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OSHA Tank Fire Prevention - Hot Work Mitigation Measures

Posted on Mon, Jun 11, 2012

Two contractors were welding atop a 10,000-gallon slurry tank when hot sparks ignited flammable vapors inside the tank, causing an explosion that killed one contractor and seriously injured another. The Chemical Safety Board (CSB) determined that the November 9, 2010 incident was caused by the increased temperature of the metal tank, sparks falling into the tank, or vapor wafting from the tank into the hot work area.

As a result, the CSB set forth new recommendations regarding “hot work”, which is defined as welding, cutting, grinding, or other spark-producing activities. Recommendations include:

  • Enforce safety procedures for hot work permits and ensure explosion hazards associated with hot work activity are recognized and mitigated.
  • Revise corporate procedures to require all process piping and vent piping be positively isolated before authorizing any hot work.
  • Require air monitoring for flammable vapor inside tanks and other containers where hot work is to be performed.

Advanced planning, safe work procedures, and mitigation measures can help prevent tank fires and explosions caused by hot works activities. The Occupational Safety and Health Standard (OSHA), 1910.252(a)(3)(i), states that “No welding, cutting, or other hot work shall be performed on used drums, barrels, tanks or other containers until they have been cleaned so thoroughly as to make absolutely certain that there are no flammable materials present or any substances such as greases, tars, acids, or other materials which when subjected to heat, might produce flammable or toxic vapors. Any pipe lines or connections to the drum or vessel shall be disconnected or blanked.”

According to OSHA, possible mitigation measures for hot work include:

  • Perform hot work in a safe location, or with fire hazards removed or covered
  • Use guards to confine the heat, sparks, and slag, and to protect the immovable fire hazards.
  • Do not perform hot work where flammable vapors or combustible materials exist. Work and equipment should be relocated outside of the hazardous areas, when possible.
  • Make suitable fire-extinguishing equipment immediately available. Such equipment may consist of pails of water, buckets of sand, hose, or portable extinguishers.
  • Assign additional personnel (fire watch) to guard against fire while hot work is being performed. Fire watchers are required whenever welding or cutting is performed in locations where anything greater than a minor fire might develop
  • Monitor the atmosphere with a gas detector. If a flammable or combustible gas exceeds 10 percent of the lower explosive level (LEL), the work must be stopped. Identify the source of the gas and repair the leakage.

Although mitigation measures can limit the potential for hot work accidents, companies should create a fire pre-plan to reduce response times and improve the effectiveness of a response in the event of a fire.

For an understanding of the necessary elements in creating an effective fire pre plan, download our Fire Pre Planning Guide.

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Tags: Fire Pre Plans, OSHA, Fire Preparedness, CSB

OSHA examines Pipe Safety Recommendations

Posted on Tue, Aug 03, 2010

The U.S Chemical Safety Board (CSB) is an independent federal agency that investigates the cause of chemical accidents.  These investigations are crucial to identifying the cause(s) of the incidents. The agency does not assess fines, but creates “lessons learned” stemming from root causes. At times, the evidence of these investigations is used to modify regulations and positively affect the future safety of employees, the public and the environment. 

The agency states that most accidents stem from flawed safety management systems. And, in most cases, accidents are a result of preventative factors. 

Throughout accident investigations, CSB has the authority to re-open prior investigations before drafting key findings of the main cause of the accident. CSB utilizes this to seek regulatory revisions in order to address safety and security issues.

On June 29th, the CSB approved urgent recommendations to regulatory agencies such as OSHA and NFPA relating to pipe cleaning and purging operations. According to the CSB, the recommendation resulted from the extensive investigations into the February 7, 2010, explosion at the Kleen Energy power plant in Middletown that caused six deaths and multiple injuries, and the June 9, 2009, explosion at the ConAgra Foods Slim Jim plant in Garner, North Carolina, that killed four workers and injured 67. An investigation revealed that both explosions resulted from releases of natural gas during the installation and commissioning of new piping for gas-fired appliances.

The CSB urged OSHA to pass regulations that would prohibit the use of natural gas for pipe cleaning, the cause of the explosion at Kleen Energy, and would prohibit the venting or purging of fuel gas indoors, the cause of the explosion at the ConAgra Slim Jim plant. Both explosions resulted from releases of natural gas during the installation and commissioning of new piping for gas-fired appliances. OSHA was also urged to require that companies involve their workers and contractors in developing safe procedures and training for handling fuel gas.”

Many CSB recommendations have been adopted by industry, leading to safer plants, workers, and communities. Investigations may lead to adjustments in corporate regulatory compliance.  Facilities must be aware of the constant changes in regulations, and adapt procedures and processes to comply with new regulations.  Regulatory tracking results in safer work-sites and limits the potential site fines assesed by regulatory agencies. 

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Tags: Pipeline, CSB