Managing Chemical Hazards

Transcription

1 2012 Managing Chemical Hazards C 8/10/2012

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4 4 Table of Contents Managing Chemical Hazards Definitions Purpose and Responsibilities Each employer is responsible for the following: Supervisors are responsible for the following: Workers are responsible for the following: Health Hazards from Oil Based Drilling Fluid Exposure Risk Identification Inhalation Skin Ingestion Risk Assessment Exposure limits Controls Engineering Controls Administrative Controls Personal Protective Equipment Respirators Gloves Coveralls Hygiene Facilities and Decontamination Procedures Washing Facilities BC Reg Health Monitoring Training Training Topics Annual Review References Workplace Hazardous Materials Information System (WHMIS) Definitions Controlled Products (Exemptions)...27

5 Inventory Hazardous Waste Decanted Products Safer Products Exposure to Airborne Hazardous Substances Automated Warning and Detection Systems Labelling Material Safety Data Sheets (MSDS) Product Information Hazardous Ingredients Physical Data Fire and Explosion Hazard Reactivity Data Toxicological Properties Preventive Measures First Aid Measures Preparation Information Availability of Material Safety Data Sheets Worker Education and Training Transportation of Dangerous Goods (TDG) Responsibilities Consignor (Shipper) Carrier (Driver) Consignee (Receiver) Classification Safety Marks TDG Labels TDG Placards Loading and Security Documentation Training Containment of Dangerous Goods...38

6 Dangerous Occurrences Chemical and Biological Substances Employer Responsibilities Employee Responsibilities Training Exposure Limits Detection Storage Immediate Danger to Life or Health (IDLH) Spills, Leaks and Accumulations Breaks and Meal Periods Reporting Hazards Contamination Limits Containers and Storage Storage Area...44

7 Managing Chemical Hazards Definitions ACGIH - American Conference of Governmental Industrial Hygienists WHMIS- Workplace Hazardous Materials Information System MSDS - Material Safety Data Sheet ECP - Exposure Control Plan Benzene - an aromatic hydrocarbon that is flammable and can be present in the drilling fluids or in the formations gas and liquids. It is highly toxic and can cause serious disease and bone cancer. Exposure Level - the maximum allowable exposure to a chemical or other agent or hazard. It is often expressed as an average over eight hours or 15 minutes or as a ceiling above which no exposure is permitted at any time. Exposures longer than eight hours are often adjusted to account for extended exposure and reduced recovery time. Exposure levels can also be referred to as occupational exposure levels (OEL) or permissible exposure levels (PEL). Mist - the presence of liquid droplets suspended in the air Silica (Quartz) - an abundant crystal that can be present in many dry products added to drilling fluids and present in the rock formations being drilled. It is highly toxic and can cause serious disease and lung cancer. Vapour - the gas form of a substance that is normally a liquid or solid at standard temperature and pressure Purpose and Responsibilities We have a duty to protect our workers from exposure to oil-based drilling fluids during drilling operations and transport. Studies show that these operations generate airborne contaminants from oil-based drilling fluids (e.g., oil mist) in excess of occupational exposure limits. Effective controls are available to protect workers from harmful exposure. A combination of control measures will be required to achieve this objective. We commit to being diligent in our efforts to select the most effective control technologies available, and to ensure that the best practices, as described in this exposure control plan (ECP), are followed at our work sites. The work procedures we establish will protect not only our workers but also any other workers on-site who are not involved in these operations. This ECP applies to the site prime contractor, the driller, the mud company, the Vacuum truck company, centrifuge and/or shale dryer company and their employees as well as any

8 8 other third party companies and their employees when at risk as determined by a risk assessment Each employer is responsible for the following: Ensure that the ECP at a minimum meets or exceed the prime contractors ECP and provincial regulatory requirements. Ensure that the materials (for example, tools, equipment, and personal protective equipment [PPE]) and other resources (for example, worker training) required to fully implement and maintain this ECP and made readily available. The employer must provide materials and documentation required to comply with other sections of the health and safety regulation (i.e., MSDS sheet). Ensure that supervisors and workers are educated in the hazards of exposure to oilbased drilling fluids and trained to work safely with them. Maintain written records of training (for example, proper use of respirators), fit-test results, crew talks, and inspections (for equipment, PPE, and work methods and practices) Conduct an annual review (or more often if conditions change) of the effectiveness of the ECP. This includes a review of available control technologies to ensure these are selected and used when practical. Coordinate work with other employers to ensure a safe work environment. Prime Contractors and their site personnel need to make sure that an exposure control plan is present on site and being adhered to. Prime Contractors need to select the drilling fluids considering the health and safety risks to all personnel using or handling those fluids. Fluids should be selected based on the recommendations detailed in Enform s IRP 14: Non Water Based Drilling and Completions/Well Servicing Fluids (IRP 14) Supervisors are responsible for the following: Provide adequate instruction to workers on the hazards of exposure to oil-based fluids during drilling operations and transport. Select and implement the appropriate control measures. Ensure that workers using respirators have been properly trained and fit-tested, and that the results are recorded. Ensure that work is conducted in a manner that minimizes and adequately controls the risk to workers and others. This includes ensuring that workers use appropriate engineering controls, Administrative controls and wear the necessary PPE only as a last line of defence.

