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Discussing osha 1910 106 nfpa 30 and recent fire incidents of 2015 2016

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Discussing osha 1910 106 nfpa 30 and recent fire incidents of 2015 2016

  1. 1. OSHA 1910.106, NFPA 30 and Recent Fire Incidents John Newquist johnanewquist@gmail.com 815-354-6853
  2. 2. Objective • Identify key requirements in the 2015 NFPA 30 • Describe seven flammable liquid hazards • Discuss solutions and prevention to flammable or combustible storage of liquids.
  3. 3. NFPA Standards Form Basis for Safety • Started in 1912 • Hazard control • Prevent or limit leakage • Prevent ignition of hazardous atmosphere • Limit consequences of the fire to acceptable levels (mitigation control)
  4. 4. Hazard Analysis • Analysis of fire and explosion hazards of the operation • Analysis of emergency relief from process vessels • Analysis of facility design requirements • Analysis of liquid handling, transfer and use • Analysis of local conditions such exposure from adjacent properties, weather, earthquakes • Analysis of emergency response issues Section 6.4
  5. 5. 51 59 63 64 130 119(d)(3)(ii) 107(b)(5)(i) 106(e)(6)(ii) 107(g)(2) 101(b) Hazardous Materials [1910.101 – .126] 5 COMPRESSED GASES – HANDLING STORAGE AND USE SPRAY BOOTH – AIR VELOCITY CLASS I LIQUIDS – DISPENSING SUBPARTH SPRAY AREAS – CLEANING WITH NON-SPARKING TOOLS DOCUMENTATION OF EQUIPMENT WITH GOOD ENGINEERING PRACTICES
  6. 6. 1910.101(b) • "Compressed gases." The in- plant handling, storage, and utilization of all compressed gases in cylinders, portable tanks, rail tank cars, or motor vehicle cargo tanks shall be in accordance with Compressed Gas Association Pamphlet P-1-1965, which is incorporated by reference as specified in Sec. 1910.6.
  7. 7. 1910.107(g)(2) • Cleaning. • All spraying areas shall be kept as free from the accumulation of deposits of combustible residues as practical, with cleaning conducted daily if necessary. • Scrapers, spuds, or other such tools used for cleaning purposes shall be of nonsparking material. What could be the weaknesses in citing this?
  8. 8. 1910.106(e)(2)(iv)(d) • Flammable liquids shall be drawn from or transferred into vessels, containers, or portable tanks within a building only through a closed piping system, from safety cans, by means of a device drawing through the top, or from a container or portable tanks by gravity through an approved self-closing valve. • Transferring by means of air pressure on the container or portable tanks shall be prohibited.
  9. 9. September 2014
  10. 10. Ether accident • Drop filling • Worker sees sparks in funnel • Next thing he knows he is on fire with invisible flames
  11. 11. Self-Closing Safety Faucet • Bonding wire between drum and container • Grounding wire between drum and ground • Safety vent in drum
  12. 12. Safety Pump • Faster and safer than using a faucet • Spills less likely • No separate safety vents in drum required • Installed directly in drum bung opening • Some pump hoses have integral bonding wires
  13. 13. 1910.107(b)(5)(i) • The spraying operations except electrostatic spraying operations shall be so designed, installed and maintained that the average air velocity over the open face of the booth (or booth cross section during spraying operations) shall be not less than 100 linear feet per minute.
  14. 14. 1910.119(d)(3)(ii) • The employer shall document that equipment complies with recognized and generally accepted good engineering practices.
  15. 15. 1910.119(d)(3)(ii) • OSHA considered, but rejected, publishing a list of RAGAGEP providers • The employer (not OSHA!) selects the applicable and protective RAGAGEP it will use / comply with!
