Transcript DOE Facility Fire Safety Initiative Initial Joint Review

Fire Protection and
Emergency Services
Requirements
in 29 CFR 1926
Dennis Kubicki, P. E.
Office of Facility Operations Support
Office of Environment, Safety & Health
1
Scope (1926.10)
Applies to construction, alteration and
repair (interpreted to include D&D)
No worker shall be exposed to conditions
which are “unsanitary, hazardous or
dangerous to health and safety as
determined under construction safety and
health standards promulgated by the
Secretary (of Labor) by regulation.”
2
Applicability to contractors (1926.13)
This section provides additional detail on
the regulation’s application to contractors
and subcontractors.
It is critical to understand that if someone
is employed by a contractor or
subcontractor at a DOE location (site,
facility, building, parcel of land) and they
are “working” in construction activities (see
previous page, broadly defined), Part 1926
applies.
3
Joint responsibility (1926.16)
This section addresses agreements that
can be reached between prime contractors
and subcontractors regarding safe work
conditions.
For example, the prime contractor can
agree to provide manual fire fighting
equipment and related training for
subcontractors.
4
General safety provisions (1926.20)
These are “catch all” requirements with
which you can be cited if specific
standards are not met.
Highlights include:
“frequent and regular inspections”
“machinery, tools, material and equipment”
must be “compliant”
employees must be “qualified” to use
machinery and equipment
5
Safety training and education (1926.21)
This section lays out general responsibilities
for safety and health training. It is critical to
remember that if you require or EXPECT an
employee to do anything that might put them
at risk, they have to be appropriately trained.
This would include…
…members of the building occupant
emergency organization or fire fighters
in a mutual aid mode.
6
General fire safety requirements (1926.24)
This paragraph establishes a global fire
protection and prevention requirement
and includes all phases of construction,
including “demolition.”
The paragraph ties the general
requirements section to the specific fire
safety requirements of Subpart F, “Fire
Protection and Prevention” of Part 1926.
7
Control of combustibles (1926.25)
This section contains broad
requirements for clear spaces, such as
around buildings (for fire department
access) and on stairs (for emergency
egress).
This section also calls for removal of
debris “at regular intervals” and the
provision of appropriate containers for
combustible and hazardous materials.
8
Personal protective equipment (1926.28)
This section contains a broad requirement
for appropriate PPE. It’s orientation is
toward conventional workers. But it can be
used to cite fire departments and brigades.
The bottom line is, evaluate what your
people are doing comprehensively and
make sure that they have appropriate
PPE.
9
Means of Egress (1926.34)
This section contains global requirements
for maintaining emergency egress
capability. Highlights include:
no locks on doors, with exceptions
requires signage and illumination
no obstructions
operable hardware
10
Emergency action Plans (1926.35)
The section contains general requirements
for the response of employees to
emergencies, including:
a range of procedures (operational,
evacuation, rescue, medical)
an alarm system of some type
employee training
11
Subpart D – Health & Environment Controls
1926.50 through 1926.66
In general, while this Subpart does not focus
exclusively on fire safety and emergency
response, aspects of it contain significant
requirements that must be addressed by
contractor fire safety programs. The four
principal examples are:
Medical services and first aid
Hazard communication
Process safety management
HAZWOPER
12
Medical services & first aid (1926.50)
The requirements in this section are very
broad. DOE would likely expect that NFPA
Standard 1710 would be met, among other
requirements. Noteworthy among the
criteria are requirements for:
First aid supplies at all worksites (.50(d))
Proper equipment for prompt transport
of injured from all worksites
(.50(e))
13
Hazard communication (1926.59)
Refers back to 1910.1200
This multi-faceted section requires:
Appropriate labeling on containers
Posting of MSDSs
Information and training for laboratory
employees**
**Applies to emergency responders for
“foreseeable emergencies” (??)
14
Process safety management (1926.64)
Another multifaceted section that contains
similar and dissimilar requirements from the
previous sections, including:
Employee involvement in the development of a
process hazards analysis
Much documentation required on hazards,
process technology, and process equipment
A documented Process Hazards Analysis
Operating procedures, including emergency procedures
Training of employees, including refresher training
Documented Safety reviews
15
HAZWOPER (1926.65)
This section contains extensive, detailed
requirements (including much paperwork)
governing hazardous waste, waste sites,
and workers, including emergency
responders. They include:
Comprehensive definition of
“hazardous substance” and ”hazardous
waste” (.65(a)(2)(iii)(C)(3)
16
HAZWOPER (1926.65) continued…
Requires a written general safety and health
program (.65(b)(1))
Requires a specific organizational structure
(.65(b)(2))
Requires a comprehensive work plan
(.65(b)(3))
Requires a worksite-specific safety and
health plan for each work phase (.65(b)(4))
17
HAZWOPER (1926.65) continued…
A safety and health risk analysis “for each
work task” (.65(b)(4)(ii)(A))
A documented emergency response plan (H)
Confined space entry procedures (I)
A spill containment program (J)
Pre-entry briefings (.65(b)(4)(iii))
Inspections to assess effectiveness of the
safety and health plan (.65(b)(4)(iv))
18
HAZWOPER (1926.65) continued…
There are explicit training requirements in
HAZWOPER that may exceed NFPA
requirements for training to emergency
responders and “supervisors.”
