Simultaneous Operations “SimOps” and Identifying Health Hazards

Do you have Concurrent or Simultaneous Operations in your organization? Could one operator’s tasks be unknowingly generating health hazards for others? Learn how to quickly Identify, Communicate and Control Chemical Hazards and Health Risk at these job sites. Our safety expert John Artym and Industrial Hygienist Mike Phibbs CIH ROH face off.

At many jobsites there are multiple operations occurring at the same time. Imagine welding, abrasive blasting and coating all taking place at the same location at the same time. The execution of two or more tasks by two or more functional groups on the same location at the same time are referred to as Simultaneous or Concurrent Operations “SimOps”.

Being effective at ensuring health and safety at the workplace requires commitment (from management and workers), resources, and a mature Health and Safety Management System. This challenge increases in complexity on a jobsite with SimOps or Concurrent Operations. We will define Simultaneous or Concurrent Operations “SimOps” as the execution of two or more tasks by two or more functional group activities on the same location at the same time. You are more likely to find SimOps during construction or when major maintenance work is being done within a “live” process area of an existing facility, on multiple well pad operations and multiple contractor facilities.

Safety View on SimOps Hazard Management Industrial Hygienist View on SimOps Hazard Management
During SimOps, organizations must consider how the hazards can be transferred or released to other functional groups.

Think of an example in construction or fabrication:  Equipment is being manufactured and/or fabricated at a jobsite where several hazardous chemicals are being used or created (i.e. welding fumes, toxic paints, abrasive blasting). Does your Chemical Management system or SimOps plan account for the electrical crew working downwind from the sand blasting operations? Are the painters working alongside the welders aware of the hazard and potential occupational health harms of the welding fumes?

The concern is that while performing independent operations, these activities and/or events may impact the health and safety of personnel or equipment or the environment of another operation. Specifically, with respect to Chemical Management and preventing exposure to workers both the physical and occupational health risks must be managed. First, to control the chemical hazards during SimOps a thorough hazard assessment should analyze each chemical and its ingredients. It is important to KNOW the Hazard. Secondly, the risk needs to be determined based on utilization (quantity, volumes, time, volatility), the task being performed and the effectiveness of the controls and measures. Who is in control of the chemical? Remember to include all your Manufactured Products, Process Additives or Shop Supplies.

Key Considerations:

1.      Do you have systems in place to maintain the Chemical Inventory, complete the hazard ranking/grouping and can communicate the hazards and controls/measures?

2.      Consider the task being performed. Will workers encounter those chemicals or their by-products? Has the physical state changed (e.g. bentonite with crystalline silica in a solid state mixed into a liquid solution)? Has the risk changed?

3.      Are the engineering controls changing (e.g. hazardous product is contained in a piping system, but containment must be broken to change filters or take samples)?

4.      Is there an energy source that will transfer the hazardous chemical or harms into concurrent operations (e.g. failure of a pressurized system spreads liquids containing BTEX across the jobsite)?

5.      Do the administrative controls and measures, PPE/RPE requirements apply for all the crews/workers on the jobsite? Consider who is at risk.

6.      Success is based on concise and on-going communication. Do your systems and “plan” demand expectations? When SimOps are planned or identified, it is important that all relevant and involved parties are include in the SimOps plan.

At multi-employer work sites with multiple hazards Industrial Hygienist need to focus on identifying and communicating the health hazards and risks in these situations. For example, on a job site you may have abrasive blasting, welding and coating tasks all taking place at the same time. We often focus on the individual tasks and hazards and focus on controlling the hazard for that task and the individual(s) involved. But on a busy job site there is typically numerous activities going on. Employers must protect their workers for the sum of the hazards on the job site regardless of who introduces a hazard. Chemical hazards do not respect fence posts or boundaries between tasks and when you add in the factor of wind these individual health hazards interact and pose additional health hazards.

In this common situation the hazards and risk need to be quickly determined. Controls need to be determined. Which party will determine what is acceptable? Who will implement? Who will bear the costs? How will this be communicated at the job site so others will act?

There are two professional trains of thought among the IH community and let’s call them System 1 vs. System 2 thinking. System 1 is automated – control first and then monitor. System 2 is calculated – monitor and then control. Health hazards lend themselves to System 1. IH’s commonly adhere to System 2. But daily exposure for workers need immediate action. Operations don’t cease for measurement, study and recommendations for exposure reduction that can take weeks to conclude.

Risks are not controlled if your hazards are not known. This returns to the foundation of doing a thorough hazard inventory. Being aware of all known health hazards. Having a discussion on how hazards transfer across workspaces. Will one operator’s tasks generate health hazards for others? Do controls for one work space apply to all?

Have you decided who is ”Prime” or how many “Primes” are at the site? The Prime Contractor on a jobsite is obligated to protect workers. But what if there are multiple primes on a jobsite? Is everyone in agreement?