  16. 16. Ammonia - IIAR (International Institute of Ammonia Refrigeration) Bulletin 107 - Guidelines for: Suggested Safety and Operating Procedures when Making Refrigeration Plant Tie-Ins Bulletin 108 - Guidelines for: Water Contamination in Ammonia Refrigeration System Bulletin 109 - Guidelines for: IIAR Minimum Safety Criteria for a Safe Ammonia Refrigeration System Bulletin 110 - Guidelines for: Start-Up, Inspection and Maintenance of Ammonia Mechanical Refrigerating Systems Potential Sources of RAGAGEP
  17. 17. Ammonia - IIAR Bulletin 111 - Guidelines for: Ammonia Machinery Room Ventilation Bulletin 112 - Guidelines for: Ammonia Machinery Room Design Bulletin 114 - Guidelines for: Identification of Ammonia Refrigeration Piping and System Components Bulletin 116 - Guidelines for: Avoiding Component Failure in Industrial Refrigeration Systems Caused by Abnormal Pressure or Shock Potential Sources of RAGAGEP
  18. 18. The Chlorine Institute Numerous Standards for: Chlorine Sodium hypochlorite Hydrogen Chloride Hydrochloric Acid Many pamphlets available for free download – www.chlorineinstitute.org Potential Sources of RAGAGEP
  19. 19. API – American Petroleum Institute ASME – American Society of Mechanical Engineers NBIC – National Board Inspection Code, The National Board of Boiler and Pressure Vessel Inspectors CCPS – American Institute of Chemical Engineers, Center for Chemical Process Safety NFPA – National Fire Protection Association Potential Sources of RAGAGEP Boiler leak
  20. 20. ANSI – American National Standards Institute NIOSH – National Institute for Occupational Safety and Health ASNT – American Society for Non-Destructive Testing ISA – International Society of Automation ISA-TR84.00.04 – Safety Instrumented Systems EPRI – Electric Power and Research Institute Potential Sources of RAGAGEP
  21. 21. Safety Management Systems NFPA standards are increasingly incorporating requirements for safety management system elements, for example: • Hazard Analysis • Operating Procedures • Training • Emergency plans and procedures • Management of Change
  22. 22. Control of Ignition Sources • 6.5.1 General. Precautions shall be taken to prevent the ignition of flammable vapors by sources such as the following: • (1) Open flames • (2) Lightning • (3) Hot surfaces • (4) Radiant heat • (5) Smoking • (6) Cutting and welding • (7) Spontaneous ignition • (8)*Frictional heat or sparks • (9) Static electricity • (10) Electrical sparks • (11) Stray currents • (12) Ovens, furnaces, and heating equipment
  23. 23. Issues?
  24. 24. Emergency Planning • Written Emergency Action Plan Procedures for • Notifying the fire department in case of fire, release of liquids or vapors. • Evacuation • Control and extinguishing fire Headcount? Safe Location?
  25. 25. Fire Protection John Newquist Draft 7 2 2016
  26. 26. May 2014 Location?
  27. 27. Jan 2016 • Issue?
  28. 28. Equipment Maintenance Procedures for maintenance and operation of: • Fire protection equipment and systems • Drainage and containment systems • Dispersion and ventilation equipment systems
  29. 29. Emergency Planning Procedures for: • Shutting down and isolating equipment to reduce, mitigate, or stop the release of liquids or vapors • Assigning plant personnel responsible for maintaining critical plant functions or shut down of plant processes and safe start up following isolation or shut down.
  30. 30. Inspection and Maintenance • Maintenance and operating practices shall be established and implemented to control leakage and prevent spillage of flammable and combustible liquids
  31. 31. Management of Security • Risk base approach with the following objectives: • Identification and evaluations of security risks • Evaluations of security performance • Security Vulnerability Analysis • Emergency Action Plan • Evaluation of protection of employees, • the facility itself, • the surrounding community, and • the environment • Security Management Review after an incident
  32. 32. 2009 Empress Casino Fire • $340 million in damage • Lawsuit blames the fire on general contractor and five other companies • The suit claims a welder inadvertently sparked the blaze in the kitchen area, which ignited greasy cooking residue and spread flames throughout the attic and truss space.
  33. 33. NFPA 30 Contents • Chapter 16 Fire Protection • Chapter 17 Processing Facilities • Chapter 18 Dispensing • Chapter 19 Specific Operations • Chapter 21-25 Tank Storage • Chapter 27 Piping • Chapter 28-29 Bulk and wharves • Chapter 1-4 Administrative and Definitions • No chapter 5, 8, 20, 26 • Chapter 6 Fire Explosion and Risk Control • Chapter 7 Electrical • Chapter 9 General Storage of Liquids in Containers • Chapter 10-15 Specific Storage Requirement
  34. 34. March 2015 • Used Brake cleaner at auto shop w pit. • Putting it in a spray bottle and it flashed from the 55 gallon drum.
