Transcript NFPA 51B and OSHA 1910.252 - Marine Chemist Association
Guy Colonna, P.E.
55 th Annual MCA Seminar Bar Harbor, ME July 16, 2013
Cadillac Mountain, Acadia National Park
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Agenda
Background Confined space statistics Recent incidents – CSB issues OSHA 29 CFR 1910.146, Permit-Required Confined Spaces - overview Aboveground Storage Tanks API resources TES Certification program Practical issues Marine Chemist role Closing 3
PRE-INVENTORY
1. An OSHA confined space has the following: a) b) c) d) large enough to permit entry intended for continuous occupancy normal atmospheric ventilation limited or restricted entry or exit
PRE-INVENTORY
2. The following are tank classifications found in OSHA 29 CFR 1910.146, Permit Required Confined Spaces.
a) b) c) Non-confined space Non-permit required confined space Permit required confined space
PRE-INVENTORY
3. API 2015 and 2016 use which of the following safety designations?
a) b) c) d) e) Enter with restrictions Enter without restrictions Enter with special precautions Enter when inerted All of the above
PRE-INVENTORY
4. What is the maximum safe level of oxygen according to 29 CFR 1910.146?
a) b) c) d) e) 10% 19.5% 20.9% 23.5% None of the above
PRE-INVENTORY
5. According to the Permit-Required Confined Space standard, no permit is required when the space is unsafe. True False
Hazard Awareness
Lessons Learned
CSB Report – June 2007 Lack of hot work safety – Failure to recognize the hazards - use of welding tools in a flammable vapor environment – Failure to isolate fuel and ignition sources – Failure to manage hazards with well established, safe work practices (API, NFPA, OSHA) Makeshift work platform Safe hot work guidelines – NO permit issued
CSB Video – Death in the Oilfield
Hawaii
October 17, 2008 Welding part of a catwalk connected to the top of an oil storage tank Tank was approximately 15 feet tall and reportedly contained waste oil Vapors from the tank were ignited by the welding activities and caused the explosion that propelled tank 30 feet One fatality, 3 injured, 2 seriously
Ohio
October 20, 2008 Welding catwalk on one of four large crude oil storage tanks at drill rig site when a tank exploded Two fatalities CSB sent investigative team – Looking for similarities with Hawaii and Mississippi
Seven Lessons from CSB Report
Seven Lessons from CSB Report
RECOGNITION
“Hazard Identification & Risk Assessment” Identification of Spaces According to Definition Identification of Hazards Atmospheric (oxygen, flammability, toxicity) Engulfment Entrapment Other physical or mechanical (energy sources, heat stress, noise)
EVALUATION
“Confirm or Deny Presence of Hazards and Determine Severity” Qualitative Assessment Use MSDS, other reference sources, and senses (subjective) Quantitative Assessment Measurement of atmospheric components; compare test results to established standards to determine whether a safe condition exists (objective)
CONTROL
“Action taken to eliminate or minimize hazards” Engineering Ventilation Administrative Isolation Substitution Safe Work Practices Permits Training Personal Protective Protective Clothing Respiratory Protection Follow-up atmospheric monitoring Emergency and rescue
OSHA Points to MC for CS Evaluation – 1910.146, Appendix B
Atmospheric testing is required for two distinct purposes: evaluation of the hazards of the permit space and verification that acceptable entry conditions for entry into that space exist.
Evaluation testing. The atmosphere of a confined space should be analyzed using equipment of sufficient sensitivity and specificity to identify and evaluate any hazardous atmospheres that may exist or arise, so that appropriate permit entry procedures can be developed and acceptable entry conditions stipulated for that space.
Evaluation and interpretation of these data, and development of the entry procedure
(e.g., OSHA consultation service, or certified industrial
certified marine chemist
, should be done by, or reviewed by, a technically qualified professional hygienist, registered safety engineer, certified safety professional, , etc.) based on evaluation of all serious hazards.
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OSHA DEFINITION 29 CFR 1910.146
A confined space must have these characteristics:
Large enough and so configured to permit entry and work Not designed for continuous human occupancy Limited or restricted means of entry and exit
PERMIT-REQUIRED CONFINED SPACE (PRCS)
Is a confined space that contains or may contain:
Hazardous atmosphere (oxygen content, flammable, or toxic) Engulfment hazard Entrapment hazard Other recognized serious safety hazard
CONFINED SPACE EXAMPLES
Aboveground and underground storage tanks Process vessels Grain silos Bins Hoppers Sewers Utility vaults Tanks on marine vessels
Confined Space Example – Diked Area
PRCS PROGRAM REQUIREMENTS
Written program Identify and classify spaces Establish hazard control measures Prevent unauthorized entry Establish acceptable conditions Isolation Ventilation Coordinate entry by multiple workers Periodic reevaluation for change of conditions
PRCS PROGRAM REQUIREMENTS
Develop permit system Preparation Issuance Implementation Cancellation Returning space to service
PRCS PROGRAM REQUIREMENTS
Provide specialized equipment Atmospheric monitoring Ventilation PPE Lighting Communication Emergency
PRCS PROGRAM REQUIREMENTS
Designate key personnel Entrants Attendants Entry supervisor Qualified atmospheric tester Emergency response
PRCS PROGRAM REQUIREMENTS
Perform testing and monitoring Prior to entry and periodically during entry and work Establish rescue and emergency procedures Procedures for contractors - multi-employer work sites Provide information and training Conduct program review
Confined Space Classifications
Non-Permit Required Confined Space (API & OSHA) Permit Required Confined Space (API & OSHA) Non-Confined Space (API)
Non-Permit Required Confined Space
Remember what a confined space is!
