Archive for the ‘Crude Health Hazards’ Category

New battlefront for petrochemical industry: benzene and childhood leukemia by Kristen Lombardi for The Center For Public Integrity

ATHENS, Georgia — It was December 29, 1998, six years after Jill McElheney and her family had moved next to a cluster of 12 petroleum storage tanks. Jill was escorting her son Jarrett, then 4, to the doctor again. He had spent the day slumped in a stroller, looking so pale and fatigued that a stranger stopped her to ask if he was all right.

It was an encounter Jill couldn’t shake. For the previous three months, she had noticed her once-energetic preschooler deteriorating. He complained of pain in his knee, which grew excruciating. It migrated to his shoulder and then his leg. His shins swelled, as did his temples. At night, Jarrett awoke drenched in sweat, screaming from spasms. Jill took him to a pediatrician and an infectious-disease specialist. A rheumatologist diagnosed him with anemia.

Now, as Jarrett lay listless, Jill found herself back at the pediatrician’s office. Tests confirmed a blood count so low that she was instructed to get him to an emergency room immediately. Within hours she was at a hospital in Atlanta, some 65 miles from her home in Athens, watching nurses rush in and out of Jarrett’s room. Doctors identified a common form of childhood leukemia. “I heard the words,” Jill recalled, “and I only knew the bald heads and the sadness.”

In the waiting room, family members heard more unsettling news: A neighbor’s child also had developed leukemia.

Days later, Jarrett’s doctor penned a letter to federal environmental regulators about the two cancer patients, highlighting their “close proximity” to Southeast Terminals, a group of 10,000-gallon tanks containing gasoline, diesel and fuel oil.

“Could you please investigate,” the doctor wrote, “whether high levels of chemicals could have contaminated the water, possibly contributing … to the development of leukemia?”

Only then did the McElheneys consider the possibility that living beside one of the nation’s 1,500 bulk-oil terminals — known sources of cancer-causing benzene — had triggered their son’s leukemia.

“It was one of those light-bulb moments for us,” said Jeff McElheney, Jarrett’s father. “You never get over it.”

New battlefront for industry

Jarrett McElheney does not represent the standard benzene plaintiff. He’s not among the hundreds of thousands of people who toil in American oil refineries or other workplaces contaminated with the chemical and run the risk of developing leukemia. In the rancorous world of toxic-tort litigation, he stands virtually alone. A lawsuit filed by his parents in 2011 against Southeast Terminals owners BP and TransMontaigne is among a relatively few alleging leukemia caused by environmental benzene exposure. Among these, the McElheney case is rarer still: Most have hinged on adult leukemia.

Yet the case may signal an emerging quandary for the petrochemical industry, according to tens of thousands of pages of previously secret documents that have come to light in lawsuits filed against benzene manufacturers and suppliers on behalf of those who suffered from leukemia and other blood diseases, including Jarrett McElheney.

Internal memorandums, emails, letters and meeting minutes obtained by the Center for Public Integrity over the past year suggest that BP and four other major petrochemical companies, coordinated by their trade association, the American Petroleum Institute, spent at least $36 million on research “designed to protect member company interests,” as one 2000 API summary put it. Many of the documents chronicle a systematic attempt by the petrochemical industry to influence the science linking benzene to cancer. Others attest to the industry’s longstanding interest in topics such as childhood leukemia.

“A number of publications in the last few years have attempted to link increased risks of childhood leukemia with proximity to both petroleum facilities and local traffic density,” another 2000 API memo warns. “Although these publications have had little impact to date, the emphasis on ‘Children’s Health’ may cause these concerns to resurface.”

“This is indeed a battlefront for the oil industry,” said Peter Infante, a former director of the office that reviews health standards at the Occupational Safety and Health Administration, who has studied benzene for 40 years and now testifies for plaintiffs in benzene litigation. He has worked on a handful of cases involving children sickened by leukemia.

“It’s in the industry’s economic interests to refuse to acknowledge the relationship between benzene and childhood leukemia,” Infante said.

In May, in a sign of the chemical’s continuing threat, the U.S. Environmental Protection Agency estimated that 5 million Americans — excluding workers — face heightened cancer risks from benzene and 68 other carcinogens spewed into the air by the nation’s 149 oil refineries. The EPA has proposed a rule that would require refinery operators to monitor for benzene, in particular, along their fence lines.

Aimed at curbing “fugitive” emissions from equipment leaks and similar releases, the proposal would set a fence line limit for benzene of 3 parts per billion — a fraction of the 10 ppb the agency recommends as the maximum chronic exposure level for the chemical.

Industry groups are pushing back. In written comments, the API’s Matthew Todd called the proposal “a major and significant Agency action [that] will dramatically increase the paperwork and recordkeeping burden on refineries. It includes several precedent-setting proposals, will cost our industry hundreds of millions of dollars per year, increase safety risk [and] may impact fuels production and cost …. Production outages will likely occur.”

The EPA also heard from the people the rule is designed to protect. “We live near a refinery, and as a result my son can’t breathe,” a woman from Fontana, California, wrote in Spanish. “My cousin had respiratory problems while living near a refinery for more than 10 years,” a woman from Houston wrote, also in Spanish. “Unfortunately, he died 2 years ago from bone cancer. We believe this was a result of the ambient air where he lived.”

In June, California officials lowered the long-term exposure level for benzene from 20 ppb to 1 ppb — among the lowest in the country — setting the stage for further emissions cuts at refineries and bulk-oil terminals in that state. Officials say such regulatory actions aim to protect children, who are more susceptible to benzene’s toxic effects than adults because their cells aren’t as developed. California is considering classifying benzene not just as a human carcinogen, but as a “toxic air contaminant which may disproportionately impact children.”

“The fact that benzene impacts the blood-forming organs when you’re a developing child is a big deal,” said Melanie Marty of the state’s Office of Environmental Health Hazard Assessment.

Hidden menace

ill McElheney agrees. A warm, garrulous mother of five who has schooled herself in the health effects of pollution, she has spent the past 16 years seeking the cause of her son’s leukemia. She has filed open-records requests and contacted state and federal agencies, piecing together a history of gasoline spills and diesel-fuel leaks at Southeast Terminals. She can cite endless details about lingering benzene contamination on terminal property — extensively catalogued in state enforcement files — located “a stone’s throw away” from the trailer park where her family lived for seven years.

Jeff, Jarrett and Jill McElheney stand in the former site of the Oakwood Mobile Home Park, where the family was living when Jarrett was diagnosed with a form of childhood leukemia. Phil Skinner for the Center for Public Integrity
Now vacant and overgrown with brush, the former site of the Oakwood Mobile Home Park lies across a residential street from Southeast Terminals, its tanks rising above a thicket of pines and oaks. All day, every day, trucks drive in and out of the facility’s gates, filling tankers with gasoline and other products.

What can’t be seen is the plume of benzene that has worked its way into the groundwater beneath the tanks. “It’s not like Cancer Alley, with smokestacks belching crap in your face,” Jill said. “It’s hidden — literally.”

When she and Jeff moved to Oakwood in 1992, they saw the 14-trailer community as something of an oasis — quiet, tight-knit. Nestled under shady trees, near churches and schools, it seemed like the perfect location. Even the park’s water supply, drawn from an unpermitted well dating back decades, appeared idyllic: Its pump house served as a beacon on park property, visible for all to see — including, court depositions later confirmed, terminal employees.

“We saw Oakwood as an opportunity,” recalled Jeff, a mustachioed, genial man who operates a roofing company and managed the park for his father, its previous owner.

Jarrett McElheney, center, with 3 of his 4 siblings. Courtesy of the McElheney family
Jarrett arrived two years later and, by his fourth birthday, had grown into an adventurous boy with an abiding love of water. His parents remember him splashing in the tub for hours. Often, he swam in an inflatable pool in their yard, dressed in what he called his “little blue [wet] suit.” He slurped on Kool Aid and popsicles made from well water whose purity his parents never questioned — until his 1998 diagnosis of acute lymphocytic leukemia, or ALL, a form of the blood cancer found overwhelmingly in children.

Within days of hearing the news, Jarrett’s parents tested their water. Samples from the Oakwood well revealed a brew of such chemicals as carbon tetrachloride and 1,2-dichloroethane, sparking a state investigation. The Georgia Environmental Protection Division (EPD) found benzene in the water of Oakwood’s well at levels up to 13 ppb — 26 times higher than the federal safety standard. In response, the agency shuttered the well and connected residents to public water.

Over the next year, state geologists worked to identify the contamination’s source. They dug monitoring wells and collected soil samples. Their initial investigation linked at least one pollutant in the park well — not benzene — to nearby abandoned grain silos. Geologists eventually eyed Southeast Terminals as a likely source of the benzene contamination, records show.

“The terminals are certainly suspects for the benzene detected in the [Oakwood] well,” one posited in a 2000 email. “The probable path is deep ground water.”

Another noted the presence of “a possible plume (with benzene) moving by Oakwood … and within a few hundred feet of the [park]’s former well, [thus] too close for comfort for a public-water supply well.”

Two years later, EPD investigators were still documenting high levels of benzene, ranging from 8,000 to 12,000 ppb, on terminal property — as well as the likelihood that, one 2002 EPD memorandum states, “the benzene contamination found in the trailer park well came from the Southeast Terminals.”

