COVID-19 Resources From ASSP

Please visit our COVID-19 resource page to find the latest free education and resources.


Recognize and Prevent Heat-Related Illnesses

Posted: Aug 22, 2013

By Renee Witherspoon, MS, CSP, CIH, CHMM, ASSE South Plains Chapter President

According to the Centers for Disease Control and Prevention approximately 400 Americans die each year due to heat related illnesses.  The National Weather Service states that excessive heat was the number one weather-related killer, causing more fatalities per year than floods, lightning, tornadoes, hurricanes, winter storms and extreme cold from 1994 to 2003.

Exposure to excessive heat can cause many safety challenges including increased accidents due to sweaty palms, dizziness or fogging of safety glasses.  Working in hot environments can also decrease mental alertness and physical performance.  With multiple days of triple-digit temperatures in Texas, utility professionals have to be able to recognize heat stress conditions, understand how our body responses to the heat (also called “heat strain”), and the basics of a heat stress program to prevent injury.

Recognition of Heat Stress Conditions

The combination of high heat and humidity can be a killer.  When heavy workloads and personal protective equipment (PPE) are added, it can place an extra strain on the body.   Each of us react differently when in hot environments and can depend on several factors including our age, weight, degree of physical fitness, degree of acclimatization, metabolism, use of alcohol or drugs, and a variety of other medical conditions including high blood pressure and heart disease.

The National Weather Service (NWS) issues heat alerts based on the Heat Index Values (see NOAA National Weather Service Heat Index graph).  The Heat Index Value factors in actual temperature and relative humidity to give an index of what it actually feels like.  This index then provides a likelihood of someone developing a heat-related illness with prolonged exposure or strenuous activity outside. Use this chart to determine if further heat stress prevention activities should be implemented.

The following are some risk factors for Heat-related Illness:

  • High temperature and humidity, direct sun exposure with no breeze or wind
  • Low liquid intake
  • Previous heat-related illnesses
  • Heavy physical labor
  • Waterproof clothing
  • No recent exposure in hot work areas or work outside during high heat conditions.

There are many types of Heat Stress-related illnesses ranging from mild to severe.  Heat stroke is the most severe, and the one we are most familiar with.  It occurs when the body is unable to regulate its temperature, the sweating mechanism fails and the body is unable to cool down.  Heat stoke can cause death or permanent disability if emergency treatment is not provided immediately.

Our Body’s Response to Heat

Working in a hot environment is stressful on the human body.  When exposed to heat the body tries to keep its internal temperature at about 98°F.  And when the body temperature rises it cools itself through perspiration.  If it is unable to keep up and dissipate the extra heat, vital organs such as the kidneys can shut down and cause damage to the central nervous system including the brain.

Heat exhaustion can be very mild with symptoms of headaches and dizziness.  Irritability and confusion are additional symptoms of heat exhaustion.  If someone passes out or collapses, call 911 and implement first aid procedures as it may have already escalated to a life-threatening condition.

Being alert to physical signs and symptoms of heat stress is a simple method to prevent a more serious injury.

If a worker becomes ill from the heat, the following are some basic procedures:

  • Call a supervisor for help. If the supervisor is not available, call 911.
  • Have someone stay with the worker until help arrives.
  • Move the worker to a cooler/shaded area.
  • Remove outer clothing.
  • Fan and mist the worker with water.
  • Apply ice (ice bags or ice towels) to the victim’s armpits, groin, neck, and back. (These areas are rich with blood vessels close to the skin, cooling them may reduce body temperature.)
  • Provide cool drinking water, if able to drink.

Prevention of Heat Stress

Not only do we need to recognize the signs and symptoms of heat stress and how to treat symptoms, but we need to educate and train our personnel on how to prevent heat-related illness.