training on worksite hazards (.65(e)(2))
training on worksite engineering
controls (.65(e)(2))
training of supervisors and trainers (e)(4)
19
HAZWOPER (1926.65) continued…
There are explicit requirements in .65(g)
that govern engineering controls for
hazardous waste that need to be reflected
in FHAs and fire safety self-assessments.
There are explicit requirements in .65(j)
that govern the handling of drums and
containers that need to be reflected in
FHAs and fire safety self-assessments.
20
HAZWOPER (1926.65) continued…
Section .65(k) contains explicit
requirements for emergency response.
The challenge for DOE is to assure the
coordination of response between the
contractor employees (per the required
emergency response plan) and
professional emergency responders from
the site fire department or off-site
emergency responders.
21
HAZWOPER (1926.65) continued…
Section .65(q) contains explicit requirements
for the conduct of emergency operations at
incidents featuring hazardous substances
release.
Documented ER Plan (.65(q)(1) and (2))
Responsibilities of “individual in charge
of the ICS” (.65(q)(3))
Requirements for “skilled support
personnel (.65(q)(4))
22
HAZWOPER (1926.65) continued…
Section .65(q)(6) details training
requirements for five categories of
emergency responders:
First responder awareness level (6)(i)
First responder operations level (6)(ii)
Haz Mat technician (6)(iii)
Haz Mat specialist (6)(iv)
On scene incident commander (v)
23
HAZWOPER (1926.65) continued…
Pause here for fire chiefs and emergency
managers to note this:
Now that you are subject to the new Rule
(Part 851), which adopts Part 1926, you
are responsible for being aware of these
requirements and reflect them in your
policies, programs, plans, procedures,
self-assessments (emphasis added).
24
HAZWOPER (1926.65) continued…
The HAZWOPER section of Part 1926
contains additional non-mandatory
guidance, including:
Appendix A on PPE test methods
Appendix B on levels of PPE needed
Appendix C on compliance**
Appendix D references
Appendix E on training curriculum
25
HAZWOPER (1926.65) continued…
**Appendix C contains much useful insights
into a range of issues that affect fire safety
and emergency response, including:
Insights into the content of H&S plans
Perspective on training programs
Emergency response plans
The incident command system
New technology and spill containment
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Spray booths (1926.66)
While this section contains many
requirements, they are not as
comprehensive as the criteria contained in
NFPA Standard 33, “Standard for Spray
Application Using Flammable or
Combustible Materials.” For example,
NFPA 33 requires automatic suppression
and control of stored combustibles.
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Subpart F – Fire Protection and
Prevention (1926.150)
In general, this section contains either
broad requirements that are comparable, if
not less comprehensive, to DOE directives;
or it contains explicit requirements that are
both less comprehensive and less
conservative than the criteria contained in
the corresponding NFPA codes and
standards. (The best example is 1926
limited treatment of automatic fire
suppression.)
28
Fire prevention (1926.151)
There are exceptions to the previous
statement regarding conservatism.
More conservative requirements for the
construction (.151(b)(2)) and location
(.151(b)(3)) of “temporary buildings” than
those found in DOE-STD-1088-95, “Fire
Protection for Relocatable Structures.”
29
Flammable and combustible liquids (1926.152)
This section contains a mixture of specific
and general requirements. Many of them
are vague. Example: “Inside storage
rooms shall be constructed to meet the
required fire-resistance rating for their
use.” This necessitates consulting the
building code and NFPA 30. Complying
with NFPA 30 should assure conformance
with 1926.152.
30
Liquefied petroleum gas (1926.153)
This section contains requirements that
are less comprehensive than the criteria
delineated in NFPA Standard 58,
“Liquefied Petroleum Gas Code.”
Compliance with NFPA 58 will assure
conformance with 1926.153.
31
“Stealth Requirements”
In places, 1926 contains imbedded requirements
that are (may be) applicable to DOE fire
departments and the fire protection program in
general. Examples:
Requirement for exit sign letters to be printed
on a “white field” (1926.200(d))
Requirements for natural and synthetic rope
(1926.251(d))
Requirements for power-operated hand tools
(1926.302)
32
Subpart J – Welding and Cutting (1926.350)
This section contains a combination of
general and specific requirements. Its
requirements for fire safety are very weak.
