Hydrogen Sulfide Training Standard Revisions
This article is written for those readers with some knowledge of ANSI/ASSE Z390.1-2006 (R2010) whether as having read it or received training to be an Instructor through an approved Train the Trainer course.
On June 30, 2017, ANSI Board of Standards Review approved ANSI/ASSE Z390.1-2017 Accepted Practices for Hydrogen Sulfide (H2S) Training Programs. This newly approved standard includes revisions to ANSI/ASSE Z390.1-2006 (R2010).
There were many significant changes, additions, clarifications, and revisions to the 2017 version. If a section or Appendix is not listed then there were no significant changes to that section or appendix.
A paragraph was added indicating the revised standard is designed to provide workers with basic knowledge to protect themselves from H2S though there is not enough information provided to satisfy the ANSI Z88.2 standard nor the OSHA 1910.134 Respiratory Protection standard. This means more information is needed to be provided by the individual Instructor to the student specifically to satisfy the requirements of the ANSI Z88.2 standard on respiratory protection as well as the OSHA regulation on respiratory protection.
Scope, Purpose, and Application
The Scope was changed to refer to a more generic term, the “occupational exposure limit”, when identifying the exposure limit instead of using the ACGIH TLV to the specify the exposure limit. This allows the “employer or facility” to determine the “occupational exposure limit” based upon “…consensus standards, regulations, and health, safety, and environmental (HSE) professionals”.
The committee removed the definition for acute toxicity. It added the terms of and definitions for Designated Rescuer, Immediately Dangerous to Health and Safety (IDLH), and Occupational Exposure Limit. The term Administrator was removed when referring to an Instructor with the definition slightly revised to state the Instructor “…possess significant experience…” in H2S instruction removing the option of “…receiving equivalent instruction from a company-designated Instructor/Trainer…”. In the definition of Visitor, the wording was added that “Visitors are exempt from the initial and annual training…” requirements.
Section 3 – Training Criteria for Certification
This new section was added specifically listing the training criteria for Instructors including certification requirements, lists the minimum course content for worker training, for Train the Trainer courses, and for site-specific orientations. The criteria allows the Instructor to conduct a needs assessment to determine the specific information to be presented yet still required to meet the objectives of the standard. The length of class is specified in the standard as being a “…minimum of 3 to 4 hours in length.” The standard specifically requires that personnel that may work in an H2S environment using respiratory protection, specifically a tight-fitting supplied air respirator, comply with ANSI Z88 and/or OSHA 1910.134 for getting a medical evaluation and fit-testing.
The Train the Trainer course is required to cover topics from the ANSI/ASSE Z490.1 Criteria for Accepted Practices in Safety, Health, and Environmental Training including training program administration and management, development, delivery, and evaluation of training as well as documentation and recordkeeping.
In addition to the requirement for annual H2S training for certification, site-specific training is required for workers with a potential for exposure to H2S above the occupational exposure limit to include site-specific information on routes of egress, wind indicators, muster areas, warning signals, emergency response, PPE, and hands-on training using the specific H2S monitor to be used, prior to use, on the specific site.
Required Course Content
Beginning with Section 4, the use of the word “shall” is consistently used to show required content versus recommended information to be included in the training course. Section 4 lists topics and specific information that is to be covered at a minimum. Names were added to the list of Synonyms and wording that ‘…odor shall not to be used as the only warning for the presence of H2S.” was removed. There was specific language added about acids that may be added to equipment containing H2S may cause an immediate release of H2S. Information was added about the formation and reaction of iron oxide as a pyrophoric listing where this may be found in specific industries. In the list of variables affecting symptoms of exposure, the terms “smoker/non-smoker” were removed.
A section was added on the Hierarchy of Hazard Controls giving a basic overview of the systematic approach to eliminating and/or controlling hazards associated with H2S.
In the section listing general work procedures, it was added to provide qualified rescue personnel trained in first-aid/CPR, providing personnel with supplied air respirators when there is a potential for exposure above the IDLH for H2S, the use of the buddy system in areas above the IDLH, and removed the work procedure to “never take shortcuts”.
In the PPE section, it is added that PPE must be “… designed for protection from H2S exposure.”, and emphasizes respiratory protection to follow OSHA or ANSI standards. Statements are included about the location of muster areas will vary based upon the wind direction, and that medical evaluations and fit testing are required for respirator use.
The Contingency Plans section had added that contingency plans “…may be required…” though “…all facilities are required to have an emergency action plan.” In the section about burning, flaring, and venting, the statement of “…some industries…” may flare or vent and that there may be a presence of H2S more than 15 ppm was removed.
An updated the list of government agencies now include the Bureau of Safety and Environmental Enforcement (BSEE).
In the section about dispersion models, the paragraph was removed discussing additional information on dispersion models being computer-generated, the use for emergency planning, and the validity of data input into the modeling program.
In the section about rescue techniques, the wording was changed from “Student” to “Designated rescuers”, and wording was removed referencing hyperbaric oxygen therapy after exposure to H2S.
Wording was added discussing H2S detection methods that students are required to be “…informed of the three most common types of detection…” for H2S. It was added that detectors will be “…worn according to manufacturer’s recommendations…” and re-states the API 49 definition of breathing zone.
Again, the designation of “Administrator” was removed from being included with Instructors and added the requirement that Instructors are required to have an “assessment of competency”.
It was added in the section identifying the documentation required for each class that documentation shall include a “record of competency for each student”.
Certification cards are now required instead of just recommended. It was also changed that certification cards are not required to be signed by the Instructor nor is it required to list on the card the respiratory protection used during the class or the air monitoring device used during training. There is a requirement that wording on the card states the training conforms to ANSI/ASSE Z390.1.
Changes to the training techniques section include adding that certification training be delivered by a qualified instructor in an appropriate and safe location and according to ANSI/ASSE Z390.1, that the training be delivered in a language the student will understand, and removing the section on the use of Computer-based Training (CBT).
The section that discussed the site-specific policy for evacuation of visitors in case of an emergency was removed.
The list of related standards was changed to add API 68 with ANSI Z49.1 being removed.
The change to the audience characteristics was the removal of the word “gender” being removed from the list. The change to the training methods was from previously listing five different models from which to choose to list only Instructor-Led Training by removing from the list that of Booklets, Brochures, and Programmed Learning Texts, Video Training, Computer-based Training (CBT), and Interactive Multimedia. The list of presentation aides was updated to current technology.
On the sample course outline, the length of training was changed from 4 hours to be flexible at 3-4 hours, the course description had the words “safety awareness” removed and just listed as “training”, removed the video listed in the course outline, and added buddy system and artificial resuscitation/CPR to the topics.
The reference to OSHA 1910.252 was removed from the related publications list. The entire section listing the Dispersion Models references was not included in the new standard.
Information was added to assist in complying with the Section 3 requirement to comply with ANSI/ASSE Z490.1 Criteria for Accepted Practices in Safety, Health, and Environmental Training including a non-mandatory syllabus, a list of learning modules, instructional plan, and materials list.
There was specific non-mandatory information included providing assistance in developing a site-specific training curriculum based upon a needs assessment. (The needs assessment information can be found in ANSI/ASSE Z490.1 Criteria for Accepted Practices in Safety, Health, and Environmental Training.)
Non-mandatory general information for developing a site-specific training curriculum for laboratories associated with the use of H2S is included in this appendix.
The 2017 version of the standard should be released mid-September for publication by ANSI/ASSE.
For more information, contact Wayne Vanderhoof CSP at RJR Safety Inc at firstname.lastname@example.org.