Known as “The Silent Killer,” Hydrogen Sulfide (H2S) is one of the leading causes of workplace gas inhalation deaths in the United States. This extremely flammable toxic gas is colorless and odorless if the concentration is high enough. For these and many other reasons, it is imperative that anyone with the potential for exposure to H2S is sufficiently trained to recognize and understand the hazards associated with this gas. The entire purpose of the ANSI/ASSE Z390.1 – 2017 standard is to establish minimum requirements for H2S safety training programs and set minimum requirements for the instructors providing the training.
Many revisions have been made to the ANSI/ASSE Z390.1 standard. From instructor qualifications to course content, some notable changes include:
• H2S training course must be a minimum 3 – 4 hours in length
• There is now only one level of training, H2S Certified
• H2S certification is only valid for one year (annual certification refresher needed)
• H2S training course must be instructor-led as computer-based training (CBT) no longer meets the standard
• The H2S instructor’s train the trainer must meet new minimum requirements
More detailed and larger curriculum that must be covered in the H2S training course
This year’s revisions to the standard are a culmination of studying the industries affected by H2S, accepted practices and the never-ending quest to save lives.
In the mid-1980s, a study of the training courses conducted revealed that the required H2S certificate could be obtained upon completion of a class which ranged from 15 minutes to 4 hours. In that study, the length of the course seemed to depend on the experience and professional integrity of the instructor, as well as the particular course curriculum. They also found that not only did the course content radically vary from one organization to another, but it was even possible to purchase a certificate without actually attending the training (providing you were willing and able to pay the asking price)! As a result of their findings, one early goal of these safety pioneers was to establish an exemplary process to thoroughly prepare the instructors that were conducting this critical training. A course curriculum was developed in the mid-1980s and was soon followed by an instructor training course.
The ANSI Z390.1 standard was approved in 1995 and then reaffirmed in 2001. In 2006, the standard was revised, but even with those standards in place, we still had classes ranging from 15 minutes to up to 4 hours and reported H2S poisoning fatalities in several different industries every year. These continued discrepancies and workplace accidents established a demand for this year’s Z390.1 standard revisions.
The ANSI Z390.1 committee took the rewrite of this standard very seriously. There was a need for a stronger standard to hopefully prevent all H2S fatalities. For this reason, the standard addresses the individual training criteria that should be incorporated into a comprehensive training course. These criteria were developed by combining accepted practices in numerous affected industries. Most significantly, emphasis has been given to the qualifications and proficiency of individual H2S safety instructors, as well as student performance-based competency and qualifications.
The guidelines presented in this standard are designed to provide workers the fundamental knowledge to protect themselves from H2S exposure. This standard does not include the information necessary to satisfy the requirements of the ANSI Z88.2 Practices For Respiratory Protection and OSHA Respiratory Protection 29CFR 1910.134. In addition, this standard does not provide the site-specific information necessary to work at a particular facility.
Governmental regulations (see OSHA Hazard Communication 29 CFR 1910.1200) specify mandatory requirements for the training of personnel working with or around hazardous chemicals. As a voluntary consensus standard, this document complements those regulations. However, compliance with this standard does not assure compliance with governmental regulations, and vice versa.
ANSI/ASSE Z390.1 – 2017: What’s Changed?
The ANSI/ASSE Z390.1 – 2017 standard moved from a “proscriptive” to a “performance” based standard. The standard was organized to simplify reading and establish more definitive subjects to present in the training curriculum, which went from four topics to thirteen topics.
The committee moved from three levels of training (Orientation, Occasional, H2S Certified) to one—simply, H2S Certified.
Definitions added and removed in Section 2 are as follows:
Definitions that were removed:
• 2.2 Acute Toxicity
• 2.6 Equivalent
• 2.7 Instructor/Administrator – Removed Administrator from the definition
Definitions that were added:
• 2.13 Occupational Exposure Limit (OEL) The committee felt that employers and facilities where personnel may encounter H2S should make their own assessments to determine appropriate safe exposure levels based on the advice of safety professionals, local laws, PELs, TLVs®, RELs, WEELs, etc. The requirement for training is no longer triggered by a universal threshold (i.e., the TLV®) that applies in all work environments and all situations.
• 2.15 Visitors are not exempt from the initial and annual H2S training. The committee felt that anyone that could be potentially exposed to H2S should complete the entire H2S training course annually.
• 2.16 Immediately Dangerous to Life and Health (IDLH)
• 2.18 Designated Rescuer
Changes that were made to Section 3 Training Criteria for H2S Certification are as follows:
• 3.1 H2S Certification – This certification training should be a minimum of 3 – 4 hours in length. The committee felt that this would establish a definitive amount of time required to cover the required material.
• 3.1 H2S Certification – The certification is valid for a period of 1 year.
• 3.1 H2S Certification – The training must be documented and an H2S Certification card stating ANSI Z390 compliant must be presented to the attendee.
• 3.1 H2S Certification – Retraining shall include all the information contained in 3.2. The committee felt strongly that all retraining of personnel would include the complete 3 – 4 hour course to ensure personnel maintain and update their knowledge and safe work practices required to work safely on-site where the potential of H2S exists.
• 3.3 – Minimum Course Content for H2S Train the Trainer – Course content must include sufficient instruction to assure competency, with regard to the topics required in the H2S certification.
• 3.3 – Minimum Course Content for H2S Train the Trainer – Additionally the student must receive adequate instruction on the following topics from Criteria For Accepted Practices in Safety Health and Environmental Training (Z490.1) The committee wanted to ensure that a connection to the training structure and the ANSI/ASSE Z490.1-2017 Standard, which establishes criteria for safety, health and environmental training programs, including program management, development, delivery, evaluation, and documentation.
• 3.4 – Minimum Requirements for Site-Specific Orientation – The committee defined a “site-specific orientation” for H2S in new §3.4 that doesn’t require a certification, but escape indoctrination. This orientation does not take the place of the required certification training. (See Appendix D: Site-Specific Training for Working above the Occupational Exposure Limit of H2S). Appendix D includes the minimum requirements that personnel shall be briefed on and documentation required to do work on a site that has the potential for H2S exposure.
• 4.4.7 – Hierarchy of Hazard Controls – The committee added the hierarchy of hazard controls. The student shall be informed of the hierarchy of controls. This is intended to provide the student with an overview of a systematic approach to eliminating hazards and reduce or control H2S risks. Each step is considered less effective than the one before it, so combining several steps increases the success of reducing the H2S risks to a level that is as low as reasonably practicable.
• Added Appendix D: Site-Specific Training for Working above the Occupational Exposure Limit of H2S
• Added Appendix E: Site-Specific Training for H2S in Laboratories and Enclosed Work Areas
If there is an internationally-recognized standard led by the United States for H2S training, why consider something less for your employees? This standard was developed by industry experts and professionals for the benefit of the worker—to save lives.