Paula Kaufmann, CIH

As part of their investigative report, NPR discovered that there were situations at the mine when the methane gas monitors on continuous mining machines were disabled because the monitors repeatedly shut down the machines.  The miners interviewed explained that supervisors told them it was acceptable to disable these monitors as long as the miner operating the equipment used a hand-held methane monitor to test the air.  This is the part of the report that stopped me in my tracks!!!

The methane gas monitors are an essential part of the mining machine’s fail-safe system. They are factory-installed and essential components of the machine design; when the monitor senses an explosive atmosphere, the mining machine shuts down automatically.  The ONLY reason that spark-generating equipment can be operated in an environment likely to contain explosive concentrations of methane gas is precisely because the equipment is designed to automatically shut down if an explosive atmosphere is encountered. 

The procedures followed at the mine undermined (no pun intended) a fundamental safety feature of the continuous mining machine. 

The problem with using a hand-held monitor as a substitute for the interlock monitor is that the miner operating a continuous mining machine is 25 to 30 feet behind the face of a machine that is a continuous source of ignition (lots of sparks from metal cutting coal and rocks).  The monitor must be located directly at the source of the spark.  The miner isn’t at the source.

How could the mine leadership eliminate a critical risk management feature?  When deciding to override a critical safety system, the mine leadership should have considered the potential for loss of life AND damage to the mine AND damage to operating equipment.  You have to wonder if anyone really thought about “what if?” especially as Upper Big Branch was a notoriously “gassy” (methane producing) and, therefore, dangerous mine.  I wonder if any hazard or risk analyses were ever conducted for operating the mining machine without an operational methane monitor.   For clarity – here is a brief explanation about the hazards and risks of overriding a safety critical system and the outcome of their analyses:

What’s the difference between hazard and risk?

• A hazard is the source of potential damage, harm or adverse health effects on something or someone (i.e., explosive concentration level of methane gas, source of ignition).
• A risk is the chance or probability that damage, harm or adverse health effect will occur if something or someone is exposed to a hazard (i.e., a chance of the methane gas concentration would reach explosive levels in the presence of a source of ignition).

 A risk assessment is the process where one

• Identifies hazards,
• Evaluates the risk associated with that hazard, and
• Determines appropriate ways to eliminate or control the hazard.
• Safety controls minimize the risk by “controlling” the hazard (i.e., shutting down the mining machine eliminates the source of ignition)

Managers must understand the risk and the systems that put in place to control the hazard.  This is “managing the risk”. 

At the Upper Big Branch mine, the life-saving interlock system in a known high risk environment was disabled while workers were assured that an inappropriately-located substitute would be effective and work continued without interruption. It appears that appropriate risk management was not the goal since the presence of combustible concentrations of methane gas at sources of ignition might not be detected using the hand held monitors.   

The integrity of an organization depends on a leadership commitment to understanding and managing risk to protect their employees and assets as well as their reputation. This NPR report highlights what can happen when leadership is focused on one measure of success, in this case, production. Another recent example of compromised risk in exchange for uninterrupted production is the BP oil leak. Have you ever encountered myopic leadership in your workplace that trades risk management for another benefit. What happened? How do employees feel?

The U.S. Chemical Safety Board (CSB) recently approved recommendations to the Occupational Safety and Health Administration (OSHA), the National Fire Protection Association (NFPA) and other organizations to help prevent explosions and fires during pipe cleaning and purging operations.  As recently as February 7, 2010 at the Kleen Energy power plant in Middletown, CT, an explosion caused six fatalities and numerous injuries during the cleaning of a natural gas pipe system. Another similar explosion occurred at the ConAgra Foods Slim Jim plant in Garner, NC on June 9, 2009 and caused the death of four workers. In both instances, an operation termed “natural gas blow” was utilized to force natural gas under pressure through a piping system during construction and prior to startup of the plant’s turbines to rid the pipe system of non-natural gas impurities and debris. The gas was vented to the ambient atmosphere at open pipe ends less than 20 feet from the ground, and in worker areas where the gas easily found a source of ignition.  It seems that common sense would lead one to never vent natural gas near sources of ignition.

• At Kleen Energy the potential ignition sources included electrical power to the building, welders actively working and diesel-fueled heaters running in the vicinity.
• Approximately TWO MILLION cubic feet of natural gas were released at Kleen Energy on February 7, 2010 during the “natural gas blow”, enough natural gas, according to the CSB, to provide heating and cooking fuel to the average American home every day for more than 25 years.

The CSB determined that no specific federal workplace safety standard exists that would prohibit the intentional release of natural gas into the workplace. Yes, I was shocked when I read that, too! Eighteen urgent recommendations were provided and voted on by the CSB to prevent future disasters. Some of the recommendations include – Prohibiting the use of natural gas for pipe cleaning and using alternatives such as compressed air, steam and other chemical substitutes, and upgrading the current gas safety standards for general industry and construction that are considered by the CSB to contain “significant gaps” that threaten the safety of workers at such facilities.

