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Hydrogen Sulfide (H2S) Forum Presented by the ANSI/ASSE Z390 H2S Training Standard

Committee Dan Brinkman, Jeffrey Painter, Frank Perry,

Eric Rosemann, and Chuck Simpson

Hydrogen Sulfide (H2S) Forum

Presented by the ANSI / ASSE Z390 H2S Training Committee

December 2-3, 2014 3

Forum Panel Presenters: • Frank H. Perry, CSP, P.E., CET

– Moderator and Facilitator

• Charles A. Simpson, CSP – Panelist

• Dan Brinkman, CSM, MSA, CSSM – Panelist

• Jeffrey Painter, CSHO – Panelist

• Eric L. Rosemann, CSP - Panelist



Status of Z390 Revision Process

• Accredited January 1, 1993

• Standards are scrutinized for revision every 5 years

• Current revision process for Z390 is the most extensive since its accreditation



• Levels of training to be defined

(a) H2S Orientation – for personnel without “hands-on” work on equipment; maybe 15-20 minute orientation

(b) H2S Awareness – for personnel working around potential exposure areas; maybe 1-2 hours in length



• H2S Certification – for individuals with “hands-on” work on and around equipment. More comprehensive training and may be 3-4 hours in length

All levels of H2S training are valid for a period of 1 year

No H2S Certification cards or certificates to be issued for orientations or awareness training




Chuck Simpson

York Risk Services

Why?



Is 1 PPM H2S TLV Reasonable?

• ACGIH reduced the TLV to 1 PPM.

• Many organizations, including ANSI Z-390 Committee, oppose the reduction from 10 to 1 PPM.

• ANSI Z-390 Committee is proposing an “Action Level” of 10 ppm.



What’s the Problem?

• Industry may have to move to closed, vapor recovery type operations.

• PPE may have to be used in a greatly expanded area and for extended periods of time.


December 2-3, 2014 10

What’s the Justification? • No evidence that adults in occupational

environments suffer any harm from exposure of 10 to 1 PPM.

• Rationale is temporary blood chemistry changes detectable in some people.

• The case cited to justify involves the exposure of a toddler to repeated exposures of unknown gases of unknown concentration.


December 2-3, 2014 11

December 2-3, 2014 11

Dan Brinkman High Plains Technology Center

Section 4 Instructor Qualifications


12

4.1 H2S training instructors/administrators shall have successfully completed an appropriate H2S train-the-trainer development course; they shall also be deemed qualified if they possess significant past experience in instructing in this field

December 2-3, 2014 Hydrogen Sulfide (H2S) Forum

13

Why should instructors attend an Instructor Development Course?

• Too much misinformation being given to end users by unqualified instructors

• Verify competency of instructors


December 2-3, 2014 14

4.1.1 The instructor/administrator shall be able to demonstrate his/her knowledge of the technical aspects of H2S training and proficiency in training techniques relating to H2S. Training credentials or certification from a recognized or accredited training authority constitutes qualification under this section.


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There is a difference between “qualified” and “competent” • Key word in 4.1.1 is DEMONSTRATE

• This reinforces the importance of attending an instructor development class


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4.2 Qualified H2S instructors should ensure that the comprehensive outline for their individual course of instruction includes all of the topics covered in this standard.


December 2-3, 2014 17

This falls in line with the requirements of ANSI Z 490 • A large number of instructors have never

heard of ANSI Z 490

• This standard gives us the requirements for teaching health and safety classes


December 2-3, 2014 18

4.3 and 4.3.1 The old adage of “if you don’t use it you lose it” plays into this. Instructors are requires to teach the class so they remain fresh and current on the topic


December 2-3, 2014 19

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Jeffrey Painter Fortis Energy Services

Section 6 Student Competency and

Qualification


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Competency and Qualification • Student competency shall be required at

the end of the training in order to receive qualification

• This performance-based competency shall be demonstrated through an evaluation mechanism designed to evaluate the student’s understanding of the materials presented throughout the training and use of demonstrated equipment.