Ultimately, though, the state’s two-year, nearly $200,000 investigation yielded few answers. By 2008, groundwater monitoring results revealed only trace amounts of benzene at Oakwood. Today, EPD officials say they lack definitive proof tying the well’s benzene pollution to any source.

For Jill McElheney, the outcome of the inquiry was anything but satisfying. “It just seems to me that when you’ve got benzene in a well and a major source of it next door, you’d make the connection,” she said.

In fact, Jill already had been seeking answers elsewhere. In 2000, she turned to the federal Agency for Toxic Substances and Disease Registry, or ATSDR, petitioning it for a public health assessment. Instead, the agency launched a less-thorough public health consultation, meant to ascertain the risk to human health posed by the contaminated well water at Oakwood.

The results brought little clarity. In a 2001 report, the ATSDR determined that “the groundwater contaminant plume” initially sampled in the Oakwood well “is a public health hazard.” At the same time, it singled out a pollutant other than benzene as the threat. For benzene, the agency found that “the likelihood someone would get cancer as a result of their exposure is very low.”

In a 2000 draft filed with the state, however, the ATSDR concluded that the highest concentrations of benzene in the water were of concern. “This risk DOES exceed an acceptable risk level,” the draft states, “and may result in an elevated risk of cancer for exposed individuals.”

An ASTDR spokeswoman did not respond to requests for comment.

Mounting evidence on benzene and leukemia

The science linking benzene to cancer — particularly leukemia, in all its forms — has preoccupied the petrochemical industry for more than half a century. As far back as 1948, the API’s toxicological profile of the chemical discussed “reasonably well documented instances of the development of leukemia as a result of chronic benzene exposure,” cautioning that “the only absolutely safe concentration … is zero.”

Later, as scientific evidence of benzene’s hazards accumulated and regulatory limits on workplace and environmental levels tightened, the industry took a different stance. By 1990, the API and member companies such as BP, Chevron, Mobil and Shell had launched a research program meant to keep further restrictions at bay — or, minutes from an API meeting in 1992 state, research “that will be most useful in improving risk assessment and influencing regulation.”

Within months, the API task force overseeing the program was enumerating “developing issues.” Topping its list, according to minutes from a meeting in 1993, was this notation: “link to childhood leukemia?”

That possible link appeared on the industry’s radar again in 2000, documents show. At the time, API representatives were drumming up financial support for an unparalleled study of workers exposed to benzene in Shanghai, China, delivering what amounted to a sales pitch for the project. They touted what one 2000 API overview described as its “tremendous economic benefit to the petroleum industry” — helping to combat “onerous regulations” and “litigation costs due to perceptions about the risks of even very low exposures to benzene.” Childhood leukemia was mentioned explicitly.

Five years later, industry representatives grew concerned enough to bankroll their own research. Documents show the API task force approved funding for what minutes of one meeting in 2005 dubbed a “benzene regulatory response,” comprising a “childhood leukemia review” and “child-to-adult sensitivity to benzene” analysis, for a total of $30,000.

By then, the scientific evidence on benzene and leukemia in adults was well-established. Throughout the 1960s and early 1970s, studies of Italian shoe and leather workers indicated a relationship between the chemical and the cancer. Then, in 1977, the National Institute for Occupational Safety and Health, part of the Centers for Disease Control and Prevention, launched a seminal study of two Goodyear plants in Ohio that made Pliofilm, a thin rubber wrap. The research quantified for the first time the leukemia risk for workers exposed to benzene, prompting OSHA to work on a stricter standard that took effect in 1987.

In years since, the science has solidified. Recent research has shown lower and lower levels of the chemical — less than the OSHA limit of 1 part per million — can cause leukemia as well as other blood and bone marrow disorders.

By contrast, experts say, the research on benzene and childhood leukemia isn’t as conclusive. Multiple studies have indicated that children whose mothers were exposed to benzene-containing solvents during pregnancy experience elevated risks of developing the disease. Others have shown that children living near gas stations or highways — breathing in benzene in the air — face heightened risks. One 2008 study reported a significant spike in the rate of the disease in Houston neighborhoods with the highest benzene emissions.

Taken together, the nearly four dozen publications on the topic strongly suggest the carcinogen can cause leukemia as much in children as adults, experts say.

“Children aren’t another species,” said Infante, the former OSHA official who has reviewed the scientific literature for medical associations and governmental agencies. “If benzene causes leukemia in adults, why wouldn’t it cause leukemia in children?”

The scientist behind the API-commissioned analysis would likely disagree. In 2009, David Pyatt, a Colorado toxicologist with long-standing ties to the petrochemical industry, published a journal article about his review, in which he reported examining 236 studies on the relationship between benzene and childhood leukemia. Many of the studies suggesting a link “suffer from the same limitations,” he concluded, such as poorly quantified exposure estimates.

“At this point,” Pyatt wrote, “there is insufficient epidemiologic support for an association or causal connection between environmental benzene exposure … and the development of childhood [leukemia].”

Some say the review reflects a common industry tactic: Compile studies on a subject, and then shed doubt on each one by claiming the data aren’t good enough.

Pyatt did not respond to repeated emails and phone calls from the Center seeking comment; nor did the API.

In depositions, Pyatt acknowledged that he has never testified for a plaintiff in a benzene exposure case. He has worked as a consultant and defense expert for such petrochemical giants as BP, ConocoPhillips, ExxonMobil and Shell, he has said; the API has financed additional work of his on benzene, as has the American Chemistry Council, the chemical industry’s main lobby.

In a deposition taken last year, Pyatt said he wouldn’t discount benzene’s link to childhood leukemia — at least, not to acute myeloid leukemia, or AML, a type rarely found in children.

“There is no reason to think that [children] are going to be protected,” he testified. “So I would certainly think that a child can develop AML if they are exposed to enough benzene.”

In other depositions, Pyatt has conceded no link between benzene and ALL, the type that attacked Jarrett McElheney.

‘They have to stop this practice’

For the McElheneys, the extent of the benzene contamination from Southeast Terminals only came to light years after Jarrett’s chemotherapy regimen had beaten back his leukemia. Yet state and federal enforcement records pinpoint on-site releases of the chemical in 1991, a year before the family moved to the area. At the time, managers of the terminal — jointly owned and operated by BP and Unocal Corp. — discovered a leak of diesel fuel seeping through soil where an underground pipeline was buried.

Terminal employees removed 40 cubic yards of “petroleum contaminated soils,” according to a report filed by BP with the state, and recorded benzene on site at levels as high as 81 ppb. Groundwater samples showed even higher concentrations: 12,000 ppb.

State regulators found such pollution “exceeds our ‘trigger’ levels,” a 1991 letter to the company states, and requested further action.

Under Georgia law, the company was required to develop what the EPD calls a “corrective action plan,” which, among other things, would have delineated the terminal’s benzene plume, as well as identified nearby public water wells.

In a 1991 reply, BP promised the EPD it would file its plan in four months.

Nine years later — after the McElheneys had tested their well water and the EPD had issued a 2000 citation against BP for failing to submit a “timely” corrective action plan — the company finally carried out that requirement, records show.

BP, in charge of the terminal’s daily operations, declined to comment for this article. At different times, Unocal, Louis Dreyfus Energy and TransMontaigne have been BP’s partners at the site. TransMontaigne, its current partner, did not respond to repeated emails and phone calls. TransMontaigne purchased Louis Dreyfus Energy in 1998. Chevron, which merged with Unocal in 2005, declined to comment.

Today, state regulators attribute their own delay in cracking down on the diesel leak to an internal debate over which EPD division had authority over the terminal’s benzene contamination — its underground storage tank program, which has purview over the pipeline; or, its hazardous waste branch. For years, compliance officers in that branch, along with their counterparts at the EPA, had been monitoring the facility’s practice of dumping benzene-laced wastewater on site — a practice later confirmed by terminal employees in court depositions.

In 1990, the EPA issued new rules classifying benzene as hazardous waste and requiring bulk-oil terminals to have permits for discharging the “bottoms water” in petroleum tanks. This wastewater can become tainted by the chemical when mixed with gasoline. Rather than treat the water, Southeast Terminals funneled it through an “oil/water separator” to skim off fuel, and then dumped it into a ditch on the ground.

Company records at the time show that terminal supervisors admitted they drained the wastewater “direct into streams” or “a dike area which eventually drains offsite into a stream.”

“I remember thinking, ‘They have to stop this practice,’” said John Williams, an EPD environmental specialist who inspected the terminal in 1993 and documented the dumping.

Three months later, the EPD issued a notice of violation against Southeast Terminals, forcing supervisors to test the bottoms water. Regulators found benzene at levels four times greater than the legal limit of 0.5 ppb, prompting the EPA to take action.

“We saw an issue there,” said Darryl Hines, of the EPA’s regional office in Atlanta, explaining why officials initiated a 1997 civil enforcement action against the facility.

In its complaint, the EPA accused BP and then-partner Louis Dreyfus Energy of violating federal hazardous-waste law — disposing waste without a permit, and failing to categorize it as hazardous. The agency ordered the companies to shut down the oil/water separator, and implement a plan addressing “any groundwater contamination.”

By the time Jarrett developed leukemia a year later, the EPA had negotiated a settlement with the companies and laid out a series of requirements for cleaning up the benzene. Without admitting fault, BP and Louis Dreyfus agreed to spend at least $100,000 to remove leaking underground pipelines and install above-ground infrastructure. They also paid a penalty of $15,000.

