing Apparatus

Must be worn above IDLHMust be worn above IDLH May be worn above TLVMay be worn above TLV ExpensiveExpensive Require a lot of support equipmentRequire a lot of support equipment Short use durationShort use duration Hoselines restricted to no more than 300 feetHoselines restricted to no more than 300 feet Not user friendlyNot user friendly

– HeavyHeavy– BulkyBulky– Restrict mobilityRestrict mobility

Engineering Engineering ControlsControls

Unlikely concentrations of HUnlikely concentrations of H22S in oil, gas, S in oil, gas,

and petrochem industry can be significantly and petrochem industry can be significantly reducedreduced– Chemical treatment?Chemical treatment?

Vapor RecoveryVapor Recovery– Could reduce airborne concentrations of HCould reduce airborne concentrations of H22SS

– Extremely expensiveExtremely expensive

The ActionThe Action

Encourage the ACGIH not to adopt proposed Encourage the ACGIH not to adopt proposed TLV-TWATLV-TWA– Research does not indicate harm from concentrations Research does not indicate harm from concentrations

lower than 10 PPMlower than 10 PPM– 1 PPM is arbitrary concentration1 PPM is arbitrary concentration– Not technologically or economically feasibleNot technologically or economically feasible– No evidence lower TLV-TWA will make workers safer!No evidence lower TLV-TWA will make workers safer!

If adoptedIf adopted– Closely monitor regulatory actions which might result Closely monitor regulatory actions which might result

in proposed TLV-TWA becoming lawin proposed TLV-TWA becoming law– Vigorously lobby against adoption of proposed TLV-Vigorously lobby against adoption of proposed TLV-

TWA into lawTWA into law

The TLV Bad NewsThe TLV Bad News

ANSI Z-390 HANSI Z-390 H22S Training Committee S Training Committee and API vigorously opposed change – and API vigorously opposed change – ACGIH did not find their arguments ACGIH did not find their arguments compellingcompelling

Although not final, momentum is for Although not final, momentum is for adoptionadoption

ACGIH is also proposing lowering the ACGIH is also proposing lowering the TLV-TWA of SOTLV-TWA of SO22

Private-Public Sector Private-Public Sector Impact From Z390.1Impact From Z390.1

The standard is not cited by reference.The standard is not cited by reference. The standard is recognized by a number The standard is recognized by a number

of government agencies.of government agencies. The standard is cited in numerous private The standard is cited in numerous private

sector contracts and work agreements.sector contracts and work agreements. The standard has been used in the past The standard has been used in the past

for vendor certification/accreditation for vendor certification/accreditation claimsclaims..

CONCLUSION

Revised standard is more user-friendly

Stresses prevention of dangerous work practices in hazardous atmospheres caused by mediocre or deficient training

Training Issues…Training Issues… Continue to train to the standardContinue to train to the standard Continue to develop competent Continue to develop competent

instructorsinstructors Redeveloped / standardized Redeveloped / standardized

instructor training materialsinstructor training materials HH22S Master Trainer Course with S Master Trainer Course with

CSHICSHI

Thank you!Thank you!

Any Questions?Any Questions?