December 2-3, 2014 21

• What are some common forms of performance-based evaluations?

– Written Test

– Verbal Test

– Practical Test

Competency and Qualification


• Documentation of the student’s ability to demonstrate such competency shall be retained as substantive proof.


Hydrogen Sulfide (H2S) Forum 22

December 2-3, 2014 23

• Due to the extreme hazard involved in H2S operations, each individual covered by this standard should be retrained annually.

• This is a matter of life and death not convenience!



December 2-3, 2014 24

December 2-3, 2014 24

Eric L. Rosemann, CSP

Eric Rosemann and Associates, LLC

H2S Training / Competencies A World-Wide Comparison


December 2-3, 2014 25

H2S TRAINING / COMPETENCIES WORLD-WIDE

• OSHA • TEXAS STATEWIDE RULE 36 • API RP 55 & 49 • CANADIAN “H2S ALIVE” • OPITO • ANSI Z390


December 2-3, 2014 26

LET’S COMPARE! HOW DOES ANSI Z-390 STACK UP AGAINST THE OTHERS?

OSHA STATE RULES

API 55 API 49 H2S ALIVE

OPITO Z390

SPECIFIC INSTRUCTOR COMPETENCIES ● ● ● ● ●

DEFINES MINIMUM STUDENT TRAINING ● ● ● ● ●

DEFINES ONSITE SUPERVISOR TRAINING ● ●

DEFINES REFRESHER TRAINING ● ● ● ● ●

INSTRUCTIONAL TECHNIQUE REQMNT ●

AUDIT REQUIREMENT ●

LEGEND ● ● REFERENCE TO, BUT NOT DEFINED WELL

WELL DEFINED


December 2-3, 2014 27


OSHASTATE RULES

API 55 API 49H2S

ALIVEOPITO Z390

CORRECTIVE ACTIONS & SHUTDOWN ● ● ● ● ●

WELL CONTROL - DRILLING ● ● ●

WELL CONTROL - WORKOVER ● ● ●

CONTINGENCY PLANNING ● ● ● ● ● ● ●


December 2-3, 2014 28


OSHASTATE RULES

API 55 API 49H2S

ALIVEOPITO Z390

HAZARDS & CHARACTERISTICS ● ● ● ● ●

SAFETY PRECAUTIONS ● ● ● ● ●

EQUIPMENT - SAFETY & SUPPORT ● ● ● ● ●

EFFECTS ON METAL ● ● ● ●

SOURCES OF H2S ●

HUMAN PHYSIOLOGY ●

MEDICAL EVALUATION ●


December 2-3, 2014 29


OSHASTATE RULES

API 55 API 49H2S

ALIVEOPITO Z390

WORK PROCEDURES ●

PPE ●

BURNING & FLARING ●

STATE AND FEDERAL REGULATIONS ●

DISPERSION MODELS ●

RESCUE TECHNIQUES ●


December 2-3, 2014 30


OSHASTATE RULES

API 55 API 49H2S

ALIVEOPITO Z390

FIRST AID ●

POST-EXPOSURE EVALUATION ●

METHODS OF DETECTION & MONITORING ●

ENGINEERING CONTROLS ●

TRANSPORTATION OF H2S CARGO ●

EMERGING TECHNOLOGIES ●


December 2-3, 2014 31


0

5

10

15

20

25

OSHA STATERULES

API 55 API 49 H2S ALIVE OPITO Z390

Poin

ts o

f Def

initi

on


December 2-3, 2014 32

SOME FINAL THOUGHTS… If you have them, why not use the consensus standards?

Civil case law will eventually speak to OSHA’s lack of specific definition

Quality of Instruction defined in ANSI Z390 covers the bases the other standards do not.


December 2-3, 2014 33


Any Last Questions of the Forum?

December 2-3, 2014 34


Thank you!

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