9 9 Site supervisors (i.e., well site supervisor, rig managers and other third party supervisors) are responsible to ensure that workers have been trained in this exposure control plan and its expectations and that it is adhered to. Periodic refresher training shall be provided at safety meetings and at tailgate safety meetings Workers are responsible for the following: To have read, understand and adhere to the controls set out in this exposure control plan when using Oil Based Drilling Fluid. A copy of this exposure control plan in relation to Oil Based Drilling Fluid must be present on every drilling site where Oil Based Drilling Fluid is being used. Use the assigned protective equipment in an effective and safe manner including but not limited to being clean shaven where a respirator seal is established with a workers face. Follow established work procedures as directed by the supervisor. Report any unsafe conditions or acts to the supervisor. Report to the employer any exposure incidents or any signs or symptoms of illness from exposure to invert fluids. The workers will acknowledge that they understand the requirement of the ECP prior to commencing their work activities Health Hazards from Oil Based Drilling Fluid Exposure Health effects from Oil Based Drilling Fluid exposure vary depending on the chemical constituents of the drilling fluid. The health effects from overexposure to oil based mist via inhalation include irritation of the respiratory tract and various forms of pneumonia, as well as, sensitization to chemicals such as oil mist. Oil based drilling fluid can cause a variety of severe health effects as well as skin disorders, such as dermatitis. Other chemical constituents are added to Oil Based Drilling Fluid or picked up from the formation or the drilling process. These substances could include benzene, other hydrocarbons, crystalline silica and others. Specific health hazards are associated with exposure to each of these substances some of which include cancer. In accordance with BC Reg 5.4 and BC Guidance 5.48 Chinook Drilling will ensure that no worker is exposed to a substance that exceeds the ceiling limit, short-term exposure limit, or 8-hour TWA limit prescribed by ACGIH.

10 Risk Identification When Oil Based Drilling Fluid is heated, pressurized, or agitated it, or some of its constituents (e.g., oil mist and hydrocarbon vapours), can become airborne as both a vapour and a mist. Worker exposure can occur by inhalation, skin contact or by ingestion. In general, inhalation exposure to Oil Based Drilling Fluid can occur in three ways as a function of: the work location; the activity (task); and/or During unplanned events. The following information represents the exposure risks as they are currently understood today. As more time progresses more locations, activities and or unplanned events may be included and therefore the exposure risks presented below may not be limited to only these locations Inhalation Work locations related to inhalation exposure are: on top of the Mud Tanks; centrifuge flow back line; at the Shakers; and On the Drilling Floor. Activities or tasks related to inhalation exposure are: the use of wash guns; mud tank cleaning; and The collection of cutting samples from the Shakers. Unplanned events related to inhalation exposure are: when Invert spills occur; and Well control is lost.

11 Skin Work locations related to skin exposure are: at the Shakers; and On the Drilling Floor. Activities or tasks related to skin exposure are: the use of water-based wash guns to clean and/or move Oil Based Drilling Fluid; tripping in and out of the hole; cleaning around the well head; handling the fluid either through pumping or mixing; pump maintenance; transferring of fluids; construction or decommissioning of tank farms; piping connections and disconnections; vacuum truck activities; mud tank cleaning; and The collection of cutting samples from the Shakers. Unplanned events related to skin exposure are: when Invert spills occur; and Well control is lost Ingestion Ingestion is a concern if workers are splashed in the face and unintentionally swallow fluids, if contaminated drink and foods are ingested and/or if the worker's hands become contaminated and they do not wash them and subsequently put their hands to their mouth such as when eating or smoking.

12 Risk Assessment Exposure to Oil Based Drilling Fluid has been recognized as a concern in the oil and gas industry. Various oil and gas associations have weighed in on this issue such as the Canadian Association of Petroleum Producers (CAPP) in their Oil Mist Monitoring Protocol, Enform with their Industry Recommended Practice IRP 14: Non Water Based Drilling and Completions/Well Servicing Fluids and the International Association of Oil and Gas Producers (OGP) in conjunction with the International Petroleum Industry Environmental Conservation Association (IPIECA) in their guideline entitled Drilling Fluids and Health Risk Management. While many assessments have been completed in the Industry, individual site variations, configurations and activities or other site-specific conditions may affect the exposure risk. Personnel working with Oil Based Drilling Fluids need to: conduct risk assessments for their specific operations as a component of their health and safety program; and Implement appropriate controls to mitigate risks to acceptable levels. Another variable that influences exposure risk is ambient conditions. Fluctuations in the ambient temperature and/or wind may change the relative amount of vapour versus mist present. Additionally, during colder ambient conditions work areas such as the drilling floor may be temporarily enclosed and the benefits of natural ventilation (wind) may be reduced or removed altogether. The partial or complete enclosure of the mud tank and shaker areas will likely result in reduced ventilation and a substantial increase in the exposure risks in these areas Exposure limits Oil Based Drilling Fluids do not have an individual Exposure Limit (EL), as they are complex mixtures. In addition, other chemicals (e.g., clays, buffers and emulsifiers) may be added to Oil Based Drilling Fluids during drilling operations or chemicals may be picked up from the formation and drilling process.