  35. 35. Combustible Liquid Accident 2012 • Willowbrook, IL • Worker were installing carpet • Liquid caught on fire
  36. 36. Combustible Liquids • Storage, processing, handling, and use of combustible liquids above its flash point can produce ignitable vapors. • 11/22/2006 • Vapor cloud at ink mfr. • Tank left overnight with steam heat.
  37. 37. Definitions • Class I are areas where flammable gases may be present in sufficient quantities to produce explosive or flammable mixtures. • Class II locations can be described as hazardous because of the presence of combustible dust. • Class III locations contain easily ignitable fibers A flammable painting room would be Class I
  38. 38. Definitions • Flammable liquid means any liquid having a flashpoint at or below 199.4 °F (93 °C). Flammable liquids are divided into four categories as follows: • Category 1 shall include liquids having flashpoints below 73.4 °F (23 °C) and having a boiling point at or below 95 °F (35 °C). NFPA 30 3.3.33.2* Flammable Liquid. Any liquid that has a closed cup flash point below 100°F (37.8°C) Class IA Liquid — Any liquid that has a flash point below 73°F (22.8°C) and a boiling point below 100°F (37.8°C)
  39. 39. Definitions • Category 2 shall include liquids having flashpoints below 73.4 °F (23 °C) and having a boiling point above 95 °F (35 °C). Many flammable paints and inks are Class 1B Class IB Liquid — Any liquid that has a flash point below 73°F (22.8°C) and a boiling point at or above 100°F (37.8°C)
  40. 40. Definitions • Category 3 shall include liquids having flashpoints at or above 73.4 °F (23 °C) and at or below 140 °F (60 °C). When a Category 3 liquid with a flashpoint at or above 100 °F (37.8 °C) is heated for use to within 30 °F (16.7 °C) of its flashpoint, it shall be handled in accordance with the requirements for a Category 3 liquid with a flashpoint below 100 °F (37.8 °C) Class IC Liquid — Any liquid that has a flash point at or above 73°F (22.8°C), but below 100°F (37.8°C)
  41. 41. Definitions• Category 4 shall include liquids having flashpoints above 140 °F (60 °C) and at or below 199.4 °F (93 °C). When a Category 4 flammable liquid is heated for use to within 30 °F (16.7 °C) of its flashpoint, it shall be handled in accordance with the requirements for a Category 3 liquid with a flashpoint at or above 100 °F (37.8 °C). Class II Liquid — Any liquid that has a flash point at or above 100°F (37.8°C) and below 140°F (60°C) (2) Class III Liquid — Any liquid that has a flash point at or above 140°F (60°C) (a) Class IIIA Liquid — Any liquid that has a flash point at or above 140°F (60°C), but below 200°F (93°C) (b) (b) Class IIIB Liquid — Any liquid that has a flash point at or above 200°F (93°C)
  42. 42. Flammable Liquid Storage Flammable storage cabinet capacities: • 1910.106(e)(2)(ii)(b) • The quantity of liquid that may be located outside of an inside storage room or storage cabinet in a building or in any one fire area of a building shall not exceed: • 25 gallons of Category 1 flammable liquids in containers
  43. 43. Let’s count • Cabinet or no cabinet?
  44. 44. Inside Storage Room Requirements • Fire resistant construction • Sprinklers • Raised sills or trench • Fire doors • Liquid tight (floor to wall) • Windows • Capacity ratings • Electrical • Ventilation • Storage requirements • Egress • Leak procedures • 29 CFR 1910.106(d)(4)
  45. 45. Industrial Fire Resistive Construction • Walls per NFPA 251 • 29 CFR 1910.106(e)(3)(iii), Flammable and Combustible Liquids; Industrial Plants; Unit Physical Operations; Chemical Processes; establishes that a firewall may have a 2-hour fire resistance rating. • NFPA Chapter 9 & 11 applies. NFPA 30 is quite different and may require 4 hour walls in some cases.
  46. 46. Openings – Flammable Storage • Non-combustible, liquid- tight sills or ramps – 4” • Open-grated trench in alternative • Storage area floor 4” below surrounding floor, in alternative • NFPA 30 Chapter 9.3 offers more alternatives and more requirements NFPA 30 requires the discharge not to go in public sewers, waterways, or adjoining properties.