It is important to define physical and task boundaries. Do Minimum PPE and Administrative Controls apply universally? Do Engineering Controls cause interactions? i.e. LEV vents towards others. Do controls change with the task?

Simplified and clear communication is important in this situation. Who is responsible to communicate the information to certain groups and in what level of detail? Icons and Images are effective to communicate information quickly and reach audiences who may have language and literacy challenges.

 

The quicker you identify hazards, understand potential interactions and communicate concisely the more effective you will be at preventing harm from chemical exposure(s) during Simultaneous Operations or Concurrent Operations. Commitment and communication from the project Owner, the Prime Contractor(s), and Contractors on the site is critical to effective management the numerous challenges encountered on a SimOps work site.

Chemicals and Medications contribute to Hearing Loss

March 3rd was World Hearing Day. It is well known that exposure to noise levels in the workplace can cause hearing loss.  However, you may not be aware that exposure to certain chemicals in the workplace as well as medication you may take on a regular basis can also damage your hearing.  These chemicals are said to be ototoxic (oto = ear, toxic = poisonous).  Furthermore, work activities where noise and ototoxin exposure are combined can lead to even more severe damage. There are over 750 groups of chemicals that are potentially ototoxic.  Some chemicals in your workplace may include benzene, carbon monoxide, lead, mercury, carbon disulfide, styrene and toluene. Exposure to ototoxins in the workplace can occur through swallowing, skin contact/absorption or inhalation. System administrators can use the msdsBinders system to identify chemicals that contain a least one ingredient that is known as an ototoxin.

Ototoxic medications have a toxic effect on the nerve cells of your inner ears. Over time, long-term usage of certain prescription medications can result in tinnitus or hearing loss. Hearing loss caused by an ototoxic medicine tends to develop rapidly. Initial symptoms tend to be ringing in the ears (tinnitus) and vertigo.  Hearing usually returns to normal after the patient stops taking the medicine. But some medicines can cause permanent damage to the inner ear and this results in permanent hearing loss.

A common prescription drug that can be ototoxic is Viagra. A 2007 study, published in The Archives of Otolaryngology-Head and Neck Surgery, shows that some individuals who have taken Viagra and other PDE-5 inhibitors reported sudden hearing loss in one or both ears, sometimes accompanied by tinnitus, or a ringing in the ear. In fact, men who have taken Viagra or other PDE-5 inhibitors are twice as likely to report hearing loss than men who have never taken the little blue pill. The findings prompted the Federal Drug Administration to send out a new warning for Viagra in 2007. The reason for the reported hearing loss isn’t specified, though hearing experts believe that increased blood flow to the delicate hearing mechanism may damage parts of the auditory (hearing) system.

Other commonly used medicines that may cause hearing loss which may surprise you include: Aspirin, when large doses (8 to 12 pills a day) are taken; Acetaminophen; and Anti-inflammatory drugs NSAIDS, like ibuprofen and naproxen. A study published in the March 2010 issue of The American Journal of Medicine suggests that regular use of these pain relief medications can cause hearing loss. The study, conducted by scientists at Harvard University, Brigham and Women’s Hospital, Vanderbilt University and the Massachusetts Eye and Ear Infirmary found an increased risk of hearing loss in men younger than 60 who regularly used NSAIDs.

Other commonly used medicines that may cause hearing loss include: certain antibiotics like aminoglycosides; diuretics; and certain chemotherapy drugs.

2018 Initiatives for WorkSafeBC in Oil and Gas

On November 29, 2017 WorkSafeBC presented a Pre-Drilling Season Update in Ft St John. Chemscape attended and I wanted to share some key points from this meeting. The Upstream Oil and Gas Industry in BC currently has 1,891 employers. Oil and Gas has the lowest injury rate of all classification Business Units in BC but they have one of the highest short term disability duration. Tragically, there has been 13 work-related deaths in the past 5 years.

A main message from WorkSafeBC was that exposure to hazardous chemicals remains a major risk for workers. Although injuries are down year over year drilling related work remains the highest risk for injury. Inspection reports and prevention orders have been increasing year over year.  In 2018, 95 Targeted Inspections occurred – 25 Occupational Exposure focused inspections.

In 2018, WorkSafeBC has an initiative in Oil and Gas to reduce the serious injury and fatality rate by implementing risk reduction tactics. WorkSafeBC predicts occupational disease claims and deaths to surpass the rates of injuries in the upcoming years.

Exposure Control Plan’s will continue to be a compliance focus for them in 2018 in Oil and Gas with a risk assessment of potential hazardous exposures including hydrocarbon based drilling fluids, aromatic hydrocarbons (benzene, toluene etc.), NORMS, Silica (new asbestos), Diesel exhaust. There are emerging concerns on welding fumes migrating through respiratory system/circulatory system and lodging in major organs as well as Ultra Violet Rays from the Sun as 1 in 3 new cancer diagnoses in Canada is now a skin cancer.