13 13 Table 1: Exposure Limits Chemical Benzene (Skin) 2 Kerosene 4 (Skin) (vapor only) Oil mist - mineral (mildly refined) Oil mist - mineral (severely refined) 6 Oil mist - mineral ACGIH BC 12-hour EL AB 12-hour EL SK 12-hour EL 12- hour TLV ppm (2.5 ppm STEL) 0.25 ppm (2.5 ppm STEL) 0.25 ppm (2.5 ppm STEL) ALARA mg/m mg/m mg/m mg/m 3 N/A mg/m mg/m mg/m mg/m 3 (10 mg/m 3 STEL) (250 mg/m 3 STEL) 2.5 mg/m 3 (10 mg/m 3 STEL) Silica (quartz) mg/m mg/m mg/m mg/m 3 NOTE: Exposure limits are subject to change by the agencies that set them. Exposure limits may differ between jurisdictions hour exposure limits are calculated from published 8 hour TLV's by multiplying the 8 hour TLV's by a conversion factor (usually 0.5). 2 Skin notation indicates that skin adsorption can be a significant exposure pathway in addition to inhalation 3 ALARA - as low as reasonably achievable 4 Kerosene EL limited to vapour only and therefore does not protect against oil mist 5 No exposure level is indicated as per the 2010 TLV 6 ACGIH has a TLV of 5 mg/m 3 ; however, it only applies to pure, highly and severely refined mineral oils and industries where additives and contamination are not commonplace as per the 2010 TLV Documentation

14 Controls The implementation of effective exposure controls is the outcome of risk assessments and evaluations. Most Occupational Health and Safety Regulations require employers to select controls based on the following hierarchy: Substitution; Engineering Controls (for example, local exhaust ventilation, barriers); Administrative Controls (for example, limiting time workers are in a potentially contaminated area); and Personal Protective Equipment (for example, respirators and disposable coveralls). Ideally, the hazard should be eliminated or substituted. Oil Based Drilling Fluid and its base oil are typically selected based on the well-bore stability advantage that they offer over water-based drilling fluids. Therefore the substitution of oil-based drilling fluids with waterbased drilling fluids may not be practical; however less toxic base oils should be used when practical and should conform to IRP 14. It is important to note that the controls discussed in this document are limited to the use of drilling fluids that conform to IRP 14 requirements. Regardless of product substitution, engineering (e.g. ventilation), administrative (e.g. work procedures) and personal protective controls (e.g. respirator) are needed. Of these controls the use of engineering controls are typically the most desirable and effective. Personal protective controls should only be considered when engineering controls and/or administrative controls are either not practical or not effective on their own. Details of each exposure control are located below and a summary table of the controls is provided in Appendix I in Table 2: Recommended Controls Summary Table Engineering Controls To limit exposure rig work involving Oil Based Drilling Fluids should take into consideration the recommendations of Enform s IRP 14, referenced above. All reasonable measures should be used to limit worker exposure to Oil Based Drilling Fluids. If any of the drilling operations are enclosed (e.g., with tarps, barriers or framing), then the increase in worker exposure must be managed through ventilation or other controls addressed in this document in accordance with provincial regulations.

15 15 Specifically the following equipment and configurations should be used: On the drilling floor: Mud can; Catch can; A stripper must be used to remove excess Invert from the pipe when it is pulled up through the table; Drip trays in the pipe racking area; and Weighted pills. Around shale shakers and mud tanks: Barriers around shakers may be placed to isolate them from nearby workers such as those on the drilling floor; Local capture hoods and exhaust ventilation on shaker units; and Ventilation fans may be positioned on the tanks to provide air movement. Proper grounding and bonding for the prevention of static electrical discharge must be in place. In the event of Oil Based Drilling Fluid spills, all reasonable measures shall be taken to collect the fluid with a vacuum truck or rig-affixed vacuum system prior to the use of wash guns Administrative Controls Personnel on site must follow established practices and procedures for drilling to limit contact with liquid or airborne Oil Based Drilling Fluid. Personnel collecting drill cutting samples from the Shakers should limit their time in the area of the Shakers and the Mud Tanks. Samples should be collected and then taken down to a designated area such as adjacent to the mud tanks for sieving and washing to occur. The sample washing is often conducted with diesel. Workers should not use their gloved hand to agitate the cutting diesel slurry, but rather should use a spoon or other mixing tool. Contractors collecting cutting samples are required to develop and implement written work procedures detailing the Shaker sample collection. The use of diesel or oil based fluids in wash guns is strictly prohibited. Workplace Monitoring for BC Operations - BC Reg 5.53 :