In February 2010, the CSB issued a safety bulletin titled “Seven Key Lessons to Prevent Worker Deaths During Hot Work In and Around Tanks”.  This bulletin highlights another gap in the OSHA standards, “While the OSHA standard prohibits hot work in an explosive atmosphere, it does not explicitly require the use of a combustible gas detector”. 

It is an unfortunate fact that such regulatory “gaps” can be found in many industries. We are reminded of these gaps while reading of disasters such as these, or more currently, watching the daily updates of oil washing ashore in the Gulf of Mexico.  It is certainly welcome news that these CSB draft recommendations were quickly approved without amendments to help prevent future explosions during pipe cleaning operations.

Do you know of other examples of what would seem to be ‘common sense’ safety measures that are not utilized because “this is the way we have always done it” wins over common sense?

October is Fire Safety Month. We’ll see the billboards and commercials and kids will learn about fire in school, but what does it mean?

It’s time to replace the batteries in your smoke detectors and don’t forget the carbon monoxide detectors, there should be one near all bedrooms. Check your fire extinguishers. Is the charge still good? What’s the expiration date? If you have kids, do they know what to do in case of fire?

The numbers speak pretty loud. According to the National Fire Protection Association there were over 1,451,500 fires reported in the U.S. in 2008 that took 3,320 civilian lives and injured 16,705 others. The cost in property damage was $15.5 billion. Fire kills more Americans than all natural disasters combined.

As with many tragedies, much of this loss could have been prevented. Planning and preparedness is critical, at home as well as at work. Fire rarely gives you a second chance. A small flame can quickly get out of control. Fast, proper, action can save lives and property. Improper action, like using the wrong type of extinguisher, can turn a bad situation into a catastrophe. Would you know what to do? At work, are you familiar with the fire and emergency action plans? If there are fire extinguishers have employees been trained in their use? The law requires both.

In a fire, it’s often the smoke that kills. It can quickly disorient and trap occupants. Many fall victim to smoke inhalation and carbon monoxide poisoning. The gasses given off by many household materials when burning can be highly toxic. Staying low to the floor may help you escape. When you’re out, stay out. Too many have died going back to retrieve some keepsake. Take the time to learn what to do and practice fire prevention. It’s time well spent.

1. Approximately 75% of fire related deaths are due to smoke inhalation rather than burns or other injuries.

2. Arson is the leading cause of non-residential structure fires in the United States, followed by electrical distribution systems.

3. Good housekeeping and proper storage of flammables and combustibles are important but often overlooked aspects of fire prevention and safety.

• Waste should not be allowed to accumulate. Combustible or flammable wastes should be removed daily.
• Keep electrical panels, heating devices, and other electrical equipment clear of waste and clutter, especially combustibles and flammables.
• Flammable and combustible liquids should be kept in approved containers. Large quantities of flammable and/or combustible liquids should be kept in approved flammables cabinets.
• Flammable gas cylinders should be stored in a well protected, well ventilated area away from sources of heat or ignition. Cylinders should be properly secured with valve cap protection in place.
• Oxygen cylinders should be stored separately from all flammables.

4. Workplaces must be equipped with an emergency alarm system that alerts employees to fires and other emergencies. The alarm should provide sufficient time for employees to safely evacuate the workplace or area.

5. Emergency alarm systems, fire prevention systems, and fire extinguishing equipment require regular maintenance and testing to verify that they are functioning properly.

6. Emergency evacuation routes and exits must be properly marked and adequately lighted to allow employees to safely evacuate.

7. Emergency evacuation routes and exits must remain clear of obstructions and obstacles at all times.

8. Emergency exit doors must remain unlocked in the direction of exit and should be free of locks or devices that require tools or special knowledge to operate them.

9. Fire extinguishing equipment, including portable fire extinguishers, should only be used by properly trained personnel. Employees required to use fire extinguishing equipment must receive training on an annual basis.

10. Fire prevention and safety are addressed in a number of OSHA regulations, including but not limited to 1910.39 Fire Prevention Plans; 1910.106 Flammable and Combustible Liquids; and 1910 Subpart L Fire Protection.

I recently read an article titled “Implementing Safety during Design: a Case Study” in the March 2009 edition of AIHA publication, The Synergist. The authors discuss how incorporating safety systems or measures in the design phase of a construction project can result in large cost savings for the overall project budget. Studies have shown that implementing safety during the planning phases of a project, compared with after construction costs, have a 1:10,000 ratio. This equates to $1 pre-construction costs versus $10,000 post-construction abatement. The authors focus on safety concerns following the guidelines established by The Institute for Safety through Design (established in 1995 by the National Safety Council’s Business and Industry Division).

