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Why We Need More than Common Sense Safety for Natural Gas Pipe System Cleaning and Purging Operations

Posted by Shivi Kakar

Jul 20, 2010 2:22:39 AM

By Don Hoeschele, MS, CHMM

The U.S. Chemical Safety Board (CSB) recently approved recommendations to the Occupational Safety and Health Administration (OSHA), the National Fire Protection Association (NFPA) and other organizations to help prevent explosions and fires during pipe cleaning and purging operations.  As recently as February 7, 2010 at the Kleen Energy power plant in Middletown, CT, an explosion caused six fatalities and numerous injuries during the cleaning of a natural gas pipe system. Another similar explosion occurred at the ConAgra Foods Slim Jim plant in Garner, NC on June 9, 2009 and caused the death of four workers. In both instances, an operation termed “natural gas blow” was utilized to force natural gas under pressure through a piping system during construction and prior to startup of the plant’s turbines to rid the pipe system of non-natural gas impurities and debris. The gas was vented to the ambient atmosphere at open pipe ends less than 20 feet from the ground, and in worker areas where the gas easily found a source of ignition.  It seems that common sense would lead one to never vent natural gas near sources of ignition.

  • At Kleen Energy the potential ignition sources included electrical power to the building, welders actively working and diesel-fueled heaters running in the vicinity.

  • Approximately TWO MILLION cubic feet of natural gas were released at Kleen Energy on February 7, 2010 during the “natural gas blow”, enough natural gas, according to the CSB, to provide heating and cooking fuel to the average American home every day for more than 25 years.


The CSB determined that no specific federal workplace safety standard exists that would prohibit the intentional release of natural gas into the workplace. Yes, I was shocked when I read that, too! Eighteen urgent recommendations were provided and voted on by the CSB to prevent future disasters. Some of the recommendations include – Prohibiting the use of natural gas for pipe cleaning and using alternatives such as compressed air, steam and other chemical substitutes, and upgrading the current gas safety standards for general industry and construction that are considered by the CSB to contain “significant gaps” that threaten the safety of workers at such facilities.

In February 2010, the CSB issued a safety bulletin titled “ Seven Key Lessons to Prevent Worker Deaths During Hot Work In and Around Tanks”.  This bulletin highlights another gap in the OSHA standards, “While the OSHA standard prohibits hot work in an explosive atmosphere, it does not explicitly require the use of a combustible gas detector”. 

It is an unfortunate fact that such regulatory “gaps” can be found in many industries. We are reminded of these gaps while reading of disasters such as these, or more currently, watching the daily updates of oil washing ashore in the Gulf of Mexico.  It is certainly welcome news that these CSB draft recommendations were quickly approved without amendments to help prevent future explosions during pipe cleaning operations.

Do you know of other examples of what would seem to be ‘common sense’ safety measures that are not utilized because “this is the way we have always done it” wins over common sense?
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Topics: OSHA, health and safety, General Industry H&S, Emergency Response, Chemical Safety Board, Hazardous Materials, Compliance, worker safety, emergency response training, Fire Safety, NFPA

Best Available Technology for Community Air Monitoring at Hazardous Waste Clean-up Sites

Posted by Shivi Kakar

Jul 12, 2010 7:57:55 AM



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Topics: OSHA, indoor air quality, Personal Protective Equipment, health and safety, Construction H&S, EPA, Hazardous Waste Management, Hazardous Materials, Compliance, worker safety, Occupational Health, Occupational Safety, Air Sampling, environmental air monitoring, Respiratory, Public Safety

Could a Bhopal Disaster Happen Here?

Posted by Shivi Kakar

Jun 21, 2010 1:00:36 AM

Dian Cucchisi, PhD, CHMM

The Bhopal Disaster has been in the news again with the eight former company executives getting convicted of negligence.     A court in the Indian city of Bhopal returned the verdict on June 7, 2010, more than 25 years after the incident

What was the Bhopal Disaster?

For those of us old enough to remember, the words “Bhopal, India” brings to mind the very tragic events of December 2, 1984.  On that day a Union Carbide facility had an accidental release of approximately 40 tons of methyl isocyanate, a chemical used in pesticides.  The chemical plume killed 3,000 people and left an estimated 500,000 people with long-term, damaging health effects.  Amnesty International reports that approximately 15,000 people died in the subsequent years as a result of this incident.  As a result the Union Carbide Bhopal accident is often considered the world's worst industrial disaster.

And then a smaller, but similar event occurred in the USA…

In August 1985 a Union Carbide facility located in Institute, West Virginia experienced an accidental release of toxic chemicals causing more than 100 residents of the area to seek medical treatment.