When BP finally filed its long-delayed action plan, it revealed the presence of what EPD project officer Calvin Jones described as a “dissolved hydrocarbon” plume containing benzene — “a bigger problem than we had thought.” The chemical, concentrated at 500 ppb and counting, had spread beyond the immediate spill areas. Of greater concern to regulators, the plan identified “free product” in groundwater.

“There was actually gasoline floating on the water,” explained Jones, of the EPD’s underground storage tank program, who oversaw the facility’s protracted cleanup. Referring to gasoline’s ability to dissolve in water, he said, “You can’t get higher concentrations of benzene … than free product.”

Despite a decade-long cleanup — 35.2 million gallons of contaminated groundwater and 1,009 pounds of benzene were collected — the chemical still saturates much of the nearly 19-acre Southeast Terminals site, records show. Last year, the EPD issued a letter declaring “no further action required,” which released the companies from remediation. At the time, the state-sanctioned benzene count remained at 1,440 ppb.

Over the years, enforcement records show, company consultants and regulators alike have tried to trace the path of the wastewater at the terminal. One company analysis details a trail beginning at the property line and then spilling into adjacent woods before hitting a tributary. Another document, produced by the EPA, depicts the discharge as moving offsite through woods and into a resident’s backyard.

“It’s where the drainage flows,” said Jeffrey Pallas, deputy director of the agency’s hazardous waste division in Atlanta, who oversaw the case against BP and Louis Dreyfus, explaining that the document, complete with photographs, was only intended to verify the hazardous-waste law violations.

“We cannot substantiate from the documentation we have that the benzene left the site,” he said.

Seeking accountability

The McElheneys have seen the evidence they need to connect Southeast Terminals to the benzene in the Oakwood well — and Jarrett’s suffering. They believe all the state and federal enforcement actions have yielded few consequences for the facility’s owners. If Jarrett hadn’t gotten sick, they say, they might never have known about the benzene hazard. “The companies would have paid off their small fines,” Jill said, “and nobody would have been the wiser.”

Seeking some accountability, the family filed a lawsuit three years ago against BP, TransMontaigne and seven other previous owners, alleging that the “illegal discharge and release of toxic chemicals” at Southeast Terminals contaminated the surrounding environment and caused Jarrett to develop leukemia.

In court filings, the companies denied the allegations and dismissed any link between benzene and childhood leukemia. Last year, defense lawyers invoked a familiar tactic: They cited the Pyatt review to support their claims that the chemical couldn’t have caused Jarrett’s illness. The family recently has agreed on a settlement in principle and is working toward resolving the litigation.

“I thought, ‘This is par for the course,’” said Jill, who has read some of the industry documents uncovered by the lawsuit. “The oil industry has fought regulations and lawsuits for workers and adults. Now they’re going to do it with children.”

Jarrett is now a slight, reserved 20-year-old in remission. He remembers his bout with leukemia through a child’s eyes — the “really cool” ambulance rides, the nurses with coloring books, swinging golf clubs in hospital hallways. “I remember being stuck over and over again by needles” while getting a bone-marrow aspiration or a chest catheter or countless blood draws, he said. “But it wasn’t until much later I realized what happened to me didn’t happen to other kids.”

Today, he has had to grapple with cancer’s lasting effects — the feebleness, and the fatigue — as well as its lingering fears. As a leukemia survivor, he is at risk for developing osteoporosis, cataracts, or even another cancer. Sitting in an Olive Garden in Athens, sandwiched between his parents, Jarrett came across as exceedingly shy, uncomfortable in the limelight. Often, his parents did the speaking for him.

Moments earlier, Jill had explained how leukemia had changed her son, taken an emotional toll.

“He had a really loud voice as a toddler but that voice has mellowed,” she said. “I’ll take that voice over anything.”

Maryam Jameel contributed to this story.

Click on the link below to access the original article at the Center for Public Integrity


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Russia Blamed, US Taxpayers on the Hook, as Fracking Boom Collapses

By Ben Ptashnik, Truthout

As Congress removes restrictions on taxpayers bailing out the too-big-to-fail banks, the right is blaming environmentalists and Russia for the demise of the fracking boom. In reality, the banks’ junk bonds and derivatives have flooded Wall Street, and now the fracking bubble threatens another financial crisis.

Collapsing crude oil prices due to oversupply are reaching tsunami proportions, threatening Wall Street banks, investors and a dozen countries, foremost Russia, Iran and Venezuela, where revenue losses have caused severe financial degradation, and economies are about to implode. While Americans are today enjoying $2 per gallon gasoline, Wall Street’s analysts predict that an imminent energy market collapse will bring financial institutions to their knees once again, and taxpayers are being set up for another mandatory bailout.

At the heart of these tectonic shifts in the entire energy sector is the recent expansion of the hydraulic fracturing (fracking) industry, a boom cycle that began in earnest when Congress and the Bush administration passed the Energy Policy Act of 2005, which exempted the new horizontal drilling technology from the Clean Water Act, the Safe Drinking Water Act and the National Environmental Policy Act. By tapping considerable quantities of new oil and gas resources from shale deposits, the fracking boom promised US energy independence, upending the world’s prevailing paradigms around renewable energy and peak oil expectations. Environmentalists fought against the huge Keystone pipeline infrastructure that would deliver the fossil fuels to foreign markets, fearing that exploiting these resources would undermine the struggle for the curbing of carbon emissions.

Fracking also threatened the dominance of Russia and Saudi Arabia as the fossil fuel suppliers of Europe when it became evident that the United States would soon become a net exporter. In the United States, fracking was hyped on Wall Street as a get-rich-quick opportunity, attracting massive capital input, and creating an investment bubble. Bloomberg reported this year that the number of bonds issued by oil and gas companies has grown by a factor of nine since 2004.

“There’s a lot of Kool-Aid that’s being drunk now by investors,” Tim Gramatovich, chief investment officer and founder of Peritus Asset Management LLC, told Bloomberg in an April 2014 article. “People lose their discipline. They stop doing the math. They stop doing the accounting,” he continued. “They’re just dreaming the dream, and that’s what’s happening with the shale boom.”

When gas fracking first popped onto the scene, grandiose claims were made that the United States had 100 years of gas supply in shale, or 2,560 trillion cubic feet. And Wall Street rode that initial estimate. The only downside (beside the environmental disaster left by this toxic industry) was that, like the housing bubble which depended on ever-growing home values to maintain profitability, shale gas wells had to deliver consistent or growing production and profitability to pay back heavy debt interest loans on well driller companies: $3 to $9 million per well. Fracking wells require not just drilling, but also huge injections of energy, water, sand and chemicals to fracture the rocks that hold the oil and gas deposits.

But in fact, no statistical evidence confirmed the hyped claims of a 100-year shale gas supply. In 2011, a study downsized this estimate from 2,560 trillion cubic feet to 750 trillion cubic feet, and by 2013, the US Geological Survey refined that down to 481 trillion cubic feet – less than a 19-year supply based on 2013 rates of production. Nevertheless, huge amounts of capital poured into increasingly marginal operations, and the fracking market was flooded with junk bonds and derivatives as investors piled in.

Meanwhile oil fracking, which is separate from gas fracking, also needed huge injections of capital, but more importantly, oil frackers needed oil prices to stay at $85 a barrel or higher on average to break even. Many of the shale oil wells that have sucked up a huge amount of investment have also turned out to have short lives and their operators required continued infusions of capital to drill new wells to keep afloat, even as prices tumbled due to the glut they themselves created. The Bakken, one of the largest oil fracking plays, is a typical example. It grew exponentially after environmental protections were removed. But since 2008, Bakken has required increasingly larger numbers of wells just to maintain level production and service debt. The industry, already in trouble in 2013, has now endured plunging revenues through a year of oil selling at $60 to $70 per barrel, on average, instead of $90 to $100.

Everyone had expected that in 2014 the Saudis would move to limit supply and maintain stable oil prices by cutting back production, as OPEC has done for decades. But an unexpected shockwave hit the industry in November 2014: The Saudis laid down the gauntlet and announced their intention to continue full production and let oil prices drop.

For the Saudis, this serves two purposes: First, it undermines the expansion of US shale oil by forcing prices down so low that many of the wells have to be shut down or lose money. Second, it punishes their enemy, Iran, whose oil export-based economy has been savaged by the lower prices. The Saudis are sitting pat, with a trillion-dollar war chest savings account accumulated over a decade of $100 per barrel oil. Oil Minister Ali al-Naimi has publicly admitted that the Saudis will wait as long as needed to retain market share, even if prices plunge further.

Falling oil prices will place a huge stress on the world’s junk bond market as energy companies now account for 15 percent of the outstanding issuance in the non-investment grade bond market. The plunge in the prices of crude could trigger a “volatility shock large enough to trigger the next wave of defaults,” according to Deutsche Bank.

This explains why the Obama administration – with complicity of both congressional Democrats and Republicans – managed in the wee hours of the morning to slip a loophole into the supposedly “must-pass” cliff-hanger omnibus budget bill. This toxic Trojan horse, passed in December 2014, now includes a minor footnote provision that might cause taxpayers to pick up the tab on more than a trillion dollars (yes, trillion) if the energy market bubble implodes, which it must if oil stays at half the price it fetched just six months ago.

