GAS DETECTION

Redefining Compliance for the Gas Detection Buyer

When it comes to gas detection, compliance with OSHA standards is a gray area.

C
BY KYLE KRUEGER
ompliance is a term you probably hear
more often than you would like when
you’re on the job. But what is compliance?
Compliance can mean adhering to any
number of different rules—internal compliance with
company policies, compliance with site rules, compli-
ance with the person who says “use this equipment,”
and of course, compliance with OSHA standards.
However, when it comes to gas detection, com-
pliance with OSHA standards is a gray area. Aside
from confined spaces, which are covered under 29
CFR 1910.146, you are left with OSHA’s General Duty
Clause, which states, “Employers must provide their
employees with a workplace free from recognized haz-
ards likely to cause death or serious physical harm.”1
If that sounds like it leaves a lot of room for in-
terpretation, you’re right. It means that companies
are responsible for determining what will keep their
workers safe. That’s a tremendous responsibility and
one that you must take seriously.
If you have ever found yourself in this situation
and need to determine if your gas detection program
is “compliant” and will protect workers from death or
physical harm, consider these points:
Ownership is not the same as compliance. Here’s
a common scenario: your company hasn’t had a gas-
related accident in years. However, now you are being
told that you must buy new gas monitors. You weren’t
planning on this purchase, and you haven’t had any is-
sues, so you buy them strictly to maintain compliance.
When the perceived risk of a gas-related incident
is low, it’s possible (and likely) that you won’t review
the manuals or properly train employees. Don’t fall
into the trap of thinking that owning gas monitors is
the same as using them properly.
Compliance requires bump testing. Turn to page
one or two of your gas detection manual. Seriously, go
grab it. Somewhere on that page, you will see some-
thing like “bump test before each day’s use.” These
words (or something similar) are in every manual.
Why? Because a gas detector can appear operational,
but fail to respond to a critical gas hazard. Just like a
car’s manual reminds you to buckle your seatbelt, a
gas detection manual asks for a bump test. Without a
bump test, you have no way of knowing that your gas
monitor will alert you to hazards.
Calibration maintains accuracy. Electrochemical
sensors drift and become less accurate over time. This
gradual loss of sensitivity is inherent, but can accel-
erate in dirty environments, around high concentra-
tions of gas, after rough handling (drops, falls, etc.),
and in extreme temperatures. These are also common
characteristics of industrial job sites. Therefore, all gas
detection manuals reference calibration. Sadly, if you
don’t calibrate your gas monitors frequently, then you
won’t detect sensor failures until it’s too late.  
People ignore alarms. Nobody wants to acknowl-
edge it, but we must: people ignore alarms. This can
happen for many different reasons. Some people think
they are invincible. Others don’t understand what the
alarm is telling them. And sometimes, alarms uncov-
er issues that nobody wants to deal with. Every gas
detector contains a data log that can clearly illustrate
these issues. However, many companies don’t use the
software that can illuminate them. Compliance isn’t
just about having gas detectors that can alert workers
to gas hazards—it’s about heeding the alarms and tak-
ing appropriate protective action.
If you still aren’t sure if you’re doing the right
thing, ask yourself a few simple questions. Why are
workers required to wear gas monitors in the first
place? If someone gets hurt and the accident was due
to the monitor not doing its job, how compliant was
that? If it didn’t respond to gas, were you compliant? If
a worker ignored an alarm, were you compliant?
Once you recognize the impact a workplace injury
or death can have on families, you can understand
why simply buying gas detectors isn’t enough. If you
maintain your gas detectors and review them regu-
larly, then you will meet the true goal of compliance:
sending your workers home safely every day.
Kyle Krueger is a district manager at Industrial
Scientific Corporation.
REFERENCES
1. https://www.osha.gov/dts/shib/shib093013.html

12 Occupational Health & Safety | NOVEMBER/DECEMBER 2019 www.ohsonline.com