Abstract

An increasing number of regulations address the control of hazardous materials and the protection of the environment. In order to protect the health and safety of employees working with hazardous materials, the Occupational Safety and Health Administration (OSHA) has issued standards on communicating the hazards of chemicals in the workplace. This law is known as the Hazard Communication Standard (HAZCOM) or employee "Right-to-Know." In addition, OSHA and the Environmental Protection Agency (EPA) have collaborated to issue standards to protect employees during emergency response to chemical spills and hazardous waste cleanup operations. These standards are known as Hazardous Waste Operations and Emergency Response (HAZWOPER).

In order to meet these standards, businesses must develop programs to communicate to employees hazards in the workplace, how to protect themselves from these hazards, and how to react in emergency situations. These programs can be developed in house or contracted through training consultants, or both. This paper reviews the HAZCOM and HAZWOPER regulations and describes their application to the oil and gas industry. This customized communication and training program which meets the requirements of OSHA and EPA describes incident prevention, emergency response, and crisis management.

Introduction

Over the last five years OSHA, EPA, and the Department Of Transportation (DOT) have introduced a number of new regulations which have drastically changed the way industry trains its personnel. The origin of these regulations can be traced back to one or more catastrophic events which forever changed the way industry views its relationship with government, its employees, contractors, and the general public. The disaster that started it all took place in Bopahl, India, where more than 2000 people were killed as a result of a gas release from a Union Carbide plant. The after shock of this unfortunate event spawned a number of new regulations and expanded existing regulations. In turn, industry members have had to cope with increasing demand to train employees to prevent catastrophic events and to properly handle emergency response situations if an accident does occur.

To meet this training demand, regulations should be evaluated as to whether training is required. Next, each company or industry must determine if these training requirements pertain to its operations. Once this is determined, an overall program must be designed that will meet our employee training objectives and be accepted by contractors, customers, government agencies, and the general public.

In light of the multiple training requirements currently in effect, the safety or training manager must concentrate on these major areas:

Prevention - The ultimate goal of any effective program is prevention. The purpose of prevention is to identify hazards in order and to minimize accidents and to identify, evaluate, and control the events that lead to these undesirable situations.

Emergency Response Preparedness - Once the company has made a risk assessment and the types of materials, processes, events that could produce a release and the potential effects of a release are identified, the next phase of emergency response can begin — preparedness.

Crisis Management - Finally, if an event does occur, employees and management must effectively handle the crisis. In the event of a crisis, media representatives may contact plant and field operations personnel, as well as safety personnel and supervisors. This can happen long before the appointed crisis management team can arrive. In this case, the training of these personnel is critical to improve the ability of key operations and plant personnel to respond to media reporters, government officials, and the general public.

STATEMENT OF THE PROBLEM

For most of us, the problem is simple: provide employees with the very best training and at the same time satisfy the various government agencies and customers who dictate that the training take place.

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