After last minute, heavy lobbying on the budget bill by Jamie Dimon of JPMorgan Chase and an army of 3,000 Wall Street lobbyists, it appears that once again sufficient insecurity and fear had been spread among the political class regarding destabilization of the financial markets (or withdrawal of campaign financing). They allowed a last minute amendment that killed Dodd-Frank protections, and allowed US taxpayers to be shaken down to cover Wall Street’s shale gambling debacle.

The heavy-handed move by the financial industry has outraged progressives and libertarians alike. It seems that these Wall Street criminals, like junkies attached to their drugs of choice, just could not resist the high of easy cash from Ponzi scheme market bubbles, and so they have stuck it to the US public once again: Preposterously huge bonuses, Porsches, pricey call girls, and million-dollar Manhattan condos were at stake. So hey, why should they kick the habit? After all, not a single one of those con artists went to jail last time.

Wall Street is now flooded with fracking industry derivatives contracts that protect the profits of oil producers from dramatic swings in the marketplace. Derivatives are essentially insurance policies taken out by the oil industry to guard against fluctuations in the cost of fossil fuel supplies. Dramatic swings rarely happen, but when they do they can be absolutely crippling.

Derivatives taken out to ensure prices don’t go down are now creating billions in losses for those who sold such bets on the market; someone is going to have to absorb massive losses created by the sudden drop in oil on the other end of those insurance contracts. In many cases, it is the big Wall Street banks, and if the price of oil does not rebound substantially they could be facing colossal losses.

The big Wall Street banks did not expect plunging home prices to implode the mortgage-backed securities market in 2008, but their current models also did not have $60 oil prices included in projections. The huge losses may send a shock wave into the entire financial industry. It has been estimated that the six largest “too-big-to-fail” banks control $3.9 trillion in commodity derivatives contracts, those same gambling instruments that brought us the 2008 housing collapse. And a very large chunk of that amount is made up of oil derivatives. Combined with the huge flood of shale junk bonds on the market, the derivatives could initiate a bubble burst that could turn into a financial market implosion.

Meanwhile, the global climate change issue and energy market turbulence have morphed into geopolitical tensions over European fracking. Unsubstantiated allegations in a New York Times report by Andrew Higgins claim that the Russians are funding anti-fracking protests to maintain their hegemony over gas markets.

The allegations have infuriated environmentalists and climate justice activists. The last thing they want is to be made scapegoats for the fracking collapse and be played as the neo-Cold War dupes of the Russian empire. But memories of red-baiting suddenly hang in the air as (by seeming coincidence) dozens of right-wing media sites regularly devoted to anti-Soviet slanders or climate change denial immediatelypicked up Higgins’ Times piece, as if on cue.

There are now dozens more of such published reports. Even as the US fracking industry collapses and tensions over control of Ukraine and other former Soviet satellites re-emerge, there seems to be a concerted right-wing effort to label fracking opponents Russian agents.

Vague innuendos dominate this narrative. In the Times piece, for example, former NATO Secretary General Anders Fogh Rasmussen is quoted: “I have met allies who can report that Russia, as part of their sophisticated information and disinformation operations, engage actively with so-called non-government organizations.” Others write, “Some in Sophia believe” or “Those who suspect Russian involvement” or “There’s no smoking gun, yet . . .”

Critics in Romania accused the Times and Higgins of scapegoating environmentalists and acting as partisan players in a renewed Cold War.

“What, exactly, is the grand total of evidence that Russia is financing these anti-fracking protests?” asks American blogger in Romania, Sam C. Roman, in his article, “Pot vs. Kettle,” pointing out that the first anti-Russia allegation came from a politician who owned land that Chevron planned to frack, and is thus losing money from the protests. “Not one allegation against Russia in the entire article is proven by a single document, piece of evidence or other direct proof. All that exists are shadowy insinuations and allegations.” He asserts that accusations by Lithuanian, Romanian and NATO officials against Russia have not yet to be backed up by any proof.

“Add it up,” Roman writes. “You’ve got two former NATO [secretary generals] stumping for Chevron (which competes with Gazprom, a Russian energy company that also conducts fracking operations in Europe) blaming the Russian government for protests. . . . And all of this tied up in a neat little bow by an American journalist who has already been caught publishing anti-Russian propaganda in his newspaper before.”

This all leaves the United States somewhat schizophrenic. On the one hand, the United States and NATO’s foreign policy hawks are delighted by the oil price collapse; it serves to isolate and subdue Russia, expand NATO’s influence in Eastern Europe, and puts pressure on Iran to negotiate on nuclear aspirations. Not to mention that with gasoline at $2 per gallon, consumer spending and economic growth will be enhanced. The US economy grew by a comparatively robust 5 percent in the third quarter of 2014.

According to an article by Larry Elliott in The Guardian, “Stakes Are High as US Plays the Oil Card Against Iran and Russia,” the price drop was an act of geopolitical warfare by the United States, administered by the Saudis. Elliott suggests that US Secretary of State John Kerry allegedly struck a deal with Saudi Arabia’s King Abdullah in September. That might explain how oil prices dropped during the crisis caused by Islamic State in Iraq and Syria, which would normally have caused prices to rise.

It would also explain why the Obama administration allowed the financial industry the amendment to Dodd-Frank that effectively exempts financial institutions from liability associated with derivatives. Though shale derivatives were not specifically mentioned by the Wall Street lobbyists as they pressured their allies in Congress and the White House, it is becoming increasingly clear that the too-big-to-fail banks were beginning to panic as dark clouds gathered on the horizon in the shale derivatives trade.

Most bank customers and voters don’t know that Congress has already written into finance regulations that, in the case of insolvency, financial institutions could grab the assets of depositors and “bail-in” – which means they can save themselves from their losses in gambling operations at their investment divisions by grabbing cash assets of depositors, even those that are FDIC guaranteed, and legally convert them to bank stocks. That means that in the event of another market crash, Chase and Citi could take their depositors’ cash in savings accounts or CDs, and give the customers back a bank stock certificate (of questionable value) instead.

There are also those who scratch their heads and ask, “Why did the TBTF banks push for a deletion of the Dodd-Frank provision now, instead of waiting for the friendlier Republican-controlled Congress to pass this legislation?” The only answer that seems to make sense, and explain their urgency, is that the collapse is imminent.

In the 1990s dot-com craze, every new Silicon Valley start-up company was advertised as the next Microsoft. What followed was the crash of 2000, when the NASDAQ dropped 4,000 points (80 percent) in months. This chart below is what the crash looked like in 2000 to 2002 after the market had reached 5,000 (almost exactly where it stands today).

Having learned their lesson well from the last bailout, and knowing that they will have a much harder time coming to Congress hat-in-hand after a collapse, the TBTF banks probably decided not to wait, pushing their minions in the Beltway to inoculate them as soon as possible from the potential market explosion.

In the meantime, they were probably dumping their own stocks on unsuspecting investors. Based on year-end reports for March 31, 2014, for 127 major oil companies, cash input for the fracking industry was $677 billion, while revenues from operations only totaled $568 billion – a difference of almost $110 billion. And this was before the price of oil started dropping six months ago.

In three out of seven major fracking fields in North America, companies are already reporting losses, with closures particularly acute in Canada. It’s not clear whether economists fully appreciate what’s about to transpire. This decline in rig count is just the beginning. Perhaps the end will come as early as this winter or spring, as fiscal reports for 2014’s fourth quarter are published, operations shut down, crews are laid off, and many unprofitable oil and gas rigs are mothballed.

So, whom will the banks, brokers and investors scapegoat for this upcoming crash? Some predict that they will likely use every available media outlet to blame community activists, Democrats and Obama for stopping the Keystone pipeline and for opposing the fracking industry. And as in the climate change denier movement, the narrative will probably use “communist” and “socialist” rhetoric, which is why the Russian card is so important to play: Hence the Higgins article.

The pundits on Fox will likely play on the patriotism of the right and use their Big Lie ploy (say something enough times, it becomes the truth) to the hilt. Six months from now, while studiously avoiding mention of our “allies,” the Saudis, or the Wall Street banks, they will likely be vociferously defending those poor “beleaguered US oilmen” who could have made our country strong and independent again in energy, but were broken by the Democrats and those “commie environmentalists” working for Putin. The market crash will be blamed on the “climate hoax.”



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Amputated Lives – Coping with Chemical Sensitivity by Alison Johnson

Four cataclysmic events have rocked the United States in the last two decades: the 1989 Exxon Valdez oil spill, the 1991 Gulf War, the destruction of the World Trade Center in 2001, and Hurricane Katrina in 2005. At first glance, these events might seem to have little in common, but all left in their wake significant numbers of people who are now chronically ill after exposure to large amounts of toxic chemicals. Some were volunteers or held jobs that left them little choice; some were just in the wrong place at a very wrong time. Hundreds of thousands of Americans became the “designated fall-guys,” finding themselves on the front lines of wars or natural disasters. During the cleanup operations in Alaska, at Ground Zero, and in the New Orleans area, thousands of people stepped forward to remove toxic substances in an effort to enable the pristine waters of Prince William Sound, the world’s financial hub in Lower Manhattan, and the jazz capital of America to return to at least some semblance of normalcy.