  47. 47. Flammable Storage Rooms • Self closing fire door, per NFPA 80-1968 • Floor to wall construction shall be liquid-tight • NPFA 30 Chapter 9.9 requires doors to closed in the event if a fire.
  48. 48. Flammable Storage • Where other portions of the building, or other properties are involved, protected windows are required per NFPA 80- 1968 • NFPA 30 Chapter 9.9.2 requires openings to match fire resistance of wall. Flammable Storage rooms should never have normal windows.
  49. 49. Storage Room Capacity • Reference Table H-13 in 1910.106(d)(4) • Capacity is dependent on: - room size - fire resistant rating - if fire protection is available (gals/cubic feet/floor area) Electrical lighting of this type and windows not allowedNFPA 30 Chapter 9.6 specifies max quantities for control area.
  50. 50. Electrical • Electrical installations (lighting, receptacles, etc) for Class I liquids must meet Class I, Division 2 Hazardous location requirements in Subpart S • NFPA 30 Chapter 9.11 has Electrical System Requirements
  51. 51. Ventilation • Gravity or mechanical • Six air changes/hour • Locate switch outside of room – wired with lighting • NFPA 30, Chapter 18.6 has much more extensive ventilation requirements. • Safe Location for vented air. • 1 cfm/sqft but not less than 150 cfm.
  52. 52. Inside Storage Rooms • Minimum 3’ wide aisles • No stacking of containers over 30 gal • Approved pump or self- closing faucet for dispensing • NFPA 30 Chapter 9.3 requires means of egress to meet NFPA 101. NFPA 30 Chapter 18.4 covers dispensing, handling, transfer and use.
  53. 53. Dec 2015 • Issues? • Diesel.
  54. 54. Basic Requirements 59 SUBPARTE • Exit routes must meet the following design and construction requirements: – Must be a permanent part of the workplace. – Separated by fire resistant materials. – Have limited openings.
  55. 55. Exit Marking • Exits marked with a readily visible sign • "Not an Exit" on confusing doors • Signs with exit directions in rooms where exit not apparent • Signs lit by 5 foot- candles
  56. 56. Exit Marking • 1910.37(b)(4) If the direction of travel to the exit or exit discharge is not immediately apparent, signs must be posted along the exit access indicating the direction of travel to the nearest exit and exit discharge. Additionally, the line-of-sight to an exit sign must clearly be visible at all times.
  57. 57. Issue?
  58. 58. Egress • Cannot block or limit safe egress (access to exits) • 1910.37(a)(3) Exits were not free and unobstructed. • NFPA 30 Chapter 9.3 requires means of egress to meet NFPA 101.
  59. 59. Exit Door Access • Must be unlocked. • Must be able to open from inside at all times without keys, tools, or special knowledge. – Panic bar that locks only from the outside is permitted. • Must be free of any device or alarm that could restrict use if device or alarm fails.
  60. 60. Door Hinges • Must be side-hinged. – Door must be used to connect any room to an exit route. • Must swing in direction of travel if room is occupied by more than 50 people, or room is a high hazard area (contains contents likely to burn with extreme rapidity or explode).
  61. 61. Exit Routes 66 SUBPARTE • The number of exit routes must be adequate - at least two. • Must be far enough apart so that if one is blocked by fire or smoke, the other is available for evacuation. • More than two may be required, depending on the size of the building and its occupancy. • Single exit permitted where the number of employees, building size, and occupancy is such that all employees can evacuate.
  62. 62. Exit Route Capacity • Must be adequate. • Must support the maximum permitted occupant load for each floor served. • Capacity may not decrease in direction of travel to exit discharge. • Note: Information regarding “occupant load” is located in NFPA 101- 2015, Life Safety Code.
  63. 63. Fire Prevention Plans • Requires housekeeping to prevent accumulation of flammable and combustible waste material and residue • Plan made available for employees to view • Requires training of employees in the plan
  64. 64. Sprinklers • Storage should be 18 inches below head • Sprinkler heads kept dust, lint, and grease free • Sprinkler heads and piping in good condition • Main drain flow test annually • Inspector’s test valve opened every two years (most do it annually)
  65. 65. Flammable Drums • Empty drum containing old xylene vapors exploded when torch cut.
  66. 66. Ether accident • Drop filling • Worker sees sparks in funnel • Next thing he knows he is on fire with invisible flames
  67. 67. PPE • Hazard Assessment required under 1910.132 • Fire Resistant Clothing?