A simple program for Heat Stress may include:

  1. Implementing a good Heat Acclimatization Program that gradually adapts workers to the heat.
  2. Having workers wear light-colored, loose fitting and breathable clothing such as cotton.
  3. Monitoring the Heat Index so that hot jobs can be scheduled during cooler times of the day.
  4. Using engineering controls, such as cooling mist fans, air conditioners or shielding for hot sources.
  5. Providing plenty of cool liquid (except alcoholic beverages) and encouraging employees to drink small amounts frequently, every 15 to 20 minutes—rather than relying on thirst. Electrolyte drinks like Gatorade also work.
  6. Allowing workers to take rest breaks in cooler environments.
  7. Using power assists and tools that reduce physical demands.
  8. Utilizing body cooling devices, such as ice vests and wetted bandanas.
  9. Establishing a screening program to identify health conditions aggravated by exposure to heat stress.
  10. Providing training programs regarding the health effects associated with heat stress, symptoms of heat-related illnesses and the methods of preventing such illnesses.

Working in temperature extremes is just part of the job for a utility professional.  As with other types of safety hazards, recognition of the signs and symptoms is a key.  We should avoid exposure to extreme heat and high humidity if possible, and if it cannot be avoided be able to take the appropriate steps to prevent heat-related illness for ourselves and our coworkers.

Save a life—Never ignore signs or symptoms of heat strain.


NOAA’s National Weather Service Heat Index can be found at

Heat Stress, NIOSH Workplace Safety and Health Topics,

OSHA Regional Notice:  Region VI emphasis program for outdoor heat related health hazards, Directive 02-00-027, Effective date:  October 1, 2010

WebMD, Heat Stroke:  Symptoms and Treatment,


There are many additional resources on heat stress, acclimatization programs, exposure limits and measurement techniques not discussed in this article.  If you would like additional information on setting up a program or would like a copy of my one-page Heat Stress Evaluation Checklist or Single Task Heat Stress Analysis sheet, send me an email at

The West Fertilizer Explosion:  Regulatory oversight wasn’t the answer

Posted: Jun 22, 2013

By:  Renee Witherspoon, MS, CSP, CIH, CHMM, South Plains Chapter President

Following the tragic fire and explosion on April 17, 2013 at the West Fertilizer Company, many questions are still being asked.  Not only what caused the fire and explosion, but where were the federal, state or local regulators that provide oversight of facilities?

Because every community has a worst case scenario when it comes to hazardous materials, whether it travels through your community or being used and stored, we as health and safety professionals need to volunteer our expertise and work with our emergency management leaders to help identify potentially high hazard facilities, recognize hazardous conditions that may exist, and communicate solutions.  This becomes important now that we know that government regulations can fail to provide the necessary oversight to prevent such events.

The Incident and Investigation

On April 17, 2013 an ammonium nitrate explosion at the West Fertilizer Company killed 14 people (11 were firefighters responding to the scene) and injured more than 200.  The explosion burned a school and destroyed or damaged buildings over a 35-block area.  Residents in the area reported that the blast felt like an earthquake.  The United States Geological Survey recorded the explosion as a 2.1 magnitude quake.

Among the many law enforcement agencies investigating the incident was the State Fire Marshal’s Office (SFMO) and the U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).  The other investigative organization that could reveal provide important findings is the US Chemical Safety Board (CSB).  The CSB does not issue fines or penalties or seek civil or criminal sanctions, but rather identifies a “root cause” by reviewing planning and zones practices in relation to schools and other public facilities.  They will also evaluate the effectiveness of regulatory coverage and review the emergency response activities during the fire.

Although law enforcement officials have determined that the investigation is officially “undetermined” with foul play still a possibility, the CSB stated that they had “no evidence pointing to an intentional criminal act”, and accused these agencies of potentially compromising or delaying their ability to complete the investigation.  Controversy aside, the results of the CSB report are highly anticipated by health and safety professionals interested in what went wrong, and how to prevent future catastrophic events.

Explosion Hazards of Ammonium Nitrate

According to a December 1997 report from the EPA, Office of Solid Waste and Response, ammonium nitrate under normal conditions is very stable.  It could however explode when exposed to strong shock or to high temperatures under confinement.  Contaminants of organic materials in the ammonium nitrate also make a potential ammonium nitrate explosion more energetic.  And with organic materials being stored onsite at an adjacent Chemical Storage Warehouse at the West site, this could have contributed to the severity of the explosion.

Regulations for Storage of Ammonium Nitrate – Federal Oversight

Ammonium nitrate is stable under normal conditions.  Because it is so stable, it does not appear on hazardous chemical lists for many Federal agencies.