Regrettably, the national attention span is short. The sick workers who helped clean up the oil from the Alaskan beaches are not on anyone’s radar screen. Two whom I interviewed were coughing so hard because of the asthma they had developed after cleaning the beaches that we could hardly continue the conversation. In November 2000, the American Journal of Epidemiology published a study showing that 34 percent of those who served in the Gulf War–over 200,000 veterans–are now chronically ill. The young men and women who answered their country’s call to serve on what has been termed the most toxic battlefield in history have felt abandoned for over seventeen years.

Then there are the heroes who responded to the World Trade Center disaster. Slogans on bumper stickers and in store windows throughout New York proclaimed that the 9/11 heroes would never be forgotten. Now most feel they have indeed been forgotten as their health deteriorates and they lose their jobs and the medical insurance that went with those jobs. In the case of Katrina, neglect has been even more evident, and little has been done to acknowledge the widespread exposure to toxic chemicals and mold encountered by residents and cleanup workers.

Large numbers of people who became chronically ill after these major exposure events have developed a new sensitivity to the chemicals they encounter in everyday life in substances like perfume, paint, gasoline, cigarette smoke, diesel exhaust, new carpet, cleaning products, and air fresheners. . . .

To access additional information click on the link below.

Amputated Lives – Coping with Chemical Sensitivity by Alison Johnson

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Gulf Oil Spill Dispersants

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This is public info and not under copyright!  
Training Marine Oil Spill Response Workers under OSHA’s Hazardous Waste Operations and Emergency Response Standard

U.S. Department of Labor

Occupational Safety and Health Administration

OSHA 3172

About this Booklet

This informational booklet is intended to provide a generic, non-exhaustive overview of a particular standards-related topic. This publication does not itself alter or determine compliance responsibilities, which are set forth in OSHA standards themselves and the Occupational Safety and Health Act. Moreover, because interpretations and enforcement policy may change over time, for additional guidance on OSHA compliance requirements, the reader should consult current and administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the Courts.

Material contained in this publication is in the public domain and may be reproduced, fully or partially, without permission of the Federal Government. Source credit is requested but not required.

This information will be made available to sensory impaired individuals upon request. Voice phone: (202) 693-1999 Teletypewriter: (TTY) 1-877-889-5627 See also OSHA’s Website at http://www.osha.gov

How Marine Oil Spill Responses Are Organized and Managed
Applying the HAZWOPER Standard to Marine Oil Spills
Hazards to Marine Oil Spill Responders
Training Requirements
Oil Spill Scenario
Other Sources of OSHA Assistance
Appendix A: Related OSHA Standards and Directives
Appendix B: Related OSHA Publications
Appendix C. OSHA Offices
Footnote Figures and Tables
Figure 1. Training Decisions Flowchart for Emergency Response Workers
Figure 2. Training Decisions Flowchart for Post-Emergency Response Cleanup Workers
Figure 3. Sample Certifications
Figure 4. Illustration of Incident
Table 1. Hazardous Chemicals and Their Effects
Table 2. Training for Workers Who Perform Emergency Response
Table 3. Training for Workers Who Perform Only Post-Emergency Response
Table 4. Training Topics and Competency Areas


This booklet, written for marine oil spill response employers,* describes the training your employees need under HAZWOPER, the Hazardous Waste Operations and Emergency Response standard, Title 29 of Code of Federal Regulations (CFR) 1910.120. The Occupational Safety and Health Administration (OSHA) published HAZWOPER to protect workers involved in hazardous substance emergency response and cleanup operations.

Not every spill response worker needs the same amount of training. The type of training you give your workers depends on how close they will be to a spill and what role they will have in stopping, containing, or recovering the spilled material from the release. For example, if you have workers who control an oil spill early in an incident, they need more training than workers who simply warn others about a spill. This booklet explains how HAZWOPER training requirements apply to the range of workers who participate in marine oil spill response. To use this guidance effectively, you need to know the duties you expect your workers to perform and the exposure conditions under which you would allow them to work. You must train your workers to the highest level of skill, responsibility, and exposure that you will assign them.

This booklet was prepared by Office of Health Enforcement in conjunction with the U.S. Coast Guard Office of Response.

*Oil spill response accounts for the majority of marine spill response operations and is the focus of this pamphlet. HAZWOPER training, however, is required for all marine spill response operations conducted under the National Contingency Plan. The training you provide must cover the range of hazardous substance spills you expect your marine response employees to handle.

How Marine Oil Spill Responses Are Organized and Managed

Marine oil spill response is organized and managed according to the regulations found in 40 CFR 300, the National Oil and Hazardous Substance Pollution Contingency Plan (NCP). These regulations describe procedures for responding to hazardous substance releases and oil discharges. Appendix E of the regulation specifically addresses oil spill response. The U.S. Coast Guard (USCG) and the Environmental Protection Agency (EPA) jointly led the development of the NCP.

Marine oil spill response involves a network of government agencies, community organizations, industry groups, and contractors. Federal and/or state agencies usually monitor the responsible party (generally the owner or operator of the vessel, facility, port, or pipeline involved in the spill). The Federal Government can direct cleanup operations if the responsible party does not respond adequately, is not capable of taking action, or is unknown.

An On-Scene Coordinator (OSC) acts as the leader for response activities. In the coastal areas of the United States, USCG serves as the OSC for oil spill responses. In inland areas, including rivers and other inland waters, EPA generally takes the lead.

HAZWOPER requires that a senior official who is present at the response site, an Incident Commander, lead an emergency response operation. For marine oil spills, the ranking Coast Guard officer or EPA official at the spill scene usually functions as the On-Scene Incident Commander. The emergency response remains in effect until the Incident Commander declares it completed.

OSHA is responsible for assuring safe and healthful working conditions for working men and women. During marine oil spill response, OSHA provides advice and consultation at the request of other government agencies. If necessary, OSHA uses enforcement action to assure that workers are properly protected.

Emergency Response vs. Post-Emergency Response

The HAZWOPER standard identifies two basic phases of a response action: emergency response and post-emergency response. Depending on the size of the spill, these phases may be managed differently. In addition, workers who participate ONLY in post-emergency response require different training than emergency response workers receive.

Emergency response is “a response effort…to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance” (29 CFR 1910.120(a)(3)). For marine oil spills, an uncontrolled release is a situation in which the oil and its associated airborne and surface contamination hazards are releasing into the environment or are in danger of releasing into the environment and posing a worker exposure hazard. Oil in grounded ships, which is in danger of being released into the environment, represents an emergency response situation. Onwater containment, skimming operations, and underwater oil recovery operations also are considered to be emergency response activities because the oil is still in danger of being released into the environment. Shoreline cleanup is normally considered to be a post-emergency response unless the oil is below the high-tide mark or storm surge boundary (active or forecasted) and can reasonably be expected to be re-released into the marine environment.

Post-emergency response is performed “after the immediate threat of a release has been stabilized or eliminated and cleanup of the site has begun” (29 CFR 1910.120(a)(3)). Oil spilled into a marine environment is considered to be stabilized when it is in a stable container with no compromised structural integrity, to limit the potential for worker exposure to associated hazards. This includes floating bladders, barges, drums, and roll-off containers on shore. Oil also is considered to be stabilized when it is stranded on shore and not reasonably expected to rerelease into the environment through wave or storm effects. Floating oil is not considered to be stabilized, even if contained within a boom.

During response to a large release such as a marine oil spill, emergency response and postemergency response cleanup activities may occur at the same time. In these cases, the boundaries between the emergency response area and the post-emergency response area must be well defined and explained to responders and cleanup workers.

Applying the HAZWOPER Standard to Marine Oil Spills

HAZWOPER Requirements that Apply to Marine Oil Spills

The NCP defines oil as any kind of oil in any form, including petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes but not dredged spoil (dirt or rock).

Response actions conducted under the NCP must comply with the provisions of HAZWOPER. You’ll find this requirement in 40 CFR 300.150. Therefore, if your workers are participating in a response action under the NCP, you must have an occupational safety and health program consistent with HAZWOPER and you must train your workers according to HAZWOPER’s training requirements. This applies whether the responsible party or a government agency is directing the cleanup.

For marine oil spill emergency response, the HAZWOPER provisions that most directly apply include:
Emergency response operations in HAZWOPER paragraph (q), and
Post-emergency response cleanup operations in paragraph (q)(11).
See also emergency response training provisions in paragraph (q)(6), and post-emergency response training requirements in paragraph (q)(11).

When HAZWOPER Does Not Apply

The NCP defines oil as any kind of oil in any form, including petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes but not dredged spoil (dirt or rock.)

HAZWOPER does not apply to incidental releases that are limited in quantity and pose no safety and health threat to employees working in the immediate vicinity of the spill. These oil spills can be absorbed or controlled at the time of the release by employees in the immediate vicinity. The difference between emergency spills and incidental releases is described in the definition of emergency response in HAZWOPER paragraph (a)(3). An incidental release does not have the potential to become an emergency within a short time. If an incidental release occurs, employers do not need to implement HAZWOPER.

HAZWOPER Coverage for Volunteers

Volunteers frequently participate in marine oil spill response, but Federal OSHA standards do not cover uncompensated workers. In states approved to manage their own occupational health and safety program (called OSHA state plan states), volunteers are often covered under state plan HAZWOPER requirements. In states administered by Federal OSHA, volunteers are covered by the EPA HAZWOPER standard (40 CFR 311). EPA’s HAZWOPER standard has identical requirements, but the coverage is different from Federal OSHA standard coverage. The EPA standard covers local and state government employees, both compensated and volunteers.

