1. Accepted Practices for Hydrogen Sulfide (H 2 S) Safety Training Status of the ANSI Z390.1 And Impact on the Oil, Gas, and Petrochemical Industry

2. What Is Hydrogen Sulfide?   Toxic substance – normal state is gas   Disagreeable odor similar to rotten eggs   Kills sense of smell at higher concentrations (IDLH 100 ppm)   Concentrations above 500 ppm will render you unconscious almost immediately

3.   Concentrations about 1000 ppm will kill with a single breath   H 2 S is about 20% heavier than air   The gas is flammable

4. Historically Hydrogen Sulfide Training: Was deficient in content and conduct; Length varied from one course to another; Importance of the technical aspects was lost in the instruction; And annual recertification certificates could be purchased without training

5. History of Standard Development   Course curriculum developed mid- 1980s followed by instructor training course   ANSI ASC chartered October 5, 1992   Z390.1 approved 1995   Z390.1 reaffirmed 2001   Z390.1 was revised in 2006 (6/7/2006)

6. Scope of the Revised Z390.1 This standard sets forth accepted practices for hydrogen sulfide (H 2 S) safety training and instruction of affected personnel. This standard sets forth accepted practices for hydrogen sulfide (H 2 S) safety training and instruction of affected personnel. The purpose of this standard is to establish minimum requirements for site- specific H 2 S safety training programs that will enhance safety in occupational settings where hydrogen sulfide is present, or is recognized as being potentially present, above the TLV-TWA. The purpose of this standard is to establish minimum requirements for site- specific H 2 S safety training programs that will enhance safety in occupational settings where hydrogen sulfide is present, or is recognized as being potentially present, above the TLV-TWA.

7. The “Guts” of Z390.1 Section 3 – Training Criteria Section 3 – Training Criteria Section 4 - Instructor Qualification & Proficiency Section 4 - Instructor Qualification & Proficiency Section 5 - Documentation and Recordkeeping Section 5 - Documentation and Recordkeeping

8. The “Guts” of Z390.1 (continued) Section 6, Student Competency and Qualification Section 6, Student Competency and Qualification Section 7, Training Techniques, Language and Literacy Factors Section 7, Training Techniques, Language and Literacy Factors Section 8, Protection Requirements for Visitors Section 8, Protection Requirements for Visitors

9. What Drove the Revision/Changes??? By procedure ANSI Standards must be reaffirmed, revised, or withdrawn every five years. By procedure ANSI Standards must be reaffirmed, revised, or withdrawn every five years. Technology and training methodologies have changed since the first version of the standard Technology and training methodologies have changed since the first version of the standard

10. Key Changes to Z390.1  Acute and Chronic exposure redefined  Boiling Point changed to Flash Point  Respiratory protection references changed from Z88.2-1991 to 29CFR 1910.134 as amended in 1998  Dispersion modeling section to be covered “if applicable”

11. Key Z390.1 Changes (continued)  Physiological effects of chronic exposure  “No course is ever to be abbreviated….” removed  Certification cards may be issued by the instructor  Computer-Based Training issue was addressed

12. ACGIH – Impact on Z390.1??? ACGIH Notice of Intended Change of TLV/TWA for H 2 S in 2004  TLV from 10 ppm to 1 ppm  STEL from 15 ppm to 5 ppm  NIC was published and ACGIH Board action was to be reported February 2008

13. The TLV / TWA Issue ACGIH proposing dramatically lower safe exposure limit for H 2 S - 10 PPM to 1 PPM ACGIH proposing dramatically lower safe exposure limit for H 2 S - 10 PPM to 1 PPM Likely to be adopted as law, at some point, by state and Federal agencies Likely to be adopted as law, at some point, by state and Federal agencies –OSHA –EPA –? Oil, gas, and petrochemical operations frequently result in Time Weighted Average exposures of 1-3 PPM to personnel in operational areas, instantaneous exposures is excess of 5-10 PPM are common Oil, gas, and petrochemical operations frequently result in Time Weighted Average exposures of 1-3 PPM to personnel in operational areas, instantaneous exposures is excess of 5-10 PPM are common Reducing worker exposure to 1 PPM technologically/economically difficult Reducing worker exposure to 1 PPM technologically/economically difficult –Almost continuous use of respiratory protection in operational areas; and /or –Vapor recovery equipped tanks, trucks, barges, railcars, loading/unloading racks, re-engineering the entire oil, gas and petrochem infrastructure!