16 16 In cases where a Chinook Drilling employee is or may be exposed to a hazardous substance, Chinook will ensure that: A walkthrough survey is conducted to assess the potential for overexposure taking into account all routes of exposure, including inhalation, ingestion, and skin contact, and A reassessment is conducted when there is a change in work conditions which may increase the exposure, such as a change in production rate, process or equipment. (If the walkthrough survey reveals that there is a risk of overexposure to an airborne contaminant, then Chinook will ensure that air sampling is conducted to assess the potential for overexposure. All reasonable efforts should be taken to limit Oil Based Drilling Fluid exposure during water based wash gun activities. Specific care must be taken regarding adjacent personnel. Contractors using water based wash guns are required to develop and implement written work procedures detailing wash gun use. Signs must be posted at the Mud Tank/Shaker areas indicating that respiratory protection is required for personnel conducting work in this area Personal Protective Equipment Respirators Workers conducting work in the vicinity of the Mud Tanks and Shakers must wear respiratory protection. For the purposes of this document conducting work entails completing a specific task or activity and does not include walking past the area occasionally or performing other work that is not prolonged in nature. At a minimum the respirator must consist of a non-disposable half-face respirator or fullface respirator equipped with combination P100/OV cartridges (the use of goggles should be considered with a half-face respirator). The superior fitting qualities of a non-disposable face-piece paired with the oil-proof particulate and mist filter (P100) and the organic vapour cartridge (OV) make this the best overall respiratory protection for a drilling rig given the potential presence of other chemical hazards such as benzene, silica, etc. Regardless of the type of respiratory protection used, a respiratory protection program must be in place to ensure that workers are clean shaven, have been fit-tested and are trained in the use, care and maintenance of their respirators. Respirators will be used, cleaned and stored in accordance with the respiratory protection program.

17 17 The presence of other chemical hazards may necessitate the need for a higher degree of respiratory protection. The use of water-based wash guns to clean up Oil Based Drilling Fluid should be conducted using respiratory protection as previously described. The use of a full-face mask may be beneficial for added protection of the face and eyes Gloves Neoprene gloves or equivalents are recommended based on their chemical and physical resistance to degradation and other properties making them suitable for the task. Alternatively, cloth-based gloves worn over top of nitrile glove may be used. Cloth-based gloves worn on their own are not designed to protect against chemical hazards and should be avoided when working with Oil Based Drilling Fluids or in areas with activities where Oil Based Drilling Fluid is likely to be encountered. Neoprene gloves or equivalents must be worn to protect the hands from chemical absorption and dermatitis (rashes). It is a common practice on drilling rigs to wash and reuse gloves on an on-going basis. The reuse of gloves can potentially be a concern because gloves lose their ability to prevent penetration of a given chemical through the glove material with repeated use. It is important to note that initially this penetration is chemical in nature rather than physical such as a hole or cut and therefore is typically not observed by the worker. The washing of gloves removes visible chemical contamination, but does not restore the gloves ability to limit chemical penetration and therefore washed gloves will offer decreasing protection with reuse. Neoprene gloves or equivalents that are heavily soiled for the majority of a work shift should be discarded and replaced at any sign of chemical penetration. Gloves that have had little to no contact with Oil Based Drilling Fluid may be washed and reused daily and discarded and replaced with new gloves at any sign of chemical penetration. If disposable nitrile gloves are worn in conjunction with cloth-based gloves the nitrile gloves shall be worn as the inner layer and should be discarded and replaced at least daily and the cloth-based gloves should be washed daily. Barrier creams can offer some assistance; however they should not be relied upon to protect the worker from dermatitis or potential skin absorption. Instead they offer secondary protection should the workers skin come into contact with fluids. It is important to note that in order for barrier creams to be effective against oil-based drilling fluids like Invert they must be water-based. This can potentially create another hazard as other

18 18 chemicals handled on a drilling site such as hydrated lime are water soluble and could increase the severity of burns and other health effects when in contact with skin covered in barrier cream. In addition to barrier creams a good skin lotion can be beneficial at the end of the work shift to help regenerate the skins natural defences and replace any oils that may have been lost due to intermittent contact with Oil Based Drilling Fluids Coveralls In general, fire retardant coveralls should be sized and worn in a manner to limit exposed skin such as at the arms, ankles and neck. If coveralls become wet saturated (to a point of skin contact) with Oil Based Drilling Fluid they should be removed and replaced with clean coveralls immediately and any affected skin surfaces should be washed with a mild detergent solution. Chemical Resistant Fire Retardant Rain Jackets and Rain Pants should be worn over fire retardant coveralls when splashes of Oil Based Drilling fluids are anticipated such as when tripping out of the hole, conducting water based wash gun activities and conducting mud tank cleaning. The use of neoprene coated rain jackets and pants is recommended. Replace coveralls immediately when they become wet saturated (to a point of skin contact) with Oil Based Drilling Fluid Hygiene Facilities and Decontamination Procedures In order to protect workers, decontamination is an integral component of exposure control. The goal is to remove contamination of skin and personal protective equipment to limit the duration of skin exposure and prevent the potential inadvertent ingestion of contaminants. Inadvertent ingestion may occur during eating, drinking, smoking, or other personal habits such as biting of finger nails etc. Prior to eating, drinking and in general leaving the rig, workers should thoroughly wash their face and hands with a mild detergent solution. Adequate washing facilities must be provided on site to enable worker decontamination. Eating and drinking is restricted to authorized areas only. Adequate washing facilities must be provided on site to enable worker decontamination.