US Regulators Respond to Community Concerns

In response to these incidents and the growing concern by the American public that this could happen in their backyard, regulatory agencies enacted laws for facilities that manufacture, store, or use certain chemicals above designated threshold quantities.

In 1986 the United States Congress passed the Emergency Planning and Community Right to Know Act (EPCRA). The law requires facilities to annually report the quantities of “extremely hazardous substances” to the facility’s state and the Local Emergency Planning Committee (LEPC).  This information is available to any member of the public upon request to the LEPC.

In late 1985, the Occupational Safety and Health Administration (OSHA) created the Hazard Communication Standard (HCS) (29 CFR 1910.1200) also known as “Right to Know.”  The HCS requires manufacturers and distributors of hazardous materials to communicate to employees the hazards of the chemicals in their workplace by providing Material Safety Data Sheets (MSDS) and ensure that hazardous materials are labeled according to certain requirements.

The Clean Air Act was amended by Congress in 1990, including some regulatory changes intending to create safer workplaces and mitigate the risk of a Bhopal-like disaster in the US, such as:

  • Charging the EPA and OSHA with more authority over the chemical industry.

    • OSHA created the Process Safety Management Standard (29 CFR 1910.119), a program that looks in depth at process technologies, procedures and management practices.

    • The EPA codified Chemical Accident Prevention Provisions (40 CFR Part 68) which requires facilities to conduct a hazard assessment, develop a prevention program, and implement a risk management plan.

    • Other laws that regulate the use of hazardous materials were enhanced.  These include the Toxic Substance Control Act (TSCA); the Resource, Conservation and Recovery Act (RCRA); and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).



  • Creating the U.S. Chemical Safety and Hazard Investigation Board (CSB). 


The Senate legislative history states: "The principal role of the new chemical safety board is to investigate accidents to determine the conditions and circumstances which led up to the event and to identify the cause or causes so that similar events might be prevented." Congress gave the CSB a unique statutory mission and provided in law that no other agency or executive branch official may direct the activities of the Board. Congress directed that the CSB's investigative function be completely independent of the rulemaking, inspection, and enforcement authorities of EPA and OSHA. The CSB became operational in January 1998.  

Accidents in the U.S. STILL OCCUR

In spite of this, accidents continue to happen.  In 2002, the Chemical Safety and Hazard Investigation Board (CSB) examined 167 chemical accidents that occurred between 1980 and 2001.  More than half of those accidents involved chemicals not covered by the regulations mentioned above.  The CSB recommended that the EPA and OSHA expand their regulations.  The Agencies did not agree with the recommendation stating they feel the best approach is worker education.  In 2004, OSHA formed an alliance with the EPA, the American Chemistry Council (ACC), and others to develop and provide worker education on chemical reactivity hazards. 

How do you feel about the expansion of regulations to include chemicals currently not covered by regulations designed to prevent accidents and reduce health risk?
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Topics: OSHA, health and safety, General Industry H&S, EPA, Emergency Response, H&S Training, Compliance, TSCA & R.E.A.C.H., Air Sampling, emergency response training, Exposure, environmental air monitoring, Respiratory, Public Safety

Safety & Health Training – A Victim of Its Own Success?

Posted by Shivi Kakar

Jun 14, 2010 1:11:20 AM

Capt. John DeFillippo, CHMP, EMT-B

These are tough economic times and businesses are looking to cut costs and save money. A disturbing trend I have noticed is the willingness of many companies to make cuts in safety programs and employee training in a misguided attempt to improve the bottom line.

Trained workers are safer workers.  The facts bear this out. Shortsighted statements I’ve heard include; “We don’t have problems in that area, so we’re cutting back on training.”, when the training was most likely the reason for the lack of problems.

Often, it is difficult to see how beneficial training can be until you experience the effects of its absence. Negative indications show themselves in higher EMRs, increased workman’s compensation claims, lost production time, and property damage. Only companies actively tracking and trending incidents are likely to realize this. (By the way, such companies would also be the ones least likely to make such cuts in the first place!)

It takes just one serious incident resulting in injuries to quickly eliminate any savings associated with cutting programs and training.  What’s more, most health and safety training is required by regulations, so there is also the risk of fines for non-compliance. These can be hefty and since most companies don’t budget for them, they become an extraordinary cost – right off the bottom line!

At Emilcott, we have seen firsthand the effects that result from a lack of training.  Recently, we were hired by a client who laid-off their safety director a couple years prior.  After starting our work, we informed the client of numerous safety violations throughout their organization. These appeared to be a direct result of the lapse in proper safety training – since they no longer had a safety director to oversee their program.  Through the Emilcott Training Institute, our client was able to receive the training needed to avoid these safety violations – and keep their employees safe and on the job. However, in their attempt to save money, the client ended up spending more in a short period of time just to catch up.

Making drastic H&S budget cuts just never pay off.  As experienced health and safety consultants, we work with our clients to offer solutions when budgets get tight:

  • Outsource until you can hire again – we have provided EHS professionals at our clients’ sites for just this purpose for both short and long term requirements.

  • Prioritize your H&S needs – consider the total reduction in your workforce or operations to determine where you can pull back and where you cannot.

  • Take advantage of training courses open to the public – it may no longer be economically sound to run a training course in-house, but don’t lapse on required courses.

  • Take advantage of FREE resources – many consultants provide lots of free info and OSHA will provide all types of assistance at no cost. As an example, Emicott offers a comprehensive Free Training Needs Assessment at www.emilcott.com!

  • Pool resources – look toward your industry’s professional organizations or neighboring companies to share services. Maybe a part-time Safety Director is better than none at all.

  • Ask a professional – put together a plan and a program to get you through the lean times


Has your company adjusted their health and safety program for leaner times?

Have you seen a direct effect and how are you compensating?
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Topics: OSHA, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Fire Safety, Occupational Training, Lab Safety, Safety Training in Spanish

What is a Certified Industrial Hygienist?

Posted by Shivi Kakar

Apr 23, 2010 5:47:54 AM

Sarah Stibbe Damaskos
Where were you the first time that someone casually mentioned that they were a Certified Industrial Hygienist? Chances are you immediately pictured some type of space-suited dental hygienist flossing the world’s most horrific tooth grunge.  Or maybe you heard the term “industrial hygiene” and the frightening image of super-sized Teflon underwear floated into your head?  The good news is that you were almost right – conceptually.

Certified Industrial Hygienists (“CIH”) are cool. Sometimes they do get to wear Major Tom kind of protective clothing and poke around dirty places but most of the time they’re more like a squad of Super Safety People and their goal is to protect you.  According to the American Board of Industrial Hygiene (www.ABIH.org) “Industrial hygiene is the science of protecting and enhancing the health and safety of people at work and in their communities.” 

Industrial hygienists (rather than be called Super Safety People which is so much better for T-shirts) fall into a large group more commonly known as Environmental, Health and Safety experts but CIH focus exclusively on Health – Occupational Health and Environmental Health.

The American Industrial Hygiene Association (www.AIHA.org) has created this handy list of typical EHS roles: 

  • Investigate and examine the workplace for hazards and potential dangers

  • Make recommendations on improving the safety of workers and the surrounding community

  • Conduct scientific research to provide data on possible harmful conditions in the workplace

  • Develop techniques to anticipate and control potentially dangerous situations in the workplace and the community

  • Train and educate the community about job-related risks

  • Advise government officials and participating in the development of regulations to ensure the health and safety of workers and their families

  • Ensure that workers are properly following health and safety procedures 


Essentially it means that a group of highly-trained, certified professional are able to prevent, investigate and address work and community safety issues so that you can live a longer, healthier life.  Specifically, industrial hygienists are focused on

  • Chemical, Biological, Physical and Other Hazardous Agent Exposure

  • Emergency Response Planning

  • Community Impact and Awareness

  • Workplace Conditions / Occupational Safety

  • Detection, Planning and Control


If you own a business and your operation has the potential to expose employees or subcontractors or neighbors to possible health hazards, you need an industrial hygienist to reduce your risk, save money and, of course, offer everyone peace of mind. If you would rather pretend that environmental, safety or health issues are not important, I suggest you purchase a pair of Teflon underwear and super-size it.

How do you feel about being called an Industrial Hygienist? What would be an improved or more descriptive job title?
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Topics: Emilcott, indoor air quality, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Hazardous Waste Management, Compliance, worker safety, Lab Safety & Electrical, Fire Safety, Public Safety, Working Green

OSHA's Latest National Emphasis Program (NEP)

Posted by Shivi Kakar

Jul 30, 2009 9:23:15 AM

Diego Tolosa, CHST

OSHA has unveiled its latest National Emphasis Program (NEP), the Process Safety Management (PSM) Covered Chemical Facilities National Emphasis Program. This program targets workplaces that could potentially release highly hazardous chemicals by evaluating their compliance of the PSM standard (29 CFR 1910.119). The only NAICS that has been excluded is 32411 (Petroleum refineries), which has been covered by the Petroleum Refinery Process Safety Management NEP.

The PSM Covered Chemical Facilities NEP will be used for programmed inspections at sites selected for the NEP in Regions 1, 7, and 10, unprogrammed and site-specific targeted PSM inspections in all OSHA Regions (click here to view the regions). Some of areas that will be assessed during the inspection include:

• Contract Employer Compliance (maintenance or construction).
• Individual processes. Includes: operator(s), age of the system and nature and PPE selection.
• Documentation. Includes: list of PSM-covered processes, maximum intended inventories, unit flow diagrams, process narrative descriptions, Process Hazard Analysis (PHA) and safe upper and lower operating limits and unit electrical classification diagrams.

For more information on the PSM Covered Chemical Facilities NEP, please refer to: http://osha.gov/OshDoc/Directive_pdf/CPL_02_09-06.pdf
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Topics: OSHA, General Industry H&S, H&S Training, Hazardous Waste Management, HazCom, Compliance, MSDS, NAICS

Top 10 Things to Know About Respiratory Protection & Fit Testing

Posted by Shivi Kakar

Jul 28, 2009 9:18:19 AM

Kevin Zeller

1. OSHA regulation 29 CFR 1910.134 details the requirements for a Respiratory Protection Program.

2. A Respiratory Protection Program is mandatory if any employee is required to wear any type of respirator during the course of their job.

3. The establishment and maintenance of a Respiratory Protection Program is the responsibility of the employer and must of: a written program, employee training, fit testing’ and medical surveillance.

4. All employees who will be issued respiratory protection must be medically cleared to wear a respirator before fit testing and donning a respirator

5. Only respirators which have been certified by the National Institute for Occupational Safety and Health (NIOSH) should be used

6. Fit testing for respirators is done to determine the correct size respirator for the employee.

7. Fit testing is required for all positive and negative pressure tight fitting facepieces.

8. Fit testing can be accomplished by using either a qualitative agent (eg Bitrex) or quantitatively (eg., PORTACOUNT®) with a probed face piece.

9. Fit testing must be conducted: prior to initial issuance of a respirator; when a different facepiece is used; when an employee’s physical changes may affect facepiece fit; and annually thereafter.

10. Employees must conduct a user seal check each time they wear a respirator to assure they have donned and adjusted the facepiece correctly.
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Topics: NIOSH, OSHA, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Hazardous Waste Management, Compliance, Occupational Health, Occupational Safety, Lab Safety & Electrical, emergency response training, Fire Safety, Respiratory, Occupational Training, Safety Training in Spanish, EMT, Fit Testing

Top 10: Water Safety at Work and Play

Posted by Shivi Kakar

Jul 21, 2009 10:31:34 AM

Capt. John DeFillippo, CHMP, EMT-B


The best thing anyone can do to stay safe in and around the water is to learn to swim. It’s never too late and kids should learn to treat the water with respect at an early age. As a veteran of the U.S. Coast Guard, an EMT and a licensed captain working in marine salvage, I’ve seen my share of tragedies on the water. Sadly, nearly all were avoidable. Here are some tips to help you stay safe in and on the water this summer when on and off the clock.

At Play

1. Swim in a supervised, marked area with a lifeguard present and never swim alone.

2. Enter the water feet first. Enter the water headfirst only when the area is clearly marked for diving .

3. Adults should never leave a child unobserved around water. Practice "reach supervision" by staying within an arm's length when around the water.

4. If you are caught in a rip current, swim parallel to the shore until you are out of the current. Once you are free, turn and swim toward shore. You can't swim against a rip, don’t’ try.

5. Keep toys away from the pool when it is not in use. Toys can attract young children into the pool.

6. If a child is missing, check the pool first. Go to the edge of the pool and scan the entire pool, bottom, and surface, as well as the surrounding pool area.

7. Take a Safe Boating Course. Many states now require this for operation of vessels, including personal water craft or jet-skies. Check your local laws.

8. Learn CPR and Basic First Aid. Knowing what to do in an emergency can save a life.

9. Leave water rescue to those who are trained. Too many would-be rescuers become victims themselves.

At Work

10. Do you or your employees work on, near or over water? Did you know that there are specific OSHA regulations covering the safety of such workers including required training and protective equipment? If you have any questions or you’re not sure, reply to this post or visit our Twitter page - @Emilcott and send a DM.
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Topics: General Industry H&S, Construction H&S, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Safety Training in Spanish, water safety, EMT

There is no OSHA in many developing nations

Posted by Shivi Kakar

Jun 11, 2009 9:38:16 AM

Sweatshop Conditions in Global Garment Factories – Efforts to Eliminate these Conditions

Paula Kaufmann - CIH
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Topics: OSHA, health and safety, General Industry H&S, H&S Training, Compliance, Occupational Health, Occupational Training, Safety Training in Spanish, Codes of Conduct

Picking a Green Theme: Household Items

Posted by Shivi Kakar

May 19, 2009 11:25:01 AM

Businesses, Charities & Groups that Can Help You be Green

Barbara Glynn Alves
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Topics: health and safety, EPA, Compliance, Working Green, landfill

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