  68. 68. 2013• State fire investigators think a sparking forklift ignited a cloud of propane in a storage yard about 10 p.m. July 29, touching off a blast felt a mile away. • Five employees were hospitalized for months with severe burns. • One of the workers awoke from a coma a month after the accident
  69. 69. Some specific NFPA 30 requirements.
  70. 70. Oxidizers • 25 foot separation from flammable and combustible liquids
  71. 71. Detached Unprotected Buildings • 1000 ft. separation from most occupancies. (Except business, industrial, mercantile, and storage.) • Want to avoid assembly and health care being too close.
  72. 72. Outdoor Storage • Kept free of weeds, debris and other combustible material within 10 feet
  73. 73. Processing Facilities • Drainage to a safe location to prevent liquids accumulating under vessel or load bearing support
  74. 74. Flammable Liquid Use • Flammable liquids shall be kept in closed tanks or containers when not in use
  75. 75. Underground Storage Tanks • Overfill prevention equipment installed to alert the transfer operator that tank is no more than 90% full.
  76. 76. Bonded Grounded • 6.5.4.2 • All metallic equipment such as tanks, machinery, and piping where the potential exists for an ignitible mixture to be present shall be bonded and grounded.
  77. 77. April 2016 • "He told our investigators, upon questioning, that he intentionally set the fire by means of a small lighter and a piece of shipping paper. So he lit the paper and then dropped it on some furniture," said Tom Ahern, a spokesman for the Bureau of Alcohol, Tobacco and Firearms and Explosives. "He had just had a heated argument with his superiors, who were going to dock him some vacation days because he had failed to show up for work on a number of occasions." Woodridge IL 65 employees were in the warehouse
  78. 78. Mar 2016
  79. 79. Hot Works combustible material and hazardous gases should be detected in buildings closer than 35 feet (10.7 m) from the point of welding.
  80. 80. "Hot work" means work involving electric or gas welding, cutting, brazing, or similar flame or spark-producing operations. What is Hot Works? Danger in the Oil Field
  81. 81. Aug 2016 • Nederland, Texas • An incident that injured seven workers – including three critically • Sunoco Logistics Partners, a terminal facility • According to initial inquiries the incident involved a flash fire during welding – also referred to as hot work - activities at the facility.
  82. 82. November 2015 • Lytton Iowa • Thirty-four-year-old Earl Moore of Milford Center, Ohio was inside a large storage tank and was going to patch weld a seam in the tank when the explosion occurred.
  83. 83. NFPA Read only access • www.nfpa.org • Set up alerts
  84. 84. Questions? • Facebook • Linked-in • Twitter
  85. 85. Background • Classes: OSHA 10/30 Hour, Incident Investigation, Confined Space, Excavation Safety, Cranes Signaling and Rigging, Fall Protection, Scaffold Safety, and many more • Services: Mock OSHA Inspections, Site Safety Audits, OSHA Litigation Consultation, • Since 1990, he has trained OSHA compliance officers in numerous areas including OSHA policy, safety and health regulations, safety and health management systems, legal aspects of investigations, and enforcement strategies. 90 • 36 years working with top companies to achieve ZERO injuries
  86. 86. Disclaimer • While the information contained in this Presentation is believed to be accurate, the Preparers have not conducted any investigation with respect to such information. The Preparers expressly disclaim any and all liability for representations or warranties, expressed or implied, contained in, or for omissions from, this Presentation or any other written or oral communication transmitted to any interested party in connection with this Presentation so far as is permitted by law. In particular, but without limitation, no representation or warranty is given as to the achievement or reasonableness of, and no reliance should be placed on, any projections, estimates, forecasts, analyses or forward looking statements contained in this Presentation which involve by their nature a number of risks, uncertainties or assumptions that could cause actual results or events to differ materially from those expressed or implied in this Presentation. Only those particular representations and warranties which may be made in a definitive written agreement, when and if one is executed, and subject to such limitations and restrictions as may be specified in such agreement, shall have any legal effect. By its acceptance hereof, each recipient agrees that none of the Preparers nor any of their respective Representatives shall be liable for any direct, indirect or consequential loss or damages suffered by any person as a result of relying on any statement in or omission from this Presentation, along with other information furnished in connection therewith, and any such liability is expressly disclaimed.

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