19 Washing Facilities BC Reg 5.85 Chinook Drilling will ensure that appropriate emergency washing facilities are provided within a work area where an employee s eyes or skin may be exposed to harmful or corrosive materials or other materials which may burn or irritate Health Monitoring A program of monitoring and evaluating workers health is beneficial, although based on the hazards of Oil Based Drilling Fluid it is not required. However, general fit for work expectations, ability to wear a respirator, and other related components such as respirator fit testing will be included in the health and safety program Training Training will be performed by the employer or the employer s designate. Records of attendance, dates of training, and training material will be documented and retained. Additional training or reference material on Oil Base Drilling Fluid exposure will be made available to employees upon request Training Topics Health hazards of Oil Based Drilling Fluid exposure; Operations that can produce vapours and mists from Oil Based Drilling Fluids; Engineering controls and safe work practices used to protect workers; The importance of proper equipment control and maintenance; Housekeeping procedures; Proper use of respirators and the respirator program; Personal hygiene procedures to reduce exposures; and Review the details of the exposure control program for Oil Based Drilling Fluids. As with all hazard controls, training is paramount to the success of any program.

20 Annual Review This Exposure Control Plan (ECP) will be reviewed at least annually and updated as necessary by the employer, in consultation with the workplace health and safety committee or the worker health and safety representative. This review should take into account any voluntary certification programs (i.e., COR Audit) in place and changes in regulatory requirements. Proposed changes to this practice can be directed to the Chinook Drilling, HS&E Coordinator References Canadian Association of Petroleum Producers (CAPP); Oil Mist Monitoring Protocol, December ( Enform; Industry Recommend Practice (IRP) 14: Non Water Based Drilling and Completions/Well Servicing Fluids, ( International Association of Oil and Gas Producers (OGP) in conjunction with the International Petroleum Industry Environmental Conservation Association (IPIECA); Drilling Fluids and Health Risk Management, ( The following table summarizes acceptable control recommendations and requirements when working with Oil Based Drilling Fluids: Table 2: Recommended Controls Summary Table Work activity Mist/vapour suppression Other controls PPE (in addition to safety equipment normally required on a rig site) Collecting mud samples from the shakers Local exhaust ventilation (LEV) unit on top of the shakers Barriers (e.g., sheet metal or plastic) around the shakers Half-face respirator (with P100/OV cartridges) and goggles; full-face respirator (with P100/OV cartridges). Neoprene gloves or clothbased gloves overtop disposable nitrile gloves. Working on top of mud tanks Half-face respirator (with P100/OV cartridges) and goggles; full-face respirator (with P100/OV cartridges). Tripping pipe Neoprene gloves or cloth-

21 21 Work activity Mist/vapour suppression Other controls PPE (in addition to safety equipment normally required on a rig site) based gloves overtop disposable nitrile gloves Neoprene or Rubber FR rain jackets and rain pants over fire retardant coveralls Transporting drilling fluids Neoprene gloves or clothbased gloves overtop disposable nitrile gloves with Barrier Cream Working near Centrifuges, Desanders, Desilters, Mud Pumps Local exhaust ventilation (LEV) unit to maximize air exchange Barriers (e.g., sheet metal or plastic) around these high shear generating units Half-face respirator (with P100/OV cartridges) and goggles; full-face respirator (with P100/OV cartridges). - Neoprene gloves or cloth-based gloves overtop disposable nitrile gloves with Barrier Cream Mixing Room for Liquid and Dry Mud Additives Local exhaust ventilation (LEV) unit to maximize air exchange Neoprene gloves or clothbased gloves overtop disposable nitrile gloves with Barrier Cream Neoprene or Rubber FR rain jackets and rain pants over fire retardant coveralls Respirator or mask (depending on product being mixed)

22 22 Work activity Mist/vapour suppression Other controls PPE (in addition to safety equipment normally required on a rig site) Field Laboratory Local exhaust ventilation (LEV) unit to maximize air exchange Neoprene gloves or clothbased gloves overtop disposable nitrile gloves with Barrier Cream Tank Cleaning Half-face respirator (with P100/OV cartridges) and goggles; full-face respirator (with P100/OV cartridges). Neoprene gloves or clothbased gloves overtop disposable nitrile gloves with Barrier Cream Neoprene or Rubber FR rain jackets and rain pants over fire retardant coveralls Workplace Hazardous Materials Information System (WHMIS) All hazardous materials on worksites are controlled under both federal and provincial legislation. This legislation requires employers to provide specific information to workers for the safe use, handling, production and storage of hazardous materials on worksites. The legislation is called WHMIS and falls under the Federal Hazardous Products Act and Controlled Products regulations. A controlled product is any product, material or substance which, by application of criteria in Part IV of the Controlled Products Regulations, is included in any of the six major classes listed below. Class A Compressed Gas Class B Flammable and Combustible Material Class C Oxidizing Material Class D Poisonous and Infectious Material Class E Corrosive Material Class F Dangerously Reactive Material

23 23 Controlled materials will be labelled with the following symbols to help identify the risk. Hazard Symbol Class & Division Description Class A Class B Division 1 Division 2 Division 3 Division 4 Division 5 Division 6 Class C Class D Division 1 Division 2 Compressed Gas Flammable & Combustible Material Flammable Gas Flammable Liquid Combustible Liquid Flammable Solid Flammable Aerosol Reactive Flammable Material Oxidizing Material Poisonous & Infectious Material Materials Causing Immediate & Serious Toxic Effect Materials Causing Other Toxic Effects Division 3 Biohazardous Infectious Material Class E Corrosive Material Class F Dangerously Reactive Material

24 24 The following are miscellaneous WHMIS symbols indicating different types of PPE and other equipment required when working with and around controlled products. Symbol Description Face Shield Self-Contained Breathing Apparatus Half Face Piece Air- Purifying Respirator Dust Mask Gloves Goggles Lab Coat Boots Protective Apron Container with Handle Container Fire Extinguisher Eye Wash Radiation NFPA

25 25 Controlled products, including hazardous waste, include a wide range of chemical substances, mixtures and products found in the workplace, as well as various bio-hazardous infectious materials. Examples of controlled products are: Hazardous Waste - Produced oil, water, gas, condensate and LPGs Acids, caustics, methanol and xylene Gasoline, diesel, glycol and propane Most solvents, paints and cleaning agents All controlled products used, stored, handled or produced at worksites must comply with this legislation. WHMIS compliance consists of three basic components that must be met to protect workers against injury: labelling, MSDS, and worker education and training Definitions bulk shipment means a shipment of a controlled product that is contained without intermediate packaging in: (i) A container with a water capacity of more than 454 litres; (ii) a freight container, road vehicle, railway vehicle or portable tank, a freight container on a road vehicle, railway vehicle, ship or aircraft or a portable tank carried on a road vehicle, railway vehicle, ship or aircraft; (iii) The hold of a ship; or (iv) A pipeline; container includes a bag, barrel, bottle, box, can, cylinder, drum, storage tank or similar package or receptacle; Controlled Products Regulations means the Controlled Products Regulations (Canada), SOR/88-66; fugitive emission means a gas, liquid, solid, vapour, fume or dust that escapes from any process or emission control equipment or from a product; hazard information means information on the proper and safe use, storage and handling of a controlled product, and includes information relating to the product s toxicological properties; hazardous waste means a controlled product that is intended for disposal or is sold for recycling or recovery;

26 26 laboratory sample means a sample of a controlled product that is intended solely to be tested in a laboratory but does not include a controlled product that is to be used: (i) By the laboratory for testing other products, materials or substances; or (ii) For educational or demonstration purposes; manufactured article means an article that is formed to a specific shape or design during manufacture, the intended use of which when in that form is dependent, in whole or in part, on its shape or design and that, under normal conditions of use, will not release or otherwise cause a person to be exposed to a controlled product; product identifier means, with respect to a controlled product, the brand name, code name or code number specified by a supplier or the chemical name, common name, generic name or trade name; readily available means present in an appropriate place in the form of a paper copy that can be handled by a worker; risk phrase means, with respect to a controlled product or a class, division or subdivision of controlled products, a statement identifying a hazard that may arise from the nature of the controlled product or the class, division or sub-division of controlled products; supplier means a supplier as defined in the Hazardous Products Act (Canada); supplier identifier means, with respect to a controlled product, the name of the supplier of the controlled product; supplier label means a label provided by a supplier that discloses the information and displays the hazard symbols mentioned in paragraph 13(b) of the Hazardous Products Act (Canada); supplier material safety data sheet means a material safety data sheet provided by a supplier that discloses the information mentioned in subparagraphs 13(a)(i) to (v) of the Hazardous Products Act (Canada); workplace label means a legible label that discloses: (i) A product identifier that is identical to that found on the material safety data sheet of the corresponding controlled product; (ii) All necessary information for the safe handling of the controlled product; and (iii) The fact that a material safety data sheet, if supplied or produced, is available.

27 Controlled Products (Exemptions) Chinook Drilling must ensure that a controlled product is used, stored, handled or manufactured at a work site in accordance with regulations. WHMIS does not apply if the controlled product is: and (a) Wood or a product made of wood, (b) Tobacco or a tobacco product, (c) A hazardous waste, or (d) A manufactured article, (i) that is formed to a specific shape or design during manufacture, (ii) That has a shape or design that determines its use in whole or in part, (iii) That, under normal use, will not release or otherwise cause a person to be exposed to chemicals emanating from it. Except for regulations on the availability of the MSD sheets, this Part does not apply if the controlled product is a dangerous good, under the Dangerous Goods Transportation and Handling Act, to the extent that its handling, offering for transport or transport is subject to that Act. Labels and material data sheets do not apply if the controlled product is (a) An explosive governed by the Explosives Act (Canada), (b) A cosmetic, device, drug or food governed by the Food and Drug Act (Canada), (c) A product governed by the Pest Control Products Act (Canada), (d) A nuclear substance governed by the Nuclear Safety and Control Act (Canada), or (e) A product, material or substance packaged (i) As a consumer product, and (ii) In a quantity normally used by a member of the general public Inventory Chinook Drilling will keep and maintain a record of all hazardous substances that are used produced, handled or stored in their office/field locations.