Large enough and so configured to permit entry and work Limited or restricted entry or exit Not designed for continuous occupancy Non-permit means the confined space has no identified hazards
Permit-Required Confined Space
All characteristics of confined space as defined Possesses one or more identified hazards Hazardous Atmosphere Engulfment hazard Entrapment hazard Other serious recognized hazard
Hazardous Atmosphere
Expose employees to – Risk of death Incapacitation Impairment of ability to self-rescue Injury Acute illness As a result of exposure to –
Hazardous Atmosphere Criteria
Flammable gas, vapor, mist in excess of 10% of lower flammable limit (LFL) Airborne combustible dust at its LFL ** Oxygen concentration less than 19.5% and greater than 23.5% by volume Toxic exposures in excess of PEL as found in Subpart G or Subpart Z Any IDLH concentrations Contains or potential, serious harm
DESIGNATED PERSONNEL - Entrant
Trained to recognize hazards Trained to use PPE as required Communicate with attendant as necessary Recognize symptoms of exposure Understand principles of self-rescue
DESIGNATED PERSONNEL Attendant
Remain outside space at all times Trained to recognize hazards and exposure symptoms Communicate with entrants Communicate alarm, evacuate if necessary May monitor more than one space at a time Prevent unauthorized entrants Alert to changing conditions
DESIGNATED PERSONNEL – Entry Supervisor
Trained to recognize hazards Authorizes entry based upon hazard assessment, identify acceptable conditions Verify emergency plans and rescue personnel availability Revoke permit if conditions change adversely Terminate permit at job completion
DESIGNATED PERSONNEL Qualified Atmospheric Tester
Responsible for conducting atmospheric monitoring Trained to properly select, calibrate, use and maintain all required instruments May be any of the key personnel - entrant, attendant, supervisor
DESIGNATED PERSONNEL - Rescue and Emergency Services Either on-site or off-site permitted Trained at least as entrants and in use of rescue equipment Trained in basic first-aid/CPR and at least one member certified in both Conduct annual drill Coordination between employer and off-site provider
ANSI/API 2015 – Summary
Scope and Applicability Applies to atmospheric and low-pressure aboveground petroleum storage tanks Includes decommissioning, hazard assessment, permit entry and work system, emergency planning, and recommissioning Does not apply to pressure vessels, process vessels, underground storage tanks Industry specific application of OSHA requirements in 29 CFR 1910.146
Testing the Tank Atmosphere
Determine what atmospheric hazards to test for based upon MSDS or other source Determine safe exposure limits Develop written calibration requirements Maintain verification of calibration for 1 year Calibrate according to manufacturer
Atmospheric Testing
Test in specific order Test from outside tank initially Test atmosphere outside the tank as well Especially during degassing Shut down ventilation prior to testing Rule of thumb 10 – 15 minutes Conduct periodic or continuous monitoring Specialized testing – lead-in-air
Storage Tank Hazards
Oxygen content Fire and explosions Toxic substances Hydrogen sulfide Organic Lead Inorganic Lead Aromatics NORM Other Physical and other hazards Tank function or design Tank condition Tank location Physiological hazards (heat stress or cold stress)
API RP 2016 – Summary
Tank Entry Supervisors will have the understanding, knowledge and skills to implement the specific tank cleaning procedures and practices presented in API 2016 in order to meet the requirements of ANSI/API 2015
Tank Entry Designations
Enter Without Restrictions Enter With Restrictions Enter With Special Precautions Entry When Inerted (See API 2217A)
Enter Without Restrictions
Oxygen content – 19.5% to 23.5% by volume Hydrocarbon vapor-in-air level inside the tank is 10% LEL or less Atmospheric toxic levels inside the tank are within established exposure limits (PEL or TLV)
Enter With Restrictions
The actual or potential atmospheric concentration levels require appropriate protective equipment or adjusted time Review NFPA 326, Standard for the
Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair
Similar designation
Enter With Special Precautions
This designation applies when: Oxygen content inside the tank is < 19.5% by volume Hydrocarbon vapor-in-air level inside the tank is > 10% LEL Atmospheric toxic levels inside the tank exceed the established exposure limits (PEL or TLV)
Entry When Inerted
The oxygen content within the tank is less than 8% by volume (or less than 50% of the lowest oxygen concentration level required to support combustion – Limiting Oxidant Concentration (LOC)) NFPA 69, Standard on Explosion Prevention Systems contains values for LOC Becomes an Enter With Special Precautions
Non-Confined Space
Does not meet any conditions necessary to be considered a confined space Atmospheric conditions same as ambient No restrictions on entry or exit Tank has been isolated See provisions in OSHA 29 CFR 1