(It says nothing about fire-resistant PPE,
for example.) DOE’s requirement to
comply with NFPA Standard 51B PLUS
conformance with the DOE “Safety &
Health Bulletin” that was issued after the
K-25 fatality (DOE/EH-0196) should
assure conformance with 1926.350.
33
Subpart K – Electrical (1926.449)
This section parallels the requirements of NFPA
70, “National Electrical Code,” but does not
contain as must elaboration of conditions. For
example, considering the classification of
locations, Subpart K provides a clarifying note
that corresponds to FPN 1 of Section 500.5 of
NFPA 70. But it does not reflect the text of FPN
2, which provides additional insights into the
classification of locations that contains pipes and
tanks and exhaust ducts (which have much
relevance to DOE). Therefore, conformance with
NFPA 70 will likely assure compliance with .449.
34
Subpart L – Scaffolds (1926.451)
In this section is a good example of a
requirement for worker safety (falling
object protection) that affects fire safety
(sprinkler discharge).
.451(h)(3) requires the installation of
canopies to protect workers without
mentioning the need to assure that
overhead sprinklers are not blocked.
35
Subpart M – Fall Protection (1926.500)
While this section would not impact DOE
fire departments or brigade directly, it
contains useful requirements that should
be consulted when planning training
evolutions on roofs and similar high-up
locations. (If you have one of your fire
fighters fall during such training, you can
bet that these criteria are going to be used
to evaluate your training program safety.)
36
Subparts N & O – Cranes, Derricks,
Mechanized Equipment (1926.550 & .600)
As a fire chief or emergency manager, you
might not normally think about safety
requirements in these sections as being
applicable to you. But…
…consider the potential need for and
use of bulldozers in wildland fire mitigation.
(This was an issue in a DOE wildland fire at
Oak Ridge.) .602 requirements for earth
moving equipment might be considered
applicable if you have an accident.
37
Subpart S – Underground safety (1926.800)
Considering the many underground areas
in DOE (accelerators, tunnels,
underground repositories, facilities to be
constructed underground, etc.), the
requirements of this section loom large.
This section requires careful study by fire
protection program managers, fire chiefs
and emergency managers. Consider…
38
Subpart S – Underground safety continued...
…the .800(g)(5)(i) requirement to provide “…two
five-person rescue teams, one on the
jobsite…”
…the .800(g)(5)(iv) requirement to practice
donning SCBA on a monthly basis
…the .800(m) restrictions on 1-day supply of
diesel fuel storage underground and the
prohibition of the use of gasoline underground
Note: Critical to the applicability of this section is
the definition of “underground chamber.”
39
Subpart T – Demolition (1926.850)
This brief section contains some
requirements that can seem contradictory
to some NFPA Std. 241 and DOE
requirements. Two examples are
illustrative:
.850(c) requirement to shut off all
utilities (including water) prior to demo
.851(a) requirement to close off
stairways that are not required for
“access.”
40
Subpart U – Explosives (1926.900)
The challenge for the DOE explosives
safety community is to reconcile the
requirements with those contained in the
DOE Explosives Safety Manual.
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Subpart X – Stairways and Ladders (.1050)
Be sensitive to the fact that this section permits
a lesser capability to that required under the
emergency egress requirements of Part 1910
and the Life Safety Code. Consult DOE D&D
guidance and be conscious of the additional
hazards facing workers attempting to escape a
fire and related event. Also, emergency
responders will face more challenges getting
into buildings provided with stairs and ladders
designed to comply with this section.
42
Subpart Z – Toxic Substances (1926.1100)
This section contains very detailed requirements
and references the requirements in 29 CFR
1910 to protect “worker” exposed to a spectrum
of substances. Emergency responders may also
be exposed to these same substances as part
their duties. Are you sensitive to what their
exposure might be, what additional PPE might
be necessary to avoid exposure, what additional
reporting requirements might be applicable,
what additional health monitoring might apply?
(You might want to be.)
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Summary
These few slides are no substitute for becoming
more familiar with the text of 29 CFR 1926.
Consider them more of a roadmap. Your
technical libraries should contain copies of the
regulations and representatives of your staffs
should take further OTI courses. Your self
assessments are required to reflect the fact that
you evaluated yourself in comparison to them
(just like NFPA codes and standards.)
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Questions should be directed to:
Dennis Kubicki, P.E.
301-903-4794
[email protected]
All E-mail questions sent to the above
address will be answered in writing,
collected, and distributed to all of the
attendees of this OTI course.
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