Hazards to Marine Oil Spill Responders

Marine oil spill responders face a variety of health and safety hazards, including fire and explosion, oxygen deficiency, exposure to carcinogens and other chemical hazards, heat and cold stress, and safety hazards associated with working around heavy equipment in a marine environment. A full discussion of these hazards is beyond the scope of this training booklet, but a brief list of hazards and their known health consequences is shown in Table 1. Your workers should be trained to anticipate and control exposure to the hazards associated with their assigned duties.

To determine acceptable levels of exposure and train your workers about them, consult OSHA’s exposure limits in Subparts G and Z. If OSHA does not regulate an exposure of concern, consult the National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limits (RELs) and Immediately Dangerous to Life and Health (IDLH) levels. If neither OSHA nor NIOSH has established a limit, consult the American Conference of Government Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs) for chemical, physical, and biological agents. You may use a more protective limit than OSHA’s if one has been established and plan your controls accordingly. Material Safety Data Sheets from the product manufacturer may provide useful information for worker training.

Additional Hazards Marine oil spill responders need training to work safely around these and other potential hazards. You should decide which hazards apply to your operations.
Biological (e.g., plants, animals, insects, remediation materials)
Slips and Trips
Biohazardous debris (e.g., syringes on shoreline)
Ergonomic Stresses (e.g., repetitive strain, low back pain)
Confined Spaces
Underwater Diving
Unguarded Equipment
Vehicles (e.g., aircraft, boats, cars, trucks)
Cutting and Welding
Fire and Explosion
Heat or Cold Stress
In-Situ Burning Particles
Other OSHA standards apply to marine oil spill response and cleanup operations. See Appendix A, Related OSHA Standards.

Table 1. Hazardous Chemicals and Their Effects

Hazardous Chemicals – Adverse Health Effects

Benzene (crude oils high in BTEX, benzene, toluene, ethylbenzene, and xylene) – Irritation to eyes, skin, and respiratory system; dizziness; rapid heart rate; headaches; tremors; confusion; unconsciousness; anemia; cancer

Benzo(a)pyrene (a polycyclic aromatic hydrocarbon reproductive [see below], formed when oil or gasoline burns) – Irritation to eyes and skin, cancer, possible effects

Carbon dioxide (inerting atmosphere, byproduct of combustion) – Dizziness, headaches, elevated blood pressure, rapid heart rate, loss of consciousness asphyxiation, coma

Carbon monoxide (byproduct of combustion) – Irritation to eyes, skin, and respiratory Dizziness, confusion, headaches, nausea, weakness, loss of consciousness, asphyxiation, coma

Ethyl benzene (high in gasoline) – Irritation to eyes, skin, and respiratory system; loss of consciousness; asphyxiation; nervous system effects

Hydrogen sulfide (oils high in sulfur, decaying plants and animals) – Irritation to eyes, skin, and respiratory system; dizziness; drowsiness; cough; headaches; nervous system effects

Methyl tert-butyl ether (MTBE) (octane booster and clean air additive for gasoline, or pure MTBE) – Irritation to eyes, skin, and respiratory system; headaches; nausea; dizziness; confusion; fatigue; weakness; nervous system, liver, and kidney

Polycyclic aromatic hydrocarbons (PAHs) (occur in crude oil, and formed during burning of oil) – Irritation to eyes and skin, cancer, possible reproductive effects, immune system effects

Sulfuric acid (byproduct of combustion of sour petroleum product) – Irritation to eyes, skin, teeth, and upper respiratory system; severe tissue burns; cancer

Toluene (high BTEX crude oils) – Irritation to eyes, skin, respiratory system; fatigue; confusion; dizziness; headaches; memory loss; nausea; nervous system, liver, and kidney effects

Xylenes (high BTEX crude oils) – Irritation to eyes, skin, respiratory system; dizziness; confusion; change in sense of balance; nervous system gastrointestinal system, liver, kidney, and blood effects

Training Requirements

HAZWOPER training requirements that apply to marine oil spill emergency response are located in 29 CFR 1910.120(q)(6). Requirements and training guidance for post-emergency response are in HAZWOPER paragraph (q)(11) and in OSHA Instruction CPL 02-02-051, Inspection Guidelines for Post-Emergency Response Operations Under 29 CFR 1910.120. The HAZWOPER training requirements are based on your workers’ assigned duties during an oil spill. For example, if you have deck hands who are assigned to equipment decontamination during and after an oil spill, you need to provide the level of HAZWOPER training required for the duties and hazards of the decontamination tasks.

Figures 1 and 2 comprise a training decision flowchart. Begin at the top of the chart (Figure 1) if your workers participate in emergency response. Begin at Figure 2 (indicated by the arrow) if your workers perform cleanup only after the release is stabilized (post-emergency). Emergency response workers may perform cleanup activities without further HAZWOPER training if you can certify that they have the skills and knowledge to do so safely.

After you determine the type(s) of training your workers need, turn to Table 2 or 3, as indicated on Figure 1. These tables show each type or category of training described in the flowchart. Table 2 contains the emergency response training requirements. For each type of emergency response training shown in the flowchart, Table 2 lists the specific HAZWOPER training requirements and examples of corresponding oil spill job functions.

Table 3 shows post-emergency response training. In the left-hand column, you’ll find the hazard characteristics that distinguish each type of training because this is how the HAZWOPER standard itself separates cleanup training categories. Verify that the hazards your workers might face fit within the training category you’ve chosen. Table 3 also lists the HAZWOPER training requirements and examples of job functions that might require that training.

Training Content

Because workers need to be trained before they respond, you should train your emergency response workers to the highest level of responsibility they might need to assume. You should train your cleanup workers to the highest exposure conditions they may encounter. You must never expect or allow your workers to perform an emergency response or cleanup operation without proper training and certification.

Table 4 lists training topics and competencies for categories of training described in Tables 2 and 3. The listed topics paraphrase the HAZWOPER required competencies listed in paragraphs (q) and (e) of the standard. As an example, if your workers perform defensive actions for all emergency response operations, they need 8 hours of training in areas 31-36 and competency in areas 25-30 on Table 4. This is equivalent to HAZWOPER requirements for the first-responder operations level in (q)(6)(ii) of the standard.

Certifying and Updating Training

Workers who receive HAZWOPER training must receive a written certificate when they successfully complete the training. This is a requirement of paragraphs (e)(6) and (q)(6). Figure 2, Sample Certifications, illustrates examples of training certification cards given to workers completing various levels of HAZWOPER training. You do not need to repeat the initial training if the worker goes to work at a new site. The worker must have additional training or site briefings, however, that are needed to work safely at the new spill incident or cleanup site. Every year, your emergency responders and cleanup workers must receive refresher training to maintain and demonstrate competency.

Note that Tables 2, 3, and 4 clarify HAZWOPER training requirements. You cannot use these tables as a substitute for the language of the regulation. Also, training required by other OSHA standards that may also apply to your employees is not discussed in this booklet.

For information about the acceptability of various technology-based training formats, see OSHA letters of interpretation on OSHA’s website at: http://www.osha.gov.

Oil Spill Scenario

This scenario is not intended to represent a typical marine oil spill. It illustrates levels of training needed for several job functions and hazardous exposure levels. Information in parentheses refers to the training levels in the Figure 1 flowchart.


A tugboat is pushing a barge loaded with a sour crude that contains sulfur, benzene, toluene, and xylene to an anchorage for lightering (See Figure 4). The anchorage is within sight of the local Coast Guard Marine Safety Office. Contractor resources also are located in the port within view of the anchorage. The tug pushing the barge miscalculates the turning radius, causing the barge to collide with the stern of a tank vessel. The vessels lock together. As a result, two of the barge’s port cargo tanks are breached, releasing several thousand gallons of crude oil into the water. Prevailing winds and currents carry the oil away from the vessels. Some oil is trapped between the barge and the tank vessel.

It is midday on a sunny summer day. The wind is 5 knots. The water temperature is around 70 degrees Fahrenheit. Air temperature is around 84 degrees Fahrenheit.


Members of the tug crew immediately notify the Coast Guard of the incident (Figure 1: First Responder Awareness Level).

The tug and tank vessel crews remain with their vessels to ensure control of their ships. Vapors from the fresh oil begin to irritate the eyes of the captains and the crews. Both captains order crew members to remain upwind of the oil and avoid the area between the vessels where the oil is trapped.

Initial Emergency Response

The owner of the barge is located across the country. According to the company’s emergency response plan, the owner calls an Oil Spill Removal Organization (OSRO) to clean up the spill. The tug captain is designated by the owner to be the company’s representative. Because the owner is not on-scene and does not participate in spill response activities, he is not required to have HAZWOPER training. The tug captain is on-scene making decisions in the response. Therefore, the tug captain must have Incident Commander training for emergency response (Figure 1: Incident Commander).

The Coast Guard radios the tug captain to confirm the oil type, the same type listed on the cargo manifest faxed by the owner. The owner also faxes the cargo manifest to the OSRO. The Coast Guard uses references and advice from federal health professionals to estimate a safe distance from the spill.

After consultation with references, mathematical computer models, and federal health and safety professionals, the Coast Guard creates a safety zone around the spill and uses its boats to enforce it (Figure 1: First-Responder Operations Level).

