Beacon Occupational Health and Safety Services
igned into law by Richard Nixon in 1970, the Occupational Safety and Health Act (OSHA) was designed to ensure employees work in an environment free from toxic chemicals, temperature stress, mechanical dangers, excessive noise levels, and other hazards. But in Alaska’s oil and gas industry, OSHA safety standards are considered a low bar, with many companies opting to adhere to much stricter safety guidelines of their own making.
“Many OSHA standards are outdated and less stringent; therefore in striving to meet American Conference of Governmental Industrial Hygienists guidelines, the oil and gas industry often finds itself in a good position meeting or exceeding the maximum allowable permissible exposure limits promulgated by OSHA.”
The importance of industrial hygiene goes beyond the need to protect employees. When a company fails to comply with safety standards and there is a resulting injury, it can lead to expensive workers’ compensation lawsuits and damage a company’s reputation.
In OSHA’s Office of Training and Education material, the agency describes industrial hygiene as the “science and art devoted to the anticipation, recognition, evaluation, and control of those environmental factors or stresses arising in or from the workplace, which may cause sickness, impaired health and well-being, or significant discomfort among workers or among the citizens of the community.”
OSHA’s training material points out that the relationship between workers’ health and their environment was understood long before the agency began implementing regulations in the United States. As early as the fourth century BC, the Greek physician Hippocrates of Kos documented issues with lead toxicity in the mining industry. In the same vein, the Roman scholar Pliny the Elder recognized health risks for those working with zinc and sulfur in the first century AD. Pliny created a face mask from animal bladders to protect workers from the fumes.
In the oil and gas industry more rigorous (and modern) systems are put in place to keep employees and equipment safe and clean. These include robust pre-job risk planning and analysis so that contaminants are identified and actions taken to eliminate or mitigate exposure prior to task execution, explains Lomax. They also include implementing preventive maintenance and applying diagnostic strategies on equipment, as well as enrolling employees in medical surveillance to assess them for early signs of exposure or adverse health effects and implementing steps to reduce or eliminate further exposure.
Beacon Occupational Health and Safety Services
Beacon Occupational Health and Safety Services
On the North Slope, EHS-Alaska’s industrial hygienists have completed worker exposure studies about welding fumes, including hexavalent chromium; exhaust adequacy studies; indoor air quality assessments; and fungal ecology assessments, Schwan says.
“Some relatively unique industrial hygiene issues inherent within oil and gas include benzene and hydrogen sulfide inhalation exposure,” Lomax says.
Other issues include oxygen-deficient atmospheres that are either planned (due to intentional purging such as nitrogen) or unplanned (due to unintentional displacement of oxygen levels from other gasses), as well as naturally occurring radioactive material associated with contaminated downhole tubing, Lomax says. In Alaska, any drilling waste that contains naturally-occurring radiological material must either be shipped out of state for proper disposal or be re-injected into an EPA permitted Class 1 injection well, according to the Alaska Division of Environmental Health.
Not all of the issues mitigated by industrial hygienists in oil and gas are endemic to the industry. Some of the prominent issues faced include hazardous noise levels, awkward or static body positioning, whole-body vibrations, airborne crystalline silica exposures from drilling fluid products, airborne asbestos exposure, welding fumes, and gasses related to inhalation exposures, as well as hydrocarbon exposures, including benzene and oil mists.
The most effective approach for dealing with a health hazard is eliminating it completely. In some circumstances, this can be as simple as postponing work until weather conditions improve, Lomax says.
When it is not possible to eliminate a hazard, companies will often look to a substitute.
“Can the health hazard be substituted with something less toxic? For example, can a less toxic and more environmentally friendly cleaning compound be alternatively used instead of a harsher cleaning compound?” Lomax says.
The next option, according to Lomax, is to consider engineering a solution. This can be done by creating a situation that removes the human-hazard interface, such as building a sound-proof enclosure to protect employees from hazardous noise work environments.
Another method of dealing with workplace hazards is through administrative efforts. In these cases, additional training, signage, and written procedures are used.
The last resort is to rely on personal protective equipment, such as earplugs, respirators, and anti-vibration gloves, Lomax says.
