Spill Prevention

            Spills. We’ve all heard of chemical spills or oil spills happening somewhere in the country or across the globe. Oil spills being one of the most popular hearing about and also one of the most dangerous. In the United States, the Environmental Protection Agency or EPA, has made oil spills one of their main priorities after the Deepwater Horizon oil spill that occurred in 2010.

            The Deepwater Horizon Oil Spill, also known as the BP Oil Spill, began on April 20^th, 2010 in the Gulf of Mexico. This spill has been considered the largest accidental marine oil spill throughout the entire history of the oil industry. What happened is that an underwater explosion and the eventual sinking of the Deepwater Horizon oil rig caused the sea floor oil leak that dispensed oil for 87 straight days. As of 2016, BP has invested in the restoration of the environment along the Gulf. Back in October of 2015, settlement agreements were filed with the federal court in New Orleans to resolve any and all state and federal claims arising from the Deepwater Horizon accident and spill. The $18.7 billion settlement included an over $7 billion to address claims for natural resource damages.

Many don’t know that the EPA is the lead federal response force when oil spills occur in inland waters while the United States Coast Guard is the lead response force for spills in coastal waters or deepwater ports. The EPA’s oil spill prevention program includes the SPCC or Spill Prevention, Control, and Countermeasure and the FRP or Facility Response Plan rules.

            The SPCC helps facilities prevent a discharge of oil into navigable waters, adjoining shorelines, and containing the discharge of the oil. SPCC Plans establish the procedures, methods, and equipment requirements to prevent any oil pollution. There are also certain rules that a facility must follow to a SPCC applies to that individual facility. The first thing facilities must determine is if they are considered non-transportation related. The second thing is that if the facility is currently engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using or consuming oil. Thirdly, if the facility is reasonably to be expected to discharge oil in quantities that can be harmful, into navigable waters or shorelines. Next, if the total aggregate capacity of above ground oil storage containers are greater than 1,320 gallons of oil. Lastly, the total aggregate capacity of completely buried storage tanks is greater that 42,000 gallons of oil.

            The FRP rule requires that certain facilities to submit a response plan and prepare to respond to a worst case oil discharge or threat of a discharge. The FRP demonstrates a facility’s preparedness when it comes to responding to a worst case scenario. Facility Response Plans must be consistent with Nation Contingency Plans and applicable Area Contingency Plans. This means an individual needs to qualified and has full authority to implement removal actions and requires immediate communication between that person and the appropriate federal authorities and responders. It is also stated that facilities must be able to identify and ensure availability of resources to remove, at the maximum extent practical, a worst case discharge scenario.

https://www.epa.gov/oil-spills-prevention-and-preparedness-regulations

http://www.bp.com/en/global/corporate/sustainability/environment/oil-spill-preparedness-and-response.html

Chemical Hygiene Plan

            When it comes to a Chemical Hygiene Plan, it’s hard to start one off from scratch. To begin with, we need to know what a Chemical Hygiene Plan is and what the components of it that make up an effective CHP. The Chemical Hygiene Plan was created and defined by Occupational Safety and Hygiene Association’s Occupational Exposure to Hazardous Chemicals in Laboratories standard or 29 CFR 1910.1450. A Chemical Hygiene Plan is a written program that states the policies, procedures and responsibilities that protect the workers from the health hazards associated with the hazardous chemicals used in that particular workplace.

            As said in the definition of the CHP, the elements that make up a Chemical Hygiene Plan are in the policies and procedures that it lays out. These policies and procedures should provide a guideline and the requirements for the use of the equipment in the lab and any personal protective equipment. The Chemical Hygiene Plan should also establish safe working practices known as standard operating procedures or SOPs for the use of hazardous chemicals or material in the lab. The Chemical Hygiene Plan should also be customized to each individual lab and kept within the Lab Safety Manual. The Chemical Hygiene Plan also needs to be accessible to the laboratory staff or students who need to refer to it.

            CHPs are written so that it keeps the employee safe from danger, so worker training needs to be included within it. Every employee needs to be trained in the methods of detecting the presence or release of a hazardous chemical and the use of appropriate work practices, emergency procedures, and personal protective equipment. Permissible exposure limits for any OSHA regulated substances or recommended exposure limits for hazardous chemicals where there is no applicable OSHA standard should also be noted in the CHP.