According to the Department of Homeland Security (DHS), the West Fertilizer facility was not covered under the Chemical Facility Anti-terrorism Standards or CFATS.  With CFATS, facilities have to conduct a Top Screen Assessment and identify all Chemicals of Interest (COI) at their facilities.

Why was West Fertilizer not covered by CFATS regulations?  They did not file the paperwork.  Each CFATS regulated entity is required to complete a Top-Screen Assessment Tool with the agency.  This may have been an oversight by the agency, as West Fertilizer met the minimum criteria for filing.  That minimum criteria or Screening Threshold Quantity (STQ) for storage of chemicals such as ammonium nitrate (subject of theft or diversion) is 400 pounds.  According to the Texas Tier 2 Report for 2012, the West facility had 270 tons of ammonium nitrate and 55 tons of Anhydrous Ammonia.  Filing of the Top Screen would have triggered a review of their terrorism risk, but may have not identified potential risks associate with unsafe storage of a hazardous chemicals.

The Risk Management Program (RMP) under the EPA regulations is applicable to facilities that handle, manufacture, use or store any of the toxic or flammable substances above the specified threshold quantities (40 CFR 68.130);  however, ammonium nitrate – stable at normal conditions – is not on this list.

RMP covered facilities have to develop and implement a risk management plan that would prevent accidental releases of substances and mitigate the severity of incidents that might occur.  West Fertilizer submitted a Risk Management Plan; however, they did not provide the correct Offsite Consequence Analysis (a key aspect of the plan) that could have lessened the severity.

OSHA has the 1910.119 standard for Process Safety Management or PSM.  This standard contains a list of highly toxic and reactive hazardous chemicals which can present a potential for a catastrophic event at or above the threshold quantity.  The purpose of this standard is to prevent or minimize those consequences, but their definition of “process” may have limited OSHA inspections of the facility.

  • Process means any activity involving a highly hazardous chemical including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. For purposes of this definition, any group of vessels which are interconnected and separate vessels which are located such that a highly hazardous chemical could be involved in a potential release shall be considered a single process. (1910.119(b))

If the hazardous chemical is on the list of “highly hazardous chemicals” but not in a “process” then this regulation would not apply.  Ammonium nitrate is not on this “highly hazardous” list.  However, anhydrous ammonia is on the list, and according to the Tier 2 report, was onsite at 55 tons or 110,000 pounds.  The threshold quantity to trigger the PSM standard for anhydrous ammonia is 10,000 pounds.  West certainly had a threshold quantity on site, but may have not been in a process with “interconnected and separate vessels”.

OSHA could have been onsite to review potential consequences when handling of the anhydrous ammonia if it were a “process”, and if a comprehensive wall-to-wall inspection was performed could have inspected the handling and storage of the ammonium nitrate.  Could an OSHA compliance officer have recognized the hazard?  Possibly, they do have well trained individuals certified in safety, but they have to have a programmed inspection, a worker complaint, serious accidents and fatalities to have them onsite.

According to records obtained by the Associated Press, the facility was last inspected by OSHA in 1985, prior to the PSM standard.  West was cited for improper storage of anhydrous ammonia and fined $30.

Regulations for Storage of Ammonium Nitrate – State and Local Oversight

As for our Texas Commission on Environmental Quality (TCEQ), a citizen filed an official complaint with the TCEQ in 2006 regarding an “ammonia smell” from the facility.  The TCEQ investigated and determined that the facility did not have the correct permits for dry fertilizer materials and for two (2)12,000 gallon anhydrous ammonia storage tanks.  The TCEQ had visited several times but had not noted any concerns that may have triggered additional investigation into improper storage conditions.

The Department of State Health Services (DSHS) requires an annual hazardous chemical inventory called the Texas Tier 2 Report.  This report contains detailed information on chemicals that meet or exceed specific reporting thresholds at any time during a calendar year.  For generally hazardous chemicals, such as ammonium nitrate, that Threshold Planning Quantity (TPQ) is 10,000 pounds.  Since the West facility had 270 tons of ammonium nitrate on hand in 2012, a Tier 2 report was filed.

Because the goal of the Tier 2 report is to protect the public health and environment by providing current and accurate information about hazardous chemicals and their health effects, the agency did not conduct any inspections to ensure this facility was complying with the applicable regulations.  Tier 2 information is required to be submitted to the Local Emergency Planning Committee (LEPC) and the local fire department with jurisdiction.