“The weather climate on the North Slope impacts industrial hygiene exposures in a variety of ways,” Lomax says. “For much of the time, winds are substantial and can be very beneficial in providing natural dilution ventilation capable of reducing airborne inhalation exposures for a variety of vapors, gasses, and aerosols. However, extreme cold Arctic temperatures have the potential to introduce cold stress health-related issues for workers and even death due to the remote North Slope work environment.”
Beacon Occupational Health and Safety Services
“Welding hooches must be built in order to provide a hospitable environment for welding or other work,” Lomax says. “The downside is that these enclosures have the potential to reduce the benefits of natural ventilation for the same work performed in less extreme environments.”
Other climatic issues faced on the North Slope affect the modular design of employee camps, Schwan says, noting that such issues would be handled by a certified safety professional.
“Industrial hygienists are quite different than certified safety professionals—industrial hygienists deal with worker exposures and certified safety professionals deal with workers’ environment. Although there is some obvious overlap, as an industrial hygienist who has some experience on the slope, I focus on worker exposures to chemicals, welding fumes, and mold.”
However, Schwan points out that his experience with modular designs suggests “that there are concerns about poor [or perceived poor] indoor air quality.”
“Modular design of man camps provides many avenues for outdoor temperatures to be conveyed into the indoor environment which can promote poor indoor air,” Schwan says.
Plans for the BP workforce “will develop as we determine how we will integrate the acquisition into Hilcorp’s existing operations,” Justin Furnace, a vice president for Hilcorp Energy, told The Associated Press.
In October, Furnace made it clear that employee safety would remain a top priority for Hilcorp, the largest privately held independent oil and gas exploration and production company in the United States.
“The safety of employees is the most important priority for Hilcorp. That responsibility rests on the company and each and every employee. As a result of this company-wide focus, Hilcorp’s OSHA recordable incident rate is significantly under that of other operators in the state. In order to achieve a safe work environment despite the many challenges faced operating in Alaska, Hilcorp continually trains our workforce using well-established industry and OSHA protocols and monitors operations around the clock,” Furnace said.
“Much of our workforce complete complex projects in conditions that involve extreme cold weather, noise, heavy machinery, travel, or the handling of chemicals. Every task requires careful consideration and training to ensure personal safety. Whether employees are veterans of oil fields, straight out of school, or transitioning from another industry, educating and training our workforce is a continuous and critical component. Many types of surveys and tests are conducted regularly. The information gathered helps to continue to get better and safer. If we can’t do a project safely and responsibly, we will not undertake that project.”
The frequency of industrial hygiene audits depends on internal standards and needs established by a company, though they are often conducted annually.
“Industrial hygiene audits encompass the evaluation of chemical and physical exposures, the interaction of the worker with the facility/machinery/equipment, and the effects of the workplace on the external environment,” Lomax says.
Included in an audit is an employee exposure assessment. According to OSHA, such assessments are designed to “characterize the nature and magnitude of employee exposures to respiratory hazards before selecting respiratory protection equipment.”
“If I am involved in a worker exposure study, I will read the appropriate OSHA standard and develop the steps necessary to comply with the standard, develop a scope with the client, gather background information on the process to include any written programs developed by the company, verify the number of workers to be included in the study, review past studies, and I will sometimes contact AKOSH [Alaska Occupational Safety and Health] directly to discuss with them the project and how best to comply,” Schwan says.
Employee exposure assessments can also be performed using the AIHA Exposure Assessment Strategy, Lomax says.
The five-step AIHA exposure assessment strategy represents a movement away from the traditional compliance assessment strategy toward a comprehensive exposure strategy that determines whether exposures are obviously acceptable, obviously unacceptable, or if there is insufficient information to make such a determination, Lomax says.
“The benefit is that information about the full exposure distribution is developed instead of just the upper extreme exposures and that exposure monitoring efforts can be focused where it is most needed [for example, the uncertain exposures]. This strategy promises to provide quality information with a minimum number of samples,” Lomax says.
By identifying exposure risks in the workplace, industrial hygienists can work alongside certified safety professionals to eliminate and mitigate hazards that are inherent in the oil and gas industry.
“My goal as an industrial hygienist is to keep workers, their families, and the community healthy and safe,” Lomax says. “I am proud to work within the oil and gas industry, which shares similar values and puts its money where its mouth is toward supporting the achievement of those goals.”