health and safety

By Ron Kaminkow - Railroad Workers United, August 6, 2019

Docket Management System
U.S. Department of Transportation
West Building, Ground Floor, Room W12–140, Routing Symbol M–30 1200
New Jersey Avenue SE, Washington, DC 20590

August 6th, 2019

Comment Re: PHMSA–2019–0100, Draft Environmental Assessment for a Special Permit Request for Liquefied Natural Gas by Rail

To William S. Schoonover, Associate Administrator of Hazardous Materials Safety, and Pipeline and Hazardous Materials Safety Administration:

Railroad Workers United (RWU) urges you to deny the special permit requested by Energy Transport Solutions, LLC to ship large quantities of Liquefied Natural Gas (LNG) using unit trains of DOT-113C120W tank cars. Rail shipments of LNG would pose dramatic health, safety, and environmental risks to railroad workers and com-munities across the United States. LNG train derailments could cause fires and ex-plosions, property damage, mass injuries and fatalities - impacts that are largely ignored in PHMSA’s cursory, 23-page analysis.

As an organization of working rank & file railroad workers from all crafts and all car-riers, Railroad Workers United is deeply concerned about the casual attitude to-wards shipping LNG by rail. Over the course of the last six years or so we have wit-nessed the danger inherent in shipping Bakken crude oil by rail with limited over-sight and regulation, a danger that continues to this day.

It is obvious that the proposal to ship LNG by rail likewise is inherently dangerous for train crews, trackside communities and the public at large if it is not moved in a safe manner. Most of the oil trains which have crashed over the last six years or so - re-sulting in spills, fires, and explosions – were in fact made up of DOT-113C120W tank cars, ones of the type that apparently are being proposed now for LNG trains. Therefore, before any LNG is moved in unit trains across the U.S., Railroad Workers United recommends the following regulation:

• LNG shall not be moved by rail unless it is moved in tank cars that have been crash tested to withstand puncturing. Many of the rail cars currently in service are not capable of safely transporting LNG and should not be used in this capacity.
• Electrically Controlled Pnuematic (ECP) braking should be employed on all unit trains of LNG as a means of possibly preventing a disaster, and/or mitigating the extent of the disaster in the event of a derailment/crash.
• The longer and heavier the train, the greater the propensity for it to derail, and having derailed, the greater chance of disaster. We recommend all such dangerous trains be limited to no more than 50 cars.
• All such trains must have a minimum of at least two persons in the cab of the locomotive to ensure safe move-ment and delivery of the product, and to mitigate against disaster throughout its routing, should there be a mishap.
• Prior to departure from the originating terminal, all such trains must undergo a thorough and proper inspection by host railroad employees who are properly trained and certified to do the work.
• Prior to movement on the mainline, such trains should have an advance “high-rail” escort service to ensure that the track ahead is clear and in proper condition for the safe passage of the train.
• After a string of oil train derailments, fires and explosions, crude oil train speed was limited to 40 mph in urban areas. Unit trains of LNG should likewise be so restricted.

Only once these safety features at a minimum are adopted would RWU be comfortable in supporting the proposed shipment of LNG by rail.

Ron Kaminkow
General Secretary
Railroad Workers United

Download (PDF).

By staff - Unite the Union, August 2019

Unite has worked closely with the TUC to produce guidance to Unite members and other union members about dust in the workplace. Unite and the TUC have consistently called for a review of dust exposure levels in line with recommendations from the trade union side of the now disbanded Advisory Committee on Toxic Substances (ACTS), based on scientific evidence from the ACTS Scientific Committee, WATCH (also disbanded).

Evidence shows that dust is one of the biggest workplace killers and several thousands of workers are dying as a result of dust exposure. Many of these deaths are due to inadequate enforcement of existing standards, but others are the result of inadequate maximum exposure levels. Too many Unite members, and workers in general, are being exposed to dangerous levels of dust at work. The current dust standards are not good enough and there is strong scientific evidence to prove it.

The HSE has accepted some of the problems with dust, although senior members of the HSE have refused to back a statement of the problem, it was left to the now-defunct Advisory Committee on Toxic Substances to publish a statement as an Annex to the minutes of its meeting in May 2014.

Read the text (PDF).

By Patrick Young - Rising Tide North America, July 9, 2019

At around 4 am on Friday, June 21, a massive fire and explosion rocked Alkylation unit at the Philadelphia Energy Solutions refinery in South Philadelphia. The explosion was so powerful that it shook houses and apartment buildings around West Philadelphia. The ball of fire could be seen for miles, turning the predawn sky orange. As the fire raged, while every human instinct must have screamed to run away from the fire, members of the PES Emergency Response Team (ERT) dropped everything to run toward the fire. They battled the blaze for hours and by 10 am the fire was contained but still burning.

Like anyone who is familiar with refinery operations, Jim Savage, an operator at PES and a union activist immediately turned his thoughts to the ERT writing, “Huge props to our refinery Emergency Response Team. I’ve always questioned their sanity, but their courage and professionalism has never been in doubt. Those explosions were terrifying and I have no idea how we didn’t have injuries or even worse. It’s going to be a long and dangerous day for them, so keep them in your thoughts.”