            Any lab personnel working with hazardous chemicals or materials should have access to the information and know the location of known reference material on the hazards, safe and proper handling, storage and disposal of hazardous material found in the lab. This means that they need access to Material Safety Data Sheets (MSDS) or Safety Data Sheet (SDS), depending on if HazCom has been initiated at the facility. The employer must also provide all personnel who with the hazardous chemicals an opportunity to receive medical attention if the need should arise, including follow-up examinations if the examining physician deems them necessary. The employer must also review and evaluate the effectiveness of the Chemical Hygiene Plan at least annually and update it as the need arises. The Chemical Hygiene Plan should also implement a laboratory inspection program that is conducted by the Environmental Health & Safety specialist or officer. He/she must ensure compliance with federal, state, and university requirements and beyond. All laboratory inspection reports should be kept in the Laboratory Safety Manual under the appropriate lab. The incident that occurred at the University of California: Los Angeles is a great example to look at if you are in need of updating a Chemical Hygiene Plan.

https://ucla.app.box.com/v/ehs-lab-safety-manual

https://www.osha.gov/Publications/laboratory/OSHAfactsheet-laboratory-safety-chemical-hygiene-plan.pdf

http://www.thestar.com/news/world/2014/03/30/a_young_lab_worker_a_professor_and_a_deadly_accident.html

Cryogenics

            From the physics standpoint, cryogenics is the study of the production and behavior of materials at very low temperatures. However, there are many sub branches of cryogenics. Cryobiology is the study of how the effects of low temperatures on organisms. The easiest way to describe cryobiology is to point people in the direction of Star Wars Episode V where Darth Vader has Han Solo frozen in substance called Carbonite that freezes him in an instant. Han was lucky to have survived the freezing. Cryonics, comes back to another sci-fi style of science in where humans or organisms are preserved using cryogenic methods, only to be revived in the future. A great example of this can be seen in the first Halo video game or read about in the novels. Cryosurgery is the study of applying incredibly low temperatures to destroy malignant tissue, like tumors. Finally, cryoelectronics is the study of superconductivity at low temperatures.

            Many people think that Dry Ice is considered cryogenics, but this is not the case. It is how ever couple with cryogenics due to properties of Dry Ice. Cryogens are substances that are used to produce temperatures that are below -153 degrees Celsius or -243 degrees Fahrenheit. A person who studies these elements and that has been exposed to extremely cold temperatures are referred to as a cryogenist. What Dry Ice will do is convert directly from a solid carbon dioxide to a carbon dioxide gas. This process will go at a rate of five to ten pounds every 24 hours, so it would be a good idea to pick up Dry Ice as close to the time its needed as possible. Dry Ice is often used in laboratories and shipments, so reviewing the hazards of cryogenics apply to it as well.

            Safety hazards associated with the use of cryogenic include cold contact burns, asphyxiation, explosion, pressure problems, or even chemical. Cold contact burns occur when the low temp liquid or gas produce an effect similar to that of a burn. Asphyxiation can occur due to the displaced oxygen in the environment due to the cryogens. Oxygen content when dealing with cryogens should be close to 22% by volume, but if that value drops to 18%, noticeable effects can occur. Around 6% oxygen volume will result in sudden death. When it comes to cryogenics, explosions are caused by pressure when the heat flux into the cryogen from the environment will vaporize the liquid and cause a potential build up of pressure. In order to counter this, adequate pressure relief needs to be provided to all parts of a cryogenic system to permit the routine outgassing to prevent the build up of pressure and potential explosion. Chemical explosions occur when the cryogenic fluids with a lower boiling point than that of liquid oxygen condense the oxygen from the atmosphere. This will lead to an oxygen enrichment, in which violent reactions and rapid combustion or an explosion may occur if the material comes into contact with the oxygen.

http://dryiceinfo.com

http://www.britannica.com/science/cryogenics

http://halo.wikia.com/wiki/Cryonics

BBP

            BBPs or Blood borne Pathogens and disease spreading microorganisms that are present in human blood. These pathogenic microorganisms have the ability to cause diseases in humans that include Hepatitis B, Hepatitis C, and Human Immunodeficiency Virus. During the semester, our class had the opportunity to tour a lab on campus that does blood work. The lab was located in Grover Center and the professor, Dr. Kushnick was gracious enough to give us the tour of his lab. Once everyone from our class was in the lab, Dr. Kushnick gave us a quick rundown of the work that the students did in his lab and the work they do for OU’s Exercise Physiology Program.