As an industrial hygienist, I have often been frustrated when working on remedies for minimizing exposure to chemicals, immediate safety concerns, chemical storage and waste handling concerns after the occupancy of new laboratory facilities. Construction design planners rely heavily on architects that create beautiful layouts, but often fail to incorporate the fire safety, hazardous material handling and life safety issues that are detailed in NFPA 45: Standard on Fire Protection for Laboratories Using Chemicals and NFPA 101: Life Safety Code®. The design planners and architects frequently look to the local fire department or permit authorities to approve the plans. These groups may be well versed in commercial building codes, but often are not experts in the potential hazards present in a laboratory operation. The costs of retrofitting a new facility to meet NFPA guidelines and OSHA standards can be staggering. The “take away” is to get an EHS professional involved in the upstream design process. Often cost of another “expert” is discouraged by the planners. Then again, studies (and our experiences) have shown that not getting the right experts at the planning table can be “penny wise but pound foolish”.

A friend recently told me that he might be developing an allergy to his office. We laughed about being allergic to work, but since he knows that I am in an industrial hygienist, he was serious about getting my opinion. He asked my thoughts about the source of his allergy. I suggested that he should see if anything new was introduced to his workspace over the winter.

It turns out that his cubicle was located by a wall covered with mold and mildew. This growth had also moved onto his paper files, cubicle and desk surfaces. His employer cleaned up the area and requested laboratory testing of the mold. He doesn’t know the extent of the remediation, but he still is not feeling well.

At the request of his doctor, my friend asked his management for copies of the records of the remediation including what type of mold was found. Management’s reply was that the information was included in company records and could not be released. He asked me if he should insist that his employer provide him with the type of mold that was present – he didn’t realize that he had a legal right to this information under the Occupational Safety and Health Act (OSHA).

Mold Growth

At the request of an employee, an employer is required by OSHA to provide the employee with “Environmental (workplace) monitoring or measuring of a toxic substance or harmful physical agent, including personal, area, grab, wipe, or other form of sampling, as well as related collection and analytical methodologies, calculations, and other background data relevant to interpretation of the results obtained …;” Employers must inform employees of the existence, location and availability of your medical and exposure records when you first begin employment and at least annually thereafter. Employers also must provide these records to an employee or their designated representatives within 15 working days of an employee’s request.

Faced with similar situations, it might be assumed that many people would not know the correct actions to take. To be precise, an employee should make a written request for all information related to the collection and analytical methodologies, calculations, and other background data relevant to interpretation of the results and conclusions from any environmental monitoring or measurements. In this letter to the employer, the employee should state — As required by the US Occupational Safety and Health Administration Standard “Access to employee exposure and medical records. – 1910.1020 “ in section 1910.20(e)(3)(ii ), I anticipate that these records will be available to me for examination and photocopying within 15 working days of this formal request”.

Here is a good summary of the standard

Here is an outline of employee’s rights under OSHA

Many people don’t realize that OSHA requires annual fire safety training.  This includes mandatory, hands-on training for all company employees that may have to use a portable fire extinguisher.  Failure to comply with these standards can subject employers to heavy fines. Many company owners and executives are surprised to learn about these requirements when it is already too late.

As an employee, be aware; employers who believe that such things as a “DO NOT TOUCH” sign above a fire extinguisher will satisfy an OSHA inspection.  It won’t.  Also, if one employee states they either used or would use the extinguisher during a fire (without proper training), that company would be subject to these fines.

In the long run, these companies learn a harsh lesson and realize that it would have been cheaper to train their employees. But most importantly, a properly trained employee may prevent millions of dollars in damage and even save lives.

The BullEx “Bulls Eye” digital extinguisher system makes this training extremely easy and cost effective compared to traditional, live fire exercises. There is no need for a live burn with its associated dangers, liabilities and permit requirements. It can even be used indoors and near hazardous locations. This technology allows employers to satisfy the OSHA standards while taking away the danger of a real fire.

These types of trainings used to take a large amount of time and careful planning.  With the “Bulls Eye” system fire training is easy.  BullEx can literally train hundreds of people a day with the capability of its digital technology.

The system uses a LED display to create the impression of a real fire.  Also, it is accurate enough to detect if the training is being performed correctly by responding to the trainee’s actions.  The “fire” will only go out if the extinguisher is used properly.  The system also had the capabilities of generating higher levels of flame and re-ignition scenarios.

“BullEx fire extinguisher training systems make annual OSHA extinguisher training clean, safe and easy. Through patented technology, BullEx systems can actually sense where the trainee aims and sweeps the training extinguisher and automatically varies the flames in response. BullEx training extinguishers utilize either compressed air and water, or a conical laser pattern to simulate the discharge of an actual extinguisher without the cost and mess.” (www.bullexsafety.com)

This type of training goes beyond a lecture or a video.  It provides hands on training that satisfies the OSHA requirements for fire safety.  Also, with the only mess coming from the discharged amount of water you use, cleaning up is effortless. While training outside is preferable, employees can use the system indoors with an adequate drainage system.

The benefit of proper fire safety training not only helps a company maintain compliance, it also helps its employees learn valuable lessons as well.  Many training sessions have led its attendees to feel more confident about fire safety in the work place as well as in their own homes.

Visit the following links for more information on the BullEx system and to find organizations that give trainings on fire safety.

www.bullexsafety.com

Training for BullEx