It took a full day to fully extinguish the fire. The explosion was bad, but it could have been much, much worse. Unit 433, the Alkylation unit where the explosion occurred used hydrofluoric acid (HF) as part of the refining process. HF is by far the most dangerous chemical in the facility and PES’s most recent emergency response plan reported that there were as many as 71 tons of the chemical at the facility. Just after the explosion, the operator on the board at the refinery’s central control room transferred the HF that was in process to another container, preventing a mass release of the chemical.

Hydrofluoric acid is an incredibly dangerous chemical used as a catalyst in some oil refineries (there are inherently safer technologies in use in many refineries but owners of many older refineries, including the PES facility in South Philadelphia have refused to invest in safer systems). HF quickly penetrates human tissue, but it interferes with nerve function so burns may initially not feel painful, giving people a false sense of safety. Once it is absorbed into the blood through the skin it reacts with calcium and can cause cardiac arrest. It volatilizes at a relatively low temperature and travels as a dense vapor cloud — PES reports that the supply of HF stored at the South Philadelphia refinery could travel as far as 7 miles putting as many as a million people at risk.

On June 21, the members of United Steelworkers Local 10–1 on the PES Emergency Response Team and in the refinery’s control room prevented the dozens of tons of HF at the refinery from being released saving tens of thousands of lives.

Then on June 26th, those workers learned that they were losing their jobs. Philadelphia Energy Solutions announced that it was shutting down refinery operations and laying off nearly all of the workers at the refinery within weeks.

By Tord Kjellstrom, Nicolas Maître, Catherine Saget, Matthias Otto and Tahmina Karimova - International Labour Organization, July 1, 2019

The phenomenon of heat stress refers to heat received in excess of that which the body can tolerate without physiological impairment. It is one of the major consequences of global warming. By 2030, the equivalent of more than 2 per cent of total working hours worldwide is projected to be lost every year, either because it is too hot to work or because workers have to work at a slower pace. This report shows the impact of heat stress on productivity and decent work for virtually all countries in the world. It presents innovative solutions based on social dialogue to promote occupational safety and health for the most vulnerable groups of workers.

Read the report (Link).

By staff - International Labour Organization, April 2019

At its 329th Session (March 2017), the Governing Body of the International Labour Office decided that a Global Dialogue Forum on decent work in the management of electrical and electronic waste (e-waste) would be held in Geneva. During its 334th Session (October– November 2018), it decided that the date of the meeting would be 9–11 April 2019 and that all interested governments should be invited. Eight Employer and eight Worker participants would be appointed on the basis of nominations made by their respective groups in the Governing Body, and selected intergovernmental organizations and non-governmental organizations would be invited as observers.

The purpose of the Global Dialogue Forum is to discuss current and emerging issues and opportunities related to the promotion of decent work in the management of e-waste, with the aim of adopting points of consensus, including recommendations for future action by the International Labour Organization (ILO) and its Members. Taking place in the centennial year of the ILO, the Forum is also an opportunity to discuss more broadly the future of work in the circular economy.

Read the report (Link).

By staff - Western Center for Agricultural Health and Safety, March 7, 2019

Farming doesn’t stop just because the sun sets. Across the West, a variety of crops are harvested at night, such as wine grapes, tomatoes, onions, garlic, and corn. Harvest, equipment transportation, set up, and maintenance as well as field prep and repairs, irrigation work, and pesticide application are other activities done at night.

Night Work is Increasing

The general, unofficial consensus among a number of professionals involved in agriculture is that night work is increasing. Possible reasons include rising temperatures and heat illness prevention regulations, increasing labor shortages, product quality and taste preferences, time-sensitive harvests, and avoidance of pests.

“The area’s cool nights create better working conditions—not only is the temperature more tolerable, but bees and rattlesnakes stay away at night” explains Lino Bozzano, VP of Vineyard Operation, in the Laetitia Vineyard and Winery blog, “Why We Harvest Fruit At Night.” Head Winemaker, Eric Hickey adds that “grapes are firmer, making them easier to work with.”

Standard databases provide limited information. For example, the Bureau of Labor Statistics public records report the time of non-fatal injury by fixed time frames that cross day- and nighttime hours (e.g., 4 pm to 8 pm), making it difficult to determine how many accidents occur in the dark or how many accidents occurred from actual farm work versus transportation to and from the work site.

By Paul Vigeant, et. al. - Massachusetts Clean Energy Center, January 2019

The 2018 Massachusetts Offshore Wind Workforce Assessment provides a comprehensive analysis of the workforce needs and economic development impacts associated with the deployment of 1600 megawatts of offshore wind in Massachusetts. The report describes the jobs associated with planning, constructing and servicing offshore wind projects and provides information on the education, skills and health and safety credentials required for each job. Importantly, the report highlights the opportunities for Massachusetts residents to work in this emerging industry, and identifies recommendations and key strategies to better position the Commonwealth, offshore wind industry, educational institutions, non-profits, and labor to develop and serve a burgeoning offshore wind workforce.

Read the Report (PDF).