28 Hazardous Waste If a controlled product is a hazardous waste generated at the work site, Chinook Drilling must ensure that it is stored and handled safely using a combination of (a) Any means of identification, and (b) Instruction of workers on the safe handling of the hazardous waste Decanted Products If a controlled product in a workplace is in a container other than the container in which it was received from a supplier, Chinook Drilling must ensure that the container has a workplace label applied to it. This does not apply to a portable container that is filled directly from a container that has a supplier label or workplace label applied to it And (a) If the controlled product (i) is under the control of and is used exclusively by the worker who filled the portable container, (ii) Is used only during the shift in which the portable container was filled, (iii) The content of the container is clearly identified, or (b) If the entire controlled product is required for immediate use Safer Products Wherever practicable, Chinook Drilling employees will utilize non-hazardous substances to perform their duties. In the event a hazardous substance must be used to perform a task, the substance ultimately selected, must be the least hazardous alternative Exposure to Airborne Hazardous Substances Chinook Drilling employees will be kept from exposure to: An airborne chemical agent Airborne grain dust Airborne chrysotile asbestos Automated Warning and Detection Systems If required and practicable, Chinook Drilling will provide automated warning and detection systems for hazardous substances known to have serious effects on health and safety.

29 Labelling All controlled products on worksites are identified with a WHMIS label. Labels are of two basic types: a supplier label or a worksite label. Supplier labels are provided, as a condition of sale, by the supplier of a controlled product. The supplier is the person or firm who manufactures, processes, imports or sells a controlled product. Worksite labels must be applied to the container of controlled products which are manufactured at the worksite or containers where an existing supplier label becomes illegible or is accidentally removed and a replacement supplier label is not immediately available. Worksite labels must also be used if a controlled product is transferred to another container. Other means of identification, which need not be worksite labels but which clearly identify controlled products, must be provided for transfer or reaction systems, which contain controlled products. These containers may be process or reaction vessels, pipeline systems and manifolds, or tank trucks containing controlled products. The product identification method may be warning signs, colour coding, piping diagrams or product identification labels. These alternative methods must be used in combination with worker education. Chinook Drilling must ensure that a controlled product or its container at a work site has a supplier label or a work site label on it. Chinook Drilling must not remove, modify or alter a supplier label on a container in which a controlled product is received from a supplier if any amount of the controlled product remains in the container. If the supplier label on a controlled product or its container is illegible or is removed or detached, Chinook Drilling must immediately replace the label with another supplier label or a work site label. Chinook Drilling may store a controlled product that does not have a supplier label or a work site label on it for not more than 120 days if Chinook Drilling (a) Is actively seeking the supplier label or the information required for a work site label, (c) ensures that a worker who works with or in proximity to the stored controlled product knows (i) The purpose of the placard and the significance of the information on it, (ii) Is trained in the procedures to be followed if there are fugitive emissions, and (iii) Is trained in the procedures to be followed in case of an emergency involving the controlled product.

30 30 If a controlled product is received at a work site in a multi container shipment and the individual containers do not have supplier labels on them, Chinook Drilling must apply to each individual container a work site label. If a controlled product imported under section 23 of the Controlled Products Regulations (Canada) (SOR/88 66) is received at a work site without a supplier label, Chinook Drilling must apply a label disclosing the information and displaying the hazard symbols referred to in paragraph 13(b) of the Hazardous Products Act (Canada). If a bulk shipment of a controlled substance is received at a work site, Chinook Drilling must (a) If a supplier label is provided, apply the supplier label to the controlled product or its container, or (b) If a material safety data sheet or a statement in writing is transmitted in accordance with section 15 of the Controlled Products Regulations (SOR/88 66) and a supplier label is not provided, apply a work site label to the controlled product or its container. If a controlled substance at a work site is contained or transferred in or on a pipe, a piping system (including valves), a process valve, a reaction vessel, or a tank car/tank truck/ore car/conveyor belt or similar conveyance Chinook Drilling must ensure the safe use, storage, handling of the controlled substance through (a) Worker training, and (b) The use of colour coding, labels, placards or any other mode of identification Material Safety Data Sheets (MSDS) MSDS are technical documents, which provide detailed and comprehensive information on a controlled product. The MSDS for all controlled products at the worksite must be retained and be accessible to all at the worksite. They are intended to supplement the alert information provided on labels and must include the following information: Product Information Including product identifiers, manufacturer and supplier names, addresses and emergency telephone numbers Hazardous Ingredients A list of ingredients as required under subparagraphs 13(a)(i) to (iv) of the Hazardous Products Act.