Some other Field issues which were addressed in the meeting include:

  • Proper respirator use and fit testing, being clean shaven. (OHSR 8.40(1-2)
  • Annual Hearing testing of workers (OHSR 7.8)
  • Immediate Reporting of Reportable Incidents
  • Having adequate Confined Space Entry Procedures: ability to identify all confined spaces by a Qualified Person; ability to conduct a proper hazard assessment of the CS’s by a Qualified Person; Failure to develop proper CSE prior to entry by a QP; Proper testing and monitoring of the atmosphere in the CS (before and during entry); Adequate continuous ventilation of the confined space, Proper supervision of confined space entry, adequate training of workers, Supervisors and persons conducting the CS assessments; and having ECP’s for hazardous products in the CS.
  • Tank cleaning safety concerns: having adequate grounding and bonding, adequately monitoring for hazardous atmospheres during cleaning, Vac trucks being equipped with rated hoses, valves and fittings; adequate training of all involved workers in regards to hazard assessments, proper SWP, use of equipment; having an ECP for exposure monitoring; having proper or appropriate PPE; disclosing and monitoring tank cleaning by parties commissioning the work.
  • Issues related to recent fire & explosion at well site due to vapor overflow at de-gasser.

Contact us at marketing@chemscape.com if you are interested in receiving the full report with all the field issues and concerns which WorkSafeBC encouraged all attendees at the meeting to share with their network.

A chemical management system can help address many of these issues. If you are challenged with this or developing Exposure Control Plans Chemscape can help.

Managing the upcoming changes to Alberta Occupational Health and Safety Act

By: John Artym, Vice President of CHAMP

As you are probably aware the Alberta Occupational Health and Safety Act is currently being reviewed, proposed changes have been shared for comment and Bill 30 has received first reading in the Legislative Assembly. Putting aside the legislative process for review and approval, it is important that organizations, managers, and workers all take the required time to assess the changes, identify any gaps in their Health and Safety Management Systems and consider strategies for implementation.

Understanding the “Why” for the proposed changes may help your teams determine/assess your gaps and develop your Corrective Action Plans.

Things to Consider: Do you have adequate authorities, responsibilities and accountabilities? How effective are your management systems? How engaged is your workforce? What are you measuring?

Some of the key areas being reviewed include:

  1. Responsibilities of Work Site Parties.
    1. How do you define “Health and Safety”? Do you consider psychological and social wellbeing? What about “Fit for Duty”, preventing violence or harassment at the worksite?
    2. How do you define worksites and who are your supervisors of the said worksites?
    3. Are your Supervisors competent?
  2. Health and Safety Program or Management systems.
    1. How are you engaging your workers? How do you communicate the hazards at your worksites? Do you have a Joint Work Site Health and Safety Committee?
    2. How are you planning to implement the Right to Refuse Dangerous Work? What actions are required when you shift from the “obligation” to the “right”?
  3. Reporting of incidents and OH&S responses.
    1. What type of incidents must be reported? What are the changes to the thresholds for reporting (hospital Admissions vs.2-day requirement or potential to cause a serious injury)? Who needs to be involved in the investigation?
    2. Additionally, the WCB Act has numerous proposed changes: Workers and Employers Code of Rights, establishment of an Occupational Diseases and Injury Advisory Committee, etc.

Ultimately the proposed changes are about preventing Occupational illness/diseases and injuries. The challenge for organizations is how to successfully implement.

For more information on this topic I personally recommend visiting these links:
http://www.assembly.ab.ca/ISYS/LADDAR_files/docs/bills/bill/legislature_29/session_3/20170302_bill-030.pdf

https://www.alberta.ca/ohs-changes.aspx#top

https://www.bennettjones.com/en/Publications-Section/Updates/Dramatic-Revision-of-the-Alberta-Occupational-Health-and-Safety-Act

Health & Safety Apps for working with Chemical Hazards

Here are some Health and Safety apps for working with Chemical Hazards that we have been recommending to make your work more productive:

Wiser
WISER (Wireless Information System for Emergency Responders) is a mobile application designed to assist first responders in hazardous material incidents. The WISER application extracts content from TOXNET’s Hazardous Substances Data Bank (HSDB), an authoritative, peer-reviewed information resource maintained by the National Library of Medicine. It provides accurate information about hazardous substances, the emergency resources available, and the surrounding environmental conditions to save lives and minimize the impact on the environment and physical property.
Android
https://play.google.com/store/apps/details?id=gov.nih.nlm.wiser&hl=en
Apple
https://itunes.apple.com/ca/app/wiser-for-ios/id375185381?mt=8