The safety zone is conservatively large to maximize public safety. Support staff, news media, and other workers who will have no exposure to hazardous substances (Figure 1: Workers unlikely to be exposed over limits) will use the safety zone.

Initial Assessment

An hour after the initial oil release, two OSRO boats approach the spill from downwind to characterize the plume and determine the release zone boundaries. Their crews will monitor exposure levels using air-monitoring equipment (Figure 1: Hazardous Materials Technician or Specialist). Because exposure to hydrogen sulfide and benzene is expected, these responders must wear self-contained breathing apparatus (SCBA) while confirming estimated exposures. They may be able to switch to airpurifying respirators after the assessment.

They continue monitoring as the OSRO boats approach the spill until reaching permissible exposure limits. The boats work around the spill area to identify the limits of the High Exposure zone caused by vapors escaping the oil. Colorimetric tubes confirm air concentrations of 0.5 ppm of benzene and 4 ppm hydrogen sulfide at 200 feet (61 meters) downwind of the slick and 100 feet (30 meters) across the widest part of the plume.

The responders complete site characterization in areas where oil could be trapped between vessels, beneath piers, and in dock corners and other bounded spaces.

Outside the high exposure zone (the hot zone), workers prepare deflection and exclusion booms to divert the oil to a recovery site (Figure 1: First-Responder Operations Level).

The response team sets up a command center to coordinate response and cleanup activities. This area supports the Incident Commander, (Figure 1: Incident Commander), supervisors of the clean-up crews (Figure 1: Managers/Supervisors) with hourly requirements dependent on exposure, and other personnel (training depends on duties and exposures).

Mechanical Recovery

Four hours have passed. Air measurements of hydrogen sulfide, benzene, toluene, and xylene, taken with colorimetric tubes, register well below permissible exposure limits near the leading edge of the slick. An industrial hygienist and a marine chemist conduct a more detailed site characterization using advanced air-monitoring equipment such as a portable infrared analyzer and portable gas chromatograph (Figure 1a: Hazardous Materials Technician/Specialist, or Specialist Employee, depending on job duties). They confirm that the air exposures from the oil slick are below permissible limits. Air concentrations are above permissible limits, however, near oil trapped between the vessels and oil remaining in the damaged tanks.

Oil recovery skimmers arrive to skim free-floating oil. Containment boom and skimmer operators work from a boat. These operators wear goggles and protective clothing because the oil could irritate their skin and eyes. Because air concentrations are below permissible limits, operators are not required to wear respirators (Figure 1: First-Responder Operations Level).

The ships’ support crews remain upwind of the spill (Figure 1: Skilled Support Personnel or Figure 1: Workers unlikely to be exposed over limits).

Shoreline Cleanup

Six hours have passed. Oil reaches the shoreline. Skimmers near the shore remove oil that was deflected into recovery areas (Figure 1: First-Responder Operations Level, if these workers also participate in emergency response; or Figure 1: Workers unlikely to be exposed over limits, if these workers perform cleanup only).

The oil continues to irritate skin and eyes, so workers cleaning the shoreline wear chemical protective clothing, gloves, booties, and goggles. Because of the increased clothing requirements, site safety officer assistants begin monitoring for heat stress (Figure 1: Skilled Support Personnel or Figure 2: Workers unlikely to be exposed over limits, depending on the assistants’ job duties).

Responders form decontamination lines at each shoreline cleanup area. Each worker decontaminates before a break period and at the end of the shift. Workers dispose of outer booties, wash or remove oiled clothing, dispose of outer gloves, wash goggles and remove inner gloves. To minimize the spread of contamination, workers conduct their own decontamination while a worker stands by to assist. The decontamination assistants take responsibility for maintaining and dismantling the decontamination line (Figure 2: Workers unlikely to be exposed over limits, if these workers perform cleanup operations only).


A skimming team recovers oil trapped between the vessels. Vessel personnel in SCBAs measure chemical and oxygen concentrations and the percentage of the lower explosive limit (LEL) for the space between the vessels (Figure 1: Hazardous Materials Technician/Specialist, or Specialist Employee, depending on job duties). Results of the monitoring indicate that workers conducting skimming operations must also be in SCBA. The workers decide to wait until exposure levels register below permissible limits before removing the oil.

Aboard the barge, a pumping team prepares to pump oil from the damaged cargo tanks into the tank vessel (Figure 1: Hazardous Materials Technician or Specialist). Explosion is a risk during pumping operations, so responders measure the LEL percentage and oxygen concentration throughout the operation. Before starting the pumping operations, workers in SCBAs put vapor recovery systems in place. Once the vapor recovery systems are in place, measured chemical concentration levels drop below permissible exposure limits and workers begin pumping.

Final Stages

Two days later, no free-floating oil remains. Pumping operations are completed. No hazardous chemicals are detected by air-monitoring equipment. The oil is weathered and is no longer an irritant; however, slip and trip hazards persist. Shoreline cleanup operations continue.

No repair facility is located within a reasonably safe distance for transport, so workers conduct initial, temporary repairs for safe sailing. They clean the damaged tanks inside and out before patching and welding them. There is a risk of explosion, oxygen deficiency, and overexposures to chemicals (Figure 1: General Spill Site Worker, if the workers perform cleanup only). Forced ventilation makes the holds safe, and a competent person tests them before the cleaning begins. A marine chemist tests and certifies the areas Safe for Hot Work before cutting and/or welding operations begin.

The company’s site safety and health plan does not cover the disposal of waste containers. Because of this oversight, oiled debris and waste decay in the containers, releasing hydrogen sulfide. A hazardous materials response team removes the contaminated waste from the containers (Figure 1: General Spill Site Worker). A week has passed. To speed removal of remaining debris on shore, training is offered to a team of local volunteers (Figure 2: Workers unlikely to be exposed above limits, and associated footnote). Trained supervisors (Figure 2: Managers/Supervisors of workers unlikely to be exposed above limits, with training level dependent on anticipated exposures) oversee the volunteers. As shoreline cleanup progresses, shoreline clean-up assessment teams begin to verify that shorelines are clean (Figure 2: Workers unlikely to be exposed above limits).

Other Sources of OSHA Assistance

Safety and Health Program Management Guidelines

Effective management of worker safety and health protection is a decisive factor in reducing the extent and severity of work-related injuries and illnesses and their related costs. To assist employers and employees in developing effective safety and health programs, OSHA published recommended Safety and Health Program Management Guidelines (Federal Register 54(16): 3904-3916, January 26, 1989). These voluntary guidelines apply to all places of employment covered by OSHA.

The guidelines identify four general elements that are critical to the development of a successful safety and health management program:
Management leadership and employee involvement,
Worksite analysis,
Hazard prevention and control, and
Safety and health training.

The guidelines recommend specific actions, under each of these general elements, to achieve an effective safety and health program. The Federal Register notice containing the guidelines is available online at http://www.osha.gov.

State Programs

The Occupational Safety and Health Act of 1970 (OSH Act) encourages states to develop and operate their own job safety and health plans. OSHA approves and monitors these plans. There are currently 26 state plan states; 23 of these states administer plans covering both private and public (state and local government) employment; the other 3 states—Connecticut, New Jersey, and New York—cover the public sector only.

The 25 states and territories with their own OSHA-approved occupational safety and health plans must adopt standards identical to, or at least as effective as, the federal standards. Until a state standard is promulgated, OSHA will provide interim enforcement assistance, as appropriate, in these states. A listing of states with approved plans appears at the end of this booklet.

Consultation Services

Consultation assistance is available on request to employers who want help in establishing and maintaining a safe and healthful workplace. Largely funded by OSHA, the service is provided at no cost to the employer. Primarily developed for smaller employers with more hazardous operations, the consultation service is delivered by state governments employing professional safety and health consultants. Comprehensive assistance includes an appraisal of all mechanical systems, physical work practices, and occupational safety and health hazards of the workplace and all aspects of the employer’s present job safety and health program. In addition, the service offers assistance to employers in developing and implementing an effective safety and health program. No penalties are proposed or citations issued for hazards identified by the consultant.

For more information concerning consultation assistance, see the list of consultation projects listed at the end of this publication, or visit OSHA’s website at http://www.osha.gov.

Voluntary Protection Programs (VPPs)

Voluntary Protection Programs and onsite consultation services, when coupled with an effective enforcement program, expand worker protection to help meet the goals of the OSH Act. The three VPPs—Star, Merit, and Demonstration—are designed to recognize outstanding achievements by companies that have successfully incorporated comprehensive safety and health programs into their total management system. The VPPs motivate others to achieve excellent safety and health results in the same outstanding way as they establish a cooperative relationship between employers, employees, and OSHA.

For additional information on VPPs and how to apply, contact the OSHA regional offices listed at the end of this publication.

Training and Education

OSHA’s area offices offer a variety of information services, such as publications, audiovisual aids, technical advice, and speakers for special engagements. OSHA’s Training Institute in Des Plaines, IL, provides basic and advanced courses in safety and health for federal and state compliance officers, state consultants, federal agency personnel, and private sector employers, employees, and their representatives.

The OSHA Training Institute also has established OSHA Training Institute Education Centers to address the increased demand for its courses from the private sector and from other federal agencies. These centers are nonprofit colleges, universities, and other organizations that have been selected after a competition for participation in the program. They are located in various parts of the U.S.