14. TLV ® - Threshold Limit Value “An occupational exposure value recommended by ACGIH® to which it is believed nearly all workers can be exposed day after day for a working lifetime without ill effect.” “An occupational exposure value recommended by ACGIH® to which it is believed nearly all workers can be exposed day after day for a working lifetime without ill effect.” By itself, TLV ® simply indicates an exposure limit established by the ACGIH. By itself, TLV ® simply indicates an exposure limit established by the ACGIH. TLVs ® are frequently incorporated into law and cited in litigation TLVs ® are frequently incorporated into law and cited in litigation ACGIH position – don’t blame us were just scientists objectively reviewing research ACGIH position – don’t blame us were just scientists objectively reviewing research

15. ACGIH Statement of Position Regarding the TLVs ® and BEIs ®

16. The Problem A 1PPM TLV ® -TWA is likely to be imposed on industry through regulation or litigation A 1PPM TLV ® -TWA is likely to be imposed on industry through regulation or litigation Worker exposure in operational area of oil, gas, and petrochem facilities often have a TWA exposure of 1-3 PPM, with frequent instantaneous exposures of 5-10 PPM Worker exposure in operational area of oil, gas, and petrochem facilities often have a TWA exposure of 1-3 PPM, with frequent instantaneous exposures of 5-10 PPM Personal Protective Equipment or Engineering Controls only options to limit worker exposure Personal Protective Equipment or Engineering Controls only options to limit worker exposure Reducing exposure to 1 PPM or less does not appear to be technologically / economically feasible Reducing exposure to 1 PPM or less does not appear to be technologically / economically feasible

17. Atmospheric Monitoring Instruments designed for continuous monitoring are not particularly accurate Instruments designed for continuous monitoring are not particularly accurate –Electrolytic cells ± 15% –Semiconductor ± 5 PPM –Colorimetric tubes ± 25% Many instruments currently used are not data logging and cannot calculate TWA Many instruments currently used are not data logging and cannot calculate TWA

18. Respiratory Protection Air Purifying Respirators Acceptable between TLV/TWA - IDLH Acceptable between TLV/TWA - IDLH APRs potentially dangerous to use for H 2 S APRs potentially dangerous to use for H 2 S –unanticipated spikes above IDLH when performing certain work (gauging, unloading, etc.) –Poor warning characteristics of H 2 S can prevent detection of breakthrough APRs uncomfortable due to weight on head & high breathing resistance APRs uncomfortable due to weight on head & high breathing resistance APRs expensive over long term APRs expensive over long term –Approx. $10.00 / set of cartridges / person –1-2 sets used / day

19. Respiratory Protection Self Contained Breathing Apparatus Must be worn above IDLH Must be worn above IDLH May be worn above TLV May be worn above TLV Expensive Expensive Require a lot of support equipment Require a lot of support equipment Short use duration Short use duration Hoselines restricted to no more than 300 feet Hoselines restricted to no more than 300 feet Not user friendly Not user friendly –Heavy –Bulky –Restrict mobility

20. Engineering Controls Unlikely concentrations of H 2 S in oil, gas, and petrochem industry can be significantly reduced Unlikely concentrations of H 2 S in oil, gas, and petrochem industry can be significantly reduced –Chemical treatment? Vapor Recovery Vapor Recovery –Could reduce airborne concentrations of H 2 S –Extremely expensive

21. The Action Encourage the ACGIH not to adopt proposed TLV-TWA Encourage the ACGIH not to adopt proposed TLV-TWA –Research does not indicate harm from concentrations lower than 10 PPM –1 PPM is arbitrary concentration –Not technologically or economically feasible –No evidence lower TLV-TWA will make workers safer! If adopted If adopted –Closely monitor regulatory actions which might result in proposed TLV-TWA becoming law –Vigorously lobby against adoption of proposed TLV- TWA into law

22. The TLV Bad News ANSI Z-390 H 2 S Training Committee and API vigorously opposed change – ACGIH did not find their arguments compelling ANSI Z-390 H 2 S Training Committee and API vigorously opposed change – ACGIH did not find their arguments compelling Although not final, momentum is for adoption Although not final, momentum is for adoption ACGIH is also proposing lowering the TLV-TWA of SO 2 ACGIH is also proposing lowering the TLV-TWA of SO 2

23. Private-Public Sector Impact From Z390.1 The standard is not cited by reference. The standard is not cited by reference. The standard is recognized by a number of government agencies. The standard is recognized by a number of government agencies. The standard is cited in numerous private sector contracts and work agreements. The standard is cited in numerous private sector contracts and work agreements. The standard has been used in the past for vendor certification/accreditation claims. The standard has been used in the past for vendor certification/accreditation claims.

24. CONCLUSION   Revised standard is more user- friendly   Stresses prevention of dangerous work practices in hazardous atmospheres caused by mediocre or deficient training

25. Training Issues… Continue to train to the standard Continue to train to the standard Continue to develop competent instructors Continue to develop competent instructors Redeveloped / standardized instructor training materials Redeveloped / standardized instructor training materials H 2 S Master Trainer Course with CSHI H 2 S Master Trainer Course with CSHI

26. Thank you! Thank you! Any Questions? Any Questions?