Therefore one of the last regulatory authorities that had oversight was the local fire marshal, volunteer fire department and LEPC.  And for a small Texas town of West where like most small Texas towns – where professionals wear “multiple hats”.  There may not have been an inspection because volunteer firemen worked for West Fertilizer.  This is just speculation, but it shows an opportunity for us as health and safety professionals to become involved.

Volunteer Your Expertise

Since these government agencies with their regulations did not prevent the tragedy in West, where does it leave similar communities with facilities having large quantities of highly hazardous chemicals in close proximity to schools, nursing homes and apartment complexes?

We have the training and expertise in health and safety, so it’s up to us to take up the banner, and be involved with emergency planning and preparedness in our communities.

Although there are many worthy community organization, let me recommend your Local Emergency Planning Committee.  The LEPC’s role in community preparedness was initiated in the wake of the Bhopal disaster in India, where more than 2,000 people died because of an accident involving a release of a hazardous chemical.

As we wait on completion of the investigation and recommendations from the CSB, this is a call to action to be prepared, have a plan and be involved in the safety of your community.   The government regulators are limited in their scope to find and recognize potential hazard in facilities with highly hazardous chemicals so it is up to us.

Government regulation is not the answer, we have the resources and the expertise to identify hazards and mitigate impacts.  So this is my challenge – what can you do to promote health and safety in your community?  We can make a difference!


A copy of the Tier 2 Report is below:


The White House releases an Executive Order to Improve Chemical Facility Safety & Security

Posted: Apr 22, 2013

By:  Renee Witherspoon, MS, CSP, CIH, CHMM, South Plains Chapter President

In the light of recent tragic events in West and other industrial accidents, the White House today (8/1/13) issued an Executive Order to improve Chemical Safety and Security.

The purpose is to see if there are additional measures that can be taken by the executive departments and agencies with regulatory authority to further improve chemical safety.

The Executive Order establishes a Chemical Facility Safety & Security Working Group that will consist of leaders from the Departments of Justice, Agriculture and Transportation.  The group will also have representatives from the Council on Environmental Quality, the National Security Staff, Domestic Policy Council, Office of Science and Technology, and the White House Office of Cabinet Affairs.

Goals for this working group include:

  • Improving operational coordination with State, Local and Tribal Partners
    • Their goal is to provide first responders, State Emergency Response Commissions (SERCs) and Local Emergency Planning Committees (LEPCs) with ready access to key information to prevent, prepare for and respond to chemical incidents.  This goal also will review the feasibility of ATF and Department of Homeland Security, specifically data from the Chemical Facility Anti-Terrorism Standards (CFATS), being shared with SERCs and LEPCs.
  • Enhancing Federal Coordination
    • The group will develop a pilot program involving the EPA, DOL and Homeland Security to validate best practices and to test innovative methods for Federal interagency collaboration regarding chemical facility safety and security.
    • The group will also be consulting the Chemical Safety Board (CSB) to develop a Memorandum of Understand (MOU) regarding full disclosure of information between the EPA, ATF and OSHA.
  • Enhancing information Collection and Sharing
    • The group will develop and analyze the potential to improve information collection by and sharing between agencies.
  • Modernizing Policy, Regulation and Standards
    • Develop options for improved chemical facility safety and security that identifies improvements to existing risk management practices through agency programs.
    • Engaging key stakeholders to discuss the options and other means to improve chemical risk management.
    • Review proposals to improve the safe and secure storage, handling, and sale of ammonium nitrate and identify ways in which ammonium nitrate safety and security can be enhanced under existing regulations.
    • Consider additional chemicals to be added to the CFATS chemicals of interest list.
    • Identify changes that need to be made in the retail and commercial grade exemptions in the PSM standard
    • Issue a Request for Information to identify any issues related to modernization of the PSM standard.
  • Identifying Best Practices
    • Identify and share best practices to reduce safety and security risks in the production and storage of potentially harmful chemicals.

With any type of emergency, communication and information is always key to good decision-making.  Collection and sharing of information with key industry stakeholders and LEPCs will hopefully improve safety and prevent tragedies like the event in West from happening again.

A link to this Executive Order is below: