Transcript Adult Education Techniques - Permian Basin STEPS

Accepted Practices for
Hydrogen Sulfide (H2S) Safety
Training
Status of the ANSI Z390.1
And Impact on the Oil, Gas,
and Petrochemical
Industry
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 mid1980s 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
Z390.1
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This standard sets forth accepted
practices for hydrogen sulfide (H2S)
safety training and instruction of affected
personnel .
The purpose of this standard is to
establish minimum requirements for sitespecific H2S safety training programs
that will enhance safety in occupational
settings where hydrogen sulfide is
present, or is recognized as being
potentially present, above the TLV-TWA.
The “Guts” of Z390.1

Section 3 – Training Criteria

Section 4 - Instructor Qualification
& Proficiency

Section 5 - Documentation and
Recordkeeping
The “Guts” of Z390.1
(continued)

Section 6, Student Competency and
Qualification

Section 7, Training Techniques,
Language and Literacy Factors

Section 8, Protection Requirements for
Visitors
What Drove the
Revision/Changes???

By procedure ANSI Standards must
be reaffirmed, revised, or withdrawn
every five years.

Technology and training
methodologies have changed since
the first version of the standard
Key Changes to Z390.1

Acute and Chronic exposure redefined

Boiling Point changed to Flash Point

Respiratory protection references
changed from Z88.2-1991 to 29CFR
1910.134 as amended in 1998

Dispersion modeling section to be
covered “if applicable”
Key Z390.1 Changes
(continued)

Physiological effects of chronic
exposure

“No course is ever to be abbreviated….”
removed

Certification cards may be issued by the
instructor

Computer-Based Training issue was
addressed
ACGIH – Impact on
Z390.1???
ACGIH Notice of Intended Change of
TLV/TWA for H2S in 2004

TLV from 10 ppm to 1 ppm

STEL from 15 ppm to 5 ppm

NIC was published and ACGIH
Board action was to be reported
February 2008
The TLV / TWA Issue

ACGIH proposing dramatically lower safe exposure limit for H2S - 10
PPM to 1 PPM

Likely to be adopted as law, at some point, by state and Federal
agencies
– OSHA
– EPA
– ?

Oil, gas, and petrochemical operations frequently result in Time
Weighted Average exposures of 1-3 PPM to personnel in operational
areas, instantaneous exposures is excess of 5-10 PPM are common

Reducing worker exposure to 1 PPM technologically/economically
difficult
– Almost continuous use of respiratory protection in operational areas; and
/or
– Vapor recovery equipped tanks, trucks, barges, railcars, loading/unloading
racks, re-engineering the entire oil, gas and petrochem infrastructure!
TLV® - Threshold Limit
Value

“An occupational exposure value recommended by
ACGIH® to which it is believed nearly all workers can be
exposed day after day for a working lifetime without ill
effect.”

By itself, TLV® simply indicates an exposure limit
established by the ACGIH.

TLVs® are frequently incorporated into law and cited in
litigation

ACGIH position – don’t blame us were just scientists
objectively reviewing research
ACGIH Statement of
Position Regarding the
TLVs® and BEIs®
The Problem

A 1PPM TLV® -TWA is likely to be imposed on industry
through regulation or litigation

Worker exposure in operational area of oil, gas, and
petrochem facilities often have a TWA exposure of 1-3
PPM, with frequent instantaneous exposures of 5-10 PPM

Personal Protective Equipment or Engineering Controls
only options to limit worker exposure

Reducing exposure to 1 PPM or less does not appear to
be technologically / economically feasible
Atmospheric Monitoring

Instruments designed for continuous
monitoring are not particularly accurate
– Electrolytic cells ± 15%
– Semiconductor ± 5 PPM
– Colorimetric tubes ± 25%

Many instruments currently used are not data
logging and cannot calculate TWA
Respiratory
Protection
Air Purifying Respirators

Acceptable between TLV/TWA - IDLH

APRs potentially dangerous to use for H2S
– unanticipated spikes above IDLH when performing certain
work (gauging, unloading, etc.)
– Poor warning characteristics of H2S can prevent detection of
breakthrough

APRs uncomfortable due to weight on head & high
breathing resistance

APRs expensive over long term
– Approx. $10.00 / set of cartridges / person
– 1-2 sets used / day
Respiratory Protection
Self Contained Breathing Apparatus

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
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Must be worn above IDLH
May be worn above TLV
Expensive
Require a lot of support equipment
Short use duration
Hoselines restricted to no more than 300
feet
Not user friendly
– Heavy
– Bulky
– Restrict mobility
Engineering
Controls

Unlikely concentrations of H2S in oil, gas,
and petrochem industry can be significantly
reduced
– Chemical treatment?

Vapor Recovery
– Could reduce airborne concentrations of H2S
– Extremely expensive
The Action

Encourage the ACGIH not to adopt proposed
TLV-TWA
– Research does not indicate harm from concentrations
lower than 10 PPM
– 1 PPM is arbitrary concentration
– Not technologically or economically feasible
– No evidence lower TLV-TWA will make workers safer!

If adopted
– Closely monitor regulatory actions which might result
in proposed TLV-TWA becoming law
– Vigorously lobby against adoption of proposed TLVTWA into law
The TLV Bad News


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ANSI Z-390 H2S Training Committee
and API vigorously opposed change –
ACGIH did not find their arguments
compelling
Although not final, momentum is for
adoption
ACGIH is also proposing lowering the
TLV-TWA of SO2
Private-Public Sector
Impact From Z390.1

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The standard is not cited by reference.
The standard is recognized by a
number of government agencies.
The standard is cited in numerous
private sector contracts and work
agreements.
The standard has been used in the
past for vendor
certification/accreditation claims.
CONCLUSION
Revised standard is more userfriendly
Stresses prevention of dangerous
work practices in hazardous
atmospheres caused by mediocre
or deficient training
Training Issues…




Continue to train to the standard
Continue to develop competent
instructors
Redeveloped / standardized
instructor training materials
H2S Master Trainer Course with
CSHI
Thank you!
Any Questions?