Frank Perry, Chair of the Z390 Accredited Standards Committee (ASC), was instrumental in the revision of the Z390 standard, “Accepted Practices for Hydrogen Sulfide Safety Training Programs” (ANSI Z390.1-2006), which received ANSI approval in June 2006. In this interview, Perry describes the improvements made to the Z390 standard, the response it has received from those in safety training and his predictions for how the revised standard will impact hydrogen sulfide safety (H 2S) training programs throughout the United States.
The Chair of any ASC must often assume several roles during the development or revision of a standard. Frank Perry’s role as Chair of the Z390 standard “was to bring the revision/reaffirmation issue forward to the Secretariat in a timely manner” while also locating “as many original members as possible and then trying to accommodate those who wanted to join the committee.”
After the realignment of the committee, Perry became more of a “facilitator.” “I ensured that the committee considered all of the comments received from organizations and individuals in a fair and impartial manner,” he explains.
Thanks to the industrious efforts of Perry and the Z390 ASC, the revised Z390 standard is a significant improvement over the previous version. “We made a number of housekeeping revisions in this latest iteration of the standard, which ranged from correcting minor typos to updating outdated references,” says Perry. “ More substantive changes included redefinition of terms,” he continues. “For example, in the previous version of the standard, the difference between the terms ‘acute exposure’ and ‘chronic exposure’ left an unexplained period of time from ‘more than 24 hours’ until ‘more than three months.’ We decided to remove the references to specific periods of time and to use more generalized terms.”
One revision that Perry feels will have the greatest impact on the use of the Z390 standard is the redefinition of its application. “The committee originally established the application for ‘occupational settings where personnel have the potential to be exposed to H 2S in excess of the Threshold Limit Values (TLVs),’” he says. “In our present occupational settings, that TLV is ten parts per million (ppm) in an eight-hour workday. This year, the American Conference of Governmental Industrial Hygienists (ACGIH) published a proposed reduction of the TLV from ten ppm to one ppm. In an effort to maintain some measure of stability in the application of the Z390, the committee revised the application component of the standard to ‘the Threshold Limit Value (TLVs)…as established by the American Conference of Governmental Industrial Hygienists (ACGIH) in their 2005 publication titled Guide to Occupational Exposure Levels,’” he illustrates.
Each year, Perry works with approximately 150-200 H 2S-specific safety trainers. Since the revision and reaffirmation of the Z390 standard this summer, he has worked with about 40 of these safety trainers, and according to Perry, their response to the revisions “has been very favorable.”
Perry credits a more “user-friendly” standard that does not “dilute the core elements” for this positive response. “For example, a few topics in the original standard were cumbersome and awkward for most safety trainers to handle, specifically H 2S dispersion models and burning/flaring. The revised standard relaxes the emphasis on these two topics for occupational settings in which these were not primary issues,” he elaborates.
He hopes that the revised Z390 standard will help “affected occupations perk up their own H 2S training programs and make the learning process more thorough and more enjoyable for both the attendees and the instructors.”
Perry, a strong proponent of the Z390 standard since its inception, also feels that by using current tools and technology, there is no need for additional rules and regulations.
“We must insist on compliance with the traditional safe work practices that have been learned and improved upon over the decades—with no shortcuts,” he emphasizes. “When we use shortcuts, minimize or eliminate proper training or work without proper safe work practices and personal protective equipment, we experience accidents and losses,” Perry adds.
While the Z390 standard addresses hydrogen sulfide safety instructor qualifications, Perry has already seen an improvement in organizational hiring practices with respect to safety training professionals. “As I spend more time in the classrooms with instructor-candidates, I find that the companies are becoming more intent on finding the ‘right candidate’ to conduct their own in-house training programs. Credentialing of those individuals has increased in importance as well,” he notes.
The revised Z390 standard will not only assist organizations in their hiring practices, it will also offer them guidelines for preventing potential exposures to hydrogen sulfide. Perry indicates that the standard provides several sections on safe work procedures and practices, personal protective equipment and personal detectors.
He does not anticipate any difficulties in ensuring that state and federal government agencies recognize the revised Z390 standard. In fact, as an adjunct instructor for Texas A&M University’s Engineering Extension Service, he has seen more Department of Labor (DOL)/Occupational Safety and Health Administration (OSHA) compliance officers, individual state OSHA personnel and Bureau of Land Management (BLM) trainers enroll in his course, “Hydrogen Sulfide Instructor Development.” “It adds such a wonderful dimension to the training environment, and it gives us the opportunity to train those regulators in the aspects of the Z390 standard,” he says.
In addition, Perry explains that the revised standard should interact well with federal and state regulations because “it was designed to complement existing safety training programs and traditional federal and state regulations such as the Hazard Communications Standard (29 CFR 1910.1200) and the Process Safety Management Standard (29CFR 1910.119).” He adds, “It also complements individual state-specific regulations such as the Texas State Rule 36, New Mexico Rule 118, Oklahoma Rule 3-203.2 and many others.”
To make the most of the revised Z390 standard, Perry recommends that organizations with potential H 2S exposure first “recognize that potential” and then “follow the guidelines within the standard to provide the required training for their workers and instructors.” “There is little reason why tragic overexposure incidents should continue to occur. Most serious incidents and fatalities occur as a result of untrained workers becoming would-be rescuers, and ultimately, another statistic,” stresses Perry.
During the next year, Perry says the Z390 ASC will continue to promote the revised standard and “to convince the scores of industries where hydrogen sulfide may be present that it is in their best interest to learn about the hazards associated with this toxic gas and to implement the recommended training and safe work practices.”
Frank Perry is the principal for Frank H. Perry & Associates, Inc. located in Franklin, Texas. He retired from Cooper Cameron Corporation as Health, Safety and Environmental Director after 26 years with the organization.
Perry is a Certified Safety Professional in Comprehensive Practice and a Registered Professional Safety Engineer in the Commonwealth of Massachusetts, and he is a Certified Health, Safety & Environmental Trainer. He also is a Professional Member, past President and Fellow of the American Society of Safety Engineers.
Perry currently serves as Chair of the standard “Accepted Practices for Hydrogen Sulfide Safety Training Programs”(ANSI Z390.1-2006) and as Vice-Chair of the standard “Accepted Practices in Safety, Health and Environmental Training” (ANSI Z490.1).He is an adjunct instructor for the Texas Engineering Extension Service at Texas A&M University.