31 Physical Data A variety of parameters such as physical state, odour, boiling point, etc. that physically characterize the product Fire and Explosion Hazard Characteristics of the substance that determine the likelihood of its ignition in various conditions, and information on the means of extinction Reactivity Data Information regarding the chemical instability of the product and chemicals with which it may dangerously react Toxicological Properties Information on how the product is likely to enter the body and on the short-term (acute) and long-term (chronic) health effects from exposure to it Preventive Measures Personal protective equipment, handling procedures and engineering controls to be used during the product s shipping, storage, use and disposal, and in emergency circumstances or leak, spill or other release First Aid Measures Specific first aid measures related to acute effects of overexposure to the product Preparation Information Identification of those responsible for the data sheet and date of preparation. MSDS remain in effect for a period of three years or sooner if new information about the product is determined. MSDS may be updated by a letter from the supplier outlining the information changes or additions. The rig manager will ensure that an up-to-date supplier MSDS is obtained the first time a supplier s controlled product is received at the worksite. For each controlled product produced or manufactured at a Chinook Drilling worksite, Chinook Drilling is responsible for developing an MSDS. Chinook Drilling will supply a copy of the MSDS to the purchaser of controlled products Availability of Material Safety Data Sheets Chinook Safety Department must ensure the material safety data sheets are readily available at a work site to workers who may be exposed to a controlled product and to the joint work site health and safety representative.

32 32 Should Chinook Drilling elect to make MSDS available on a computer system, Chinook Drilling will take all reasonable steps to keep the system in active working order, make the MSDS readily available on the request of a worker, and provide training in accessing computer-stored MSDS to one or more workers working at a workplace where the MSDS is available on a computer terminal, and Members of the joint committee or the worker health and safety representative, as applicable Worker Education and Training The Field Supervisor will ensure that workers are educated on each controlled product supplied or produced at the worksite. The Field Supervisor will also provide information on the safe use, storage and handling of the controlled product. The worker will know: the content required to be on a supplier label and a work site label and the purpose and significance of the information on the label, the content required to be on a material safety data sheet and the purpose and significance of the information on the material safety data sheet, procedures for safely storing, using and handling the controlled product, if applicable, the procedures for safely manufacturing the controlled product, the procedures to be followed if there are fugitive emissions, and The procedures to be followed in case of an emergency involving the controlled product. WHMIS worker education and training programs will be reviewed every three years and more frequently if dictated by a change in work conditions or available hazard information. Workers must make every effort to learn information provided on controlled products, and must inform the supervisors in any circumstance where they do not have adequate information to ensure their health and safety Transportation of Dangerous Goods (TDG) The TDG legislation is to protect the public when dangerous goods are being transported. The TDG regulations were written to ensure the proper information is provided to anyone who handles, offers for transport or transports dangerous goods, as well as to anyone who

33 33 responds to emergencies involving dangerous goods. The regulations apply from the time material is being loaded into a container or vehicle to the time the unloading operation is complete. Under the regulations, anyone who handles, offers for transport or transports dangerous goods must be trained and certified. Training includes the classification, labelling and documentation of hazardous goods, as well as reporting procedures for spills, leaks or accidents involving dangerous goods. All Chinook Drilling owner-operated fluid trucks or tanks are designed, constructed, filled, closed, secured and maintained so under normal transport conditions, including handling, there will not be any release that could endanger the public or environment Responsibilities Consignor (Shipper) The consignor must ensure that the goods are classified, packaged, marked, labelled and documented in accordance with the regulations. In addition, the consignor must: Give the carrier (driver) a copy of the shipping document. Ensure placards are on the vehicle if required. Report dangerous occurrences that occur during loading. Keep a copy of the shipping document for two years Carrier (Driver) The carrier must: Check the shipment before accepting it. Attach placards, if required. Maintain or replace safety marks, if necessary. Carry and deliver shipping documents with the goods. Report dangerous occurrences that occur during transport. Keep a copy of the shipping document for two years Consignee (Receiver) The consignee must: Report dangerous occurrences that occur during unloading. Keep a copy of the shipping document for two years.

34 Classification Dangerous goods are separated into nine classes according to the type of danger they present: Class 1 Explosives Class 2 Compressed Gas Class 3 Flammable Liquid Class 4 Flammable or Water Reactive Solid Class 5 Oxidizing Agents Class 6 Toxic Substances Class 7 Radioactive Materials Class 8 Corrosive Substances Class 9 Miscellaneous Most classes are further separated into divisions according to the type or degree of danger. See the following pages.

35 35 Class 1 - Explosives 1.1 Mass Explosion Hazard 1.2 Major Projection Hazard 1.3 Mass Fire Hazard Class 2 Compressed Gas 2.1 Flammable Gas 2.2 Non-Flammable, Non-Poisonous, Non-Corrosive Gas 2.2 (5.1) Oxygen only (mixed load) 2.3 Poison Gas 2.4 Corrosive Gas Class 3 Flammable Liquid 3.1 Flash Point Below -18ºC 3.2 Flash Point Between -18ºC & 23ºC 3.3 Flash Point Between 23ºC & 61ºC Class Flammable Solid 4.2 Spontaneously Combustible 4.3 Dangerous When Wet 5.1 Oxidizer Class Organic Peroxide

36 36 Class Poisonous Substances Packing Group I and II 6.1 Poisonous Substances Packing Group III 6.2 Infectious Substances Class 7 7 Radioactive Materials 7 Radioactive Materials Category I 7 Radioactive Materials Category II 7 Radioactive Materials Category III 8 Corrosives Class 8 Class Miscellaneous Dangerous Goods 9.1 Miscellaneous Dangerous Goods