OSHA also provides funds to nonprofit organizations, through grants, to conduct workplace training and education in subjects where OSHA believes there is a lack of workplace training. Grants are awarded annually. Grant recipients are expected to contribute 20 percent of the total grant cost.

For more information on grants, training, and education, contact the OSHA Training Institute, Office of Training and Education, 1555 Times Drive, Des Plaines, IL 60018, (847) 297-4810. For further information on any OSHA program, contact your nearest OSHA area or regional office listed at the end of this publication.

Electronic Information

Internet—OSHA standards, interpretations, directives, and additional information are now on the World Wide Web at http://www.osha.gov.

CD-ROM—A wide variety of OSHA materials, including standards, interpretations, directives, and more, can be purchased on CD-ROM from the U.S. Government Printing Office. To order, write to the Superintendent of Documents, P.O. Box 371954, Pittsburgh, PA 15250-7954 or phone (202) 512-1800. Specify OSHA Regulations, Documents and Technical Information on CD-ROM (ORDT), GPO Order No. S/N 729-013-00000-5. The price is $46 per year ($57.50 foreign); $17 per single copy ($21.25 foreign).


For life-threatening situations, call (800) 321-OSHA. The teletypewriter (TTY) number is (877) 889-5627. Complaints will go immediately to the nearest OSHA area or state office for help. For further information on any OSHA program, contact your nearest OSHA area or regional office listed at the end of this publication.

Appendix A: Related OSHA Standards and Directives

OSHA standards, interpretations, and directives are available online at http://www.osha.gov

To review the complete report click on the link below.

Training Marine Oil Spill Response Workers under OSHA’s Hazardous Waste Operations and Emergency Response Standard

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Gulf Oil Spill Health Hazards

Dr. Michael Harbut, Karmanos Cancer Institute
Dr. Kathleen Burns, Sciencecorps

Many people will be exposed to airborne and waterborne chemicals as a result of the BP Gulf of Mexico spill. It is important to understand the potential toxic effects and take appropriate steps to prevent or reduce exposure and harm.

Crude Oil Fact Sheet

Crude oil contains hundreds of chemicals, comprised primarily of hydrogen and carbon (e.g., simple straight chain paraffins, aromatic ring structures, naphthenes), with some sulfur, nitrogen, metal, and oxygen compounds (see Table D-1 in CDC, 1999 linked below). Crude oil composition varies slightly by its source, but its toxic properties are fairly consistent. Chemicals such as benzene and polycyclic aromatic hydrocarbons (PAHs) are very toxic components of crude oil and of high concern. These and other chemicals are volatile, moving from the oil into air. Once airborne, they blow over the ocean for miles, reaching communities far from the oil spill. They can be noticed as petroleum odors. Those working on the spill and people far from it can be exposed to crude oil chemicals in air.

We have prepared 1 page summaries for the public and for workers. You can download and print them.



Chemicals being applied to the water, such as dispersants, are also of concern. We don’t have chemical composition details at this time, so can’t provide information on health hazards, beyond noting that most are reported to contain petroleum distillates, which pose health hazards when aspirated. See EPA’s summary of oil spill response products (March 2010):

Click to access notebook.pdf


Exposure can occur through skin contact, inhalation of contaminated air or soil, and ingestion of contaminated water or food. These can occur simultaneously. Exposure pathways may result in localized toxicity (e.g., irritation of the skin following contact), but most health effects are systemic because ingredients can move throughout the body. Exposure varies based on the duration and concentrations in contaminated media. Differences may result from location, work and personal activities, age, diet, use of protective equipment, and other factors. Concurrent exposure to other toxic chemicals must be considered when evaluating toxic effects. Some chemicals in crude oil are volatile, moving into air easily, and these can often be detectable by smell.

Basic Physiological Effects

Crude oil is a complex mixture of chemicals that have varying abilities to be absorbed into the body through the skin, lungs, and during digestion of food and water. Most components of crude oil enter the bloodstream rapidly when they are inhaled or swallowed. Crude oil contains chemicals that readily penetrate cell walls, damage cell structures, including DNA, and alter the function of the cells and the organs where they are located. Crude oil is toxic, and ingredients can damage every system in the body:

respiratory nervous system, including the brain
liver reproductive/urogenital system
kidneys endocrine system
circulatory system gastrointestinal system
immune system sensory systems
musculoskeletal system

Damaging or altering these systems causes a wide range of diseases and conditions. In addition, interference with normal growth and development through endocrine disruption and direct damage to fetal tissue is caused by many crude oil ingredients (CDC, 1999). DNA damage can cause cancer and multi-generational birth defects.

Acute Exposure Hazards – brief exposure at relatively high levels

Crude oil contains many chemicals that can irritate the skin and mucous membranes on contact. Irritant effects can range from slight reddening to burning, swelling (edema), pain,and permanent skin damage. Commonly reported effects of acute exposure to crude oil through inhalation or ingestion include difficulty breathing, headaches, dizziness, nausea, confusion, and other central nervous system effects. These are more likely to be noticed than potentially more serious effects that don’t have obvious signs and symptoms: lung, liver and kidney damage, infertility, immune system suppression, disruption of hormone levels, blood disorders, mutations, and cancer.

Chronic Exposure Hazards – long-term exposure at relatively low levels

This type of exposure should be avoided, if at all possible, because the potential for serious health damage is substantial. Chronic health effects are typically evaluated for specific crude oil components (see CDC, 1999), and vary from cancer to permanent neurological damage. They cover a range of diseases affecting all the organ systems listed above.

Susceptible Subgroups

Children are vulnerable to toxic chemicals in crude oil that disrupt normal growth and development. Their brains are highly susceptible to many neurotoxic ingredients. Endocrine disruptors in crude oil can cause abnormal growth, infertility, and other health conditions. Children’s exposures may be higher than adults and can include contaminated soil or sand. Newborns are especially vulnerable due to incompletely formed immune and detoxification systems.

Many people with medical conditions are more susceptible to crude oil toxicity because chemical ingredients can damage organ systems that are already impaired. Specific susceptibilities depend on the medical condition (e.g., inhalation poses risks for those with asthma and other respiratory conditions).

People taking medications that reduce their detoxification ability, and those taking acetaminophen, aspirin, haloperidol, who have nutritional deficiencies or who concurrently drink alcohol may be more susceptible. Some inherited enzyme deficiencies also increase susceptibility (listed in CDC, 1999).

People exposed to other toxic chemicals at work or home may be at higher risk.

Pregnancy places increased stress on many organ systems, including the liver, kidneys, and cardiovascular system. Chemicals in crude oil that are toxic to these same systems can pose serious health risks. Pregnancy also requires a careful balance of hormones to maintain a health pregnancy and healthy baby. Endocrine disruptors in crude oil can jeopardize the hormone balance.

The developing fetus is susceptible to the toxic effects of many chemicals in crude oil. Many cause mutations, endocrine disruption, skeletal deformities, and other types of birth defects.

Personal and Public Protection


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Kids in the Gulf by Alice Shabecoff

As the massive oil slicks from the BP Gulf spill advance upon shores and communities, everyone is worried about the effect on wildlife and the natural environment, but
strangely silent about another unavoidable danger. Substantial harm to the children of the Gulf Coast is now unavoidable.

If you can smell oil in the air, as is now reported, that means the chemicals are in the air, and can be inhaled. Parents who are helping to mop up the oil (often, we’ve heard, without even being given gloves) will bring these chemicals into their homes on their skin and clothing. As the oil hits shore, it enters the water supply.

Crude oil is complex mix of hundreds of highly toxic chemicals, including benzene and polycyclic aromatic hydrocarbons, which are infamous for their capacity to cause cancer as well as damage to the nervous system. In fact, crude oil components can damage every one of the body’s systems, from the reproductive and respiratory systems to the immune system, kidneys, liver and gastrointestinal system. They disrupt the organs that make up the endocrine system that controls mental and physical growth as well as fertility. They easily penetrate cell walls, to damage cell structures, including DNA.
But the danger is greatest to children because their immature bodies, with incompletely formed immune and detoxification systems, are substantially more vulnerable than adults’. The child in the womb is the most at risk. The report released just a few days ago by the President’s Cancer Panel warns about exposures to chemicals during pregnancy. Harm has already occurred: childhood cancer, once a rarity, has leapt 67 percent over the past twenty years as chemical production escalated. We’ll see a spike in similar awful statistics for the Gulf area in years to come.

Why aren’t federal agencies discussing this looming disaster? They need to alert local authorities of ways to minimize exposure. People who work with crude oil need to be given protective equipment. Special measures must be taken to protect young children and pregnant women.

Our children’s bodies are already dangerously overloaded with toxic substances and far too many, one out of three, are suffering from chronic, sometimes deadly, illnesses as a result.

What will we learn from this disaster? Will the costs in childhood cancer, birth defects, asthma, and dwindling male births be factored into our nation’s future energy plans?
This latest assault from the sea is one more reason that we need to act now to phase out oil from our economy and from our environment.

For more information: Crude Oil Health Hazards Fact Sheet, by Dr. Michael Harbut (Kamanos Cancer Institute) and Dr. Kathleen Burns (Sciencecorps),
Click above to access the Fact Sheet.

Alice Shabecoff is the co-author with her husband Philip of the just-released book,

Poisoned by Profit: How Toxins Are Making Our Children Chronically Ill.

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