            While going through the lab, Kushnick pointed out various safety checks that he had in place throughout the lab. One of the first ones he pointed out was the cover that was installed on the centrifuge to prevent aerosolizaiton of any blood samples that may have broken in the centrifuge. The next feature he pointed out was the absorbent material that is placed over the main table in the lab. This absorbent material has an absorbent top layer and a plastic layer underneath to trap any liquid that has been spilled on it so the material is easily replaced.

            When looking around the rest of the lab, many things caught my attention, both good and bad. For the bad things, was the fridge that was located in the lab. The fridge itself was just a standard commercial fridge that you could buy at Lowe’s or Best Buy, not the kind required to hold the material that was being stored in it. The next thing was the lack of a proper storage cabinet for chemicals in the lab, but as Kushnick described it, there wasn’t enough money in the budget for one and how he had his chemicals stored in the lab worked for his needs, so he didn’t get into to trouble for it. Probably one of the biggest ‘bad’ things that caught my attention were the old lemonade and juice containers being used as liquid waste storage containers. These jugs had a skull and crossbones on them, but the symbol was small and incredibly faded to the point to where you couldn’t see it.

            When it came to the students in the lab, it is important to note that they will still fall under OSHA protection as an employee. Hence, it is required that they be trained in how to handle blood and working in this lab gave those students the opportunity to improve those skills. All unknown infectious materials when working in a blood lab need to be treated as though they are contaminated with HIV, HBV, or other blood borne pathogens. A good place to start with that is to have engineering controls in place such as sharps containers throughout the lab and fluid resistant barriers used efficiently in the lab. Work place habits such as hand washing are heavily enforced in the lab as there are signs and postings all over the lab and near sinks.

https://www.ohio.edu/riskandsafety/docs/bbp_prog2010.pdf

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051

Process Safety Management

           Process Safety Management came about in 1992 due to horrific and catastrophic incidents that were occurring around the world that came about as a result of unintended releases of highly hazardous chemicals, or HHCs.  For Process Safety Management, you have fourteen important parts for it to work correctly. 

            Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Contractors, Mechanical Integrity, Hot Work, Management of Change, Incident Investigation, Compliance Audits, Trade Secrets, Employee Participation, Pre-startup Safety Review, and finally Emergency Planning and Response. Employee Participation is probably the shortest of all the elements, but has the biggest impact. According to CFR 1910.119, employers need to develop a written plan of action regarding the implementation of employee participation. Essentially employees, production, maintenance, and any other staff are to be involved in all aspects of the PSM program. 

            Process Safety Information is considered one of the most concentrated, maintenance-specific listings of all the elements. In CFR 1910.119, it is stated that the employer shall complete a compilation of written process safety information before conducting any process safety hazard analysis. Process Hazard Analysis is one of the more technical elements, and even includes a what-if evaluation. In the CFR, it states that the process hazard analysis needs to be appropriate to the complexity of the process and needs to identify, evaluate, and control the hazards involved in the process. 

            Operating procedures seem like an oversight by many people, but the element itself has a few items to take note of. In cases of physical contact or airborne exposure, control measures are to be taken after startups following a turnaround or an emergency shutdown. The Training element specifically addresses the needs for those during a process operation. Maintenance technicians need to be fully trained for all the functions they are performing, and the training needs to be accomplished through a competent source and very well documented. Contractors can provide a plethora of opportunities to trip an otherwise healthy and well-executed maintenance strategy.

            Pre-Startup Safety Reviews are important reviews that need to take place before any highly hazardous chemical is introduced into a process. With the PSM, it requires the employer to perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. Mechanical Integrity is something that OSHA believes is important to maintain. The integrity of critical process equipment is important to ensure it is designed and installed correctly and operates properly. Hot Work Permits are issued for hot work operations conducted near or on a covered process. The permit must document that the fire prevention and protection regulations have been implemented prior to beginning the hot work operations, the date or dates authorized for the hot work, and the identity of the object on which the hot work is to be performed. 

            

            One of the other most crucial elements of PSM is Incident Investigation. Incident Investigation is a thorough investigation of any incident to identify the chain of events and causes so that corrective measures can be developed and implemented. PSM requires the investigation of each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical into the workplace. 

https://www.safetyinfo.com/guest-library/materials/process-safety-management-elements-psm

http://www.plantengineering.com/single-article/the-14-elements-of-osha-inspections-how-they-affect-maintenance-processes/124d9efb4bf664edbf59804775c72cc1.html

https://www.osha.gov/Publications/osha3132.html#psi