ERG App
PHMSA (U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration)’s 2016 Emergency Response Guidebook provides first responders with a go-to resource to help deal with hazmat accidents during the critical first 30 minutes.
Apple
https://itunes.apple.com/ca/app/erg-2016/id592158838?mt=8
Android
https://play.google.com/store/apps/details?id=gov.nih.nlm.erg2012&hl=en

msdsBinders
We have to recommend out own app! Search for your companies (M)SDSs, print, email and save your binder offline. You must be a customer with msdsBinders to use this. Free app available on apple and android devices.
Apple
https://itunes.apple.com/ca/app/msdsbinders/id982354626?mt=8
Android
https://play.google.com/store/apps/details?id=com.chemscape.msdsbinders&hl=en

NIOSH Pocket Guide to Chemical Hazards Mobile Web Application
This Mobile Web App works on any mobile device with an HTML5-compliant web browser and can be used offline. The industrial hygiene information found in this Pocket Guide assists users to recognize and control occupational chemical hazards. Content is sourced from the National Institute for Occupational Safety and Health (NIOSH®).
Apple
https://itunes.apple.com/us/app/chemical-hazards-pocket-guide/id337472634?mt=8
Download it from your web browser on your mobile device.
https://www.cdc.gov/niosh/npg/mobilepocketguide.html?s_cid=3ni7d2NiUpdatemNPG07142016

Transportation of Dangerous Goods needs to be integrated into your Chemical Management Program

By: Corinne Paul
If your organization produces or ships chemical products you likely have different departments working on different areas of that product’s life cycle; whether that is marketing them, managing their hazards and risks, or transporting those products. All departments have many common links and tasks between managing a chemical but frequently, they do not communicate with each other. For example, your marketing group may be selling a product under one name, the Safety Data Sheet is likely written for the product under a separate name and when transported the product’s shipping name can be entirely different again. These groups may even be conducting their own sampling of the product.

Communication between the industrial hygienist, process engineers and marketing personnel is important so they all understand what the chemical properties are of the product they are selling and what is being communicated to carriers and customers.

Sampling is critical to many elements of a Transportation of Dangerous Goods (TDG) program. Section 15 on a Safety Data Sheet informs people of the Transportation of Dangerous Goods criteria. Sampling affects classification which determines placarding and safety marks on a means of containment (MOC). Composition affects the class of the product and flammability affects the packing group. Developing a sampling strategy ensures confidence in the proper classification, which flows into accurate and reliable SDSs. Proof of Classification is a regulatory requirement under TDG and needs to be incorporated into your TDG and/or Chemical Management program.  Is that information readily available for all groups to access? Is every group conducting their own sampling activity or can this be consolidated for efficiency?

Better communication between these 3 groups will mitigate the risk of miscommunication on products and reduce an overlap of tasks. It may also minimize the risk of an error on shipping documentation or placarding that can result in a TDG infraction.

How do you define “Fit for Duty”? And how you can incorporate this into your event/incident investigations to uncover the WHY.

By: John Artym

I have recently been part of industry conversation with respect to preventing injuries and occupational illness.  Part of our discussions has raised the issue that industry must move pass deferring to the immediate cause(s) of events/incidents to focus on determining the indirect/root causes of events/incidents to improve how they answer – why events/incidents occur?

The control measures and counter-measures organizations implement must focus on the gaps in management systems and those indirect or root causes. It is easier to focus on substandard conditions or blame an individual for a substandard act(s) then determine the “WHY”.

The worker’s mind was not on task…they made a mistake…impaired decisions…distracted driving…or fell asleep at the wheel are all terms we have heard to explain why an event/incident occurred. A typical investigation focuses too much on anecdotal information, peer discussions and personal experience.

Does your investigation ask if the individual was “Fit for Duty”? Does the organization have a Fit for Duty model or standard? Was this a contributing factor? Or the indirect or root cause?

“Fit for Duty” is a term used by industry to describe the individual’s physical, mental or emotional state and how it enables their job performance in a manner that optimizes safety and performance.

What should be included in “Fit for Duty?”

  1. Physically capable to safely perform the work duties.
  2. Mindset, mentally and emotionally capable to perform the work duties.
  3. Not impaired by drugs (alcohol, legal or illegal drugs).
  4. Medically capable to perform work duties (chemical sensitivities or exposure risks).
  5. Human Factors (communication, language, cultural, social aspects).
  6. Not impaired by fatigue (personal and operational).
  7. Not impaired by cognitive distraction.

Ultimately, it is about having the capacity to make the correct decisions when required and the ability to preform the work activities safely. Usually, there are multiple causes and contributing factors to an incident and considering the aspects of a workers’ emotional, physical and mental state as well as the many aspects of their work environment will help point uncover the WHY.