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.

How to identify chemicals or ingredients for elimination

Banning, Prohibiting and /or Restricting a Chemical or Ingredient

Eliminating the chemical or ingredient in the workplace eliminates the hazards associated with the chemical or ingredient. Elimination can prevent injuries, illness, loss or adverse effect on the environment. Elimination is the first method of control in chemical handling to consider. Elimination of a chemical or ingredient can take on a few different meanings.

Banned Chemicals or Ingredients are not to be present on a job site.

This method of control would begin with controlling access through a chemical approval process. Current inventories can be searched to determine if a chemical is being used and act to eliminate.

Banned Lists contain those chemicals and ingredients that are banned for use. The intention for the “Banned Lists” is not to simply provide a checklist to eliminate chemicals of concern. Rather, it should be viewed as specific examples that may also be used to guide substitution.

Prohibited Chemicals or Ingredients are allowed with very specific controls and limits. May require Senior Management and or HSE Committee approval. Organizations can select what chemicals and or ingredients are prohibited from their job sites, determine controls and limitations during the chemical approval process.

Prohibited Lists contain those chemicals and ingredients that have been approved with very specific controls. The intention for the “Prohibited Lists” is not to simply provide a checklist to eliminate chemicals of concern. Rather, it should also be viewed as specific examples that may substituted and/or require external monitoring or controls verification.

Restricted Chemicals or Ingredients are allowed with very specific controls and limits. Restriction may be based on use, volume, and/or environmental concerns. Organizations can select what chemicals and or ingredients are restricted, determine controls and limitations during the chemical approval process. Products listed in different environment and import requirements can be linked to meet restrictions.

Where to Begin? 3 Steps to Get You Started:

  1. Identify chemicals or ingredients of concern on human health and the environment. This can be done right in msdsBinders, run a regulatory report on designated substances of concern (i.e. BC/ON Designated Substances List, Alberta Code of Practice Schedule 1) for your jurisdiction to scan your chemical inventory. This will identify chemicals of concern in your jurisdiction.
  2. Search for chemicals or ingredients of concern in your chemical inventory. This can be done in msdsBinders by searching your chemical inventory by CAS number for the substance of concern.
  3. Act and eliminate. Once the substance restriction has been adopted, your organization must comply. The elimination of a substance must be in your chemical approval and handling process. It needs to be communicated to all areas from procurement to field workers.

Speak to a Chemscape Representative for further information on the elimination and substitution of dangerous substances as well as how you can use our CHAMP technology in msdsBinders to begin substituting for less hazardous chemicals.

How to Begin Substituting for less Hazardous Chemicals

Reducing your company’s chemical footprint by reducing the exposure to high hazard chemicals in the workplace can be achieved by substituting chemicals you use each day for similar chemicals that are less hazardous. As an example, a liquid can be substituted for a powder, or perhaps the work task to weigh out powders could be eliminated by buying the powder pre-packed. It still needs to confirmed that the replacement substance does not create a greater hazard than the current one.

There are many benefits to an organization from substitution; including:

  1. Improved immediate and long-term health of the workers potentially exposed to the hazardous substance
  2. Reduced costs to the organization by:
    1. lowering sickness absence
    2. spending less on control measures
  3. Cost savings on
    1. fire and explosion protection
    2. product consumption
    3. materials
    4. compliance with environmental standards
  4. Increased efficiency of work processes
  5. Reduced impact on the environment

Where to Begin
Start by eliminating any avoidable exposure to dangerous substances.  Look at open processes, (e.g. painting big surfaces, mixing /compounding in open containers/vessels) and processes that generate dust, vapours or fumes or disperse liquids in the air e.g. welding, spraying paint.

If you cannot change the work process, look at the substances being used by the organization and consider substituting substances that:

  1. increase fire and explosion risks
  2. potentially may lead to high exposure of workers
  3. result in exposure to many workers
  4. are carcinogenic or mutagenic
  5. are volatile, e.g., organic solvents
  6. are dispersed in the air (aerosols, dust)
  7. cause acute health risks, e.g., poisons, corrosives, and irritants
  8. cause chronic health risks, such as allergens, substances toxic for reproduction and others
  9. have already caused problems in your enterprise (health problems, accidents or other incidents)
  10. cause occupational diseases
  11. make regular health monitoring (medical examination of workers) necessary
  12. can be absorbed through the skin
  13. the use of personal protective equipment, especially respiratory protection, is necessary

Practical Steps to Substitution

Approval may be required before you take the practical steps towards substitution, ask yourself:

  • Who decides on what substance is being purchased?
  • Who has to comment or give agreement?

There are three steps to substitution:

Once you have identified that the substance or process is a hazard.

  1. Identify the alternatives: find out all the options available to you. Look for alternative process methods (to remove the need to use a substance entirely) and potential replacement substances (if elimination is not possible). If the substance you wish to replace is used in a widely applied process such as spray-painting or degreasing, then the number of options available is likely to be larger.
  2. Compare the alternatives: evaluate alternatives against the substance or process you are using at the moment. Complete a risk assessment of all the alternatives, including the substance or process used, and compare your findings. Think about what could happen if you use the alternatives. Does the alternative pose a new hazard and risk under the conditions of use? Will it work for the intended purposes?
  3. Decide whether or not to substitute: make a decision based on the regulatory requirements, technological possibilities, potential implications for the quality of the products, costs, including the required investment, and training for use of the new product.

Once you introduce the substitute assess how it is working.

Speak to a Chemscape Representative for further information on the elimination and substitution of dangerous substances as well as how you can use our CHAMP technology in msdsBinders to begin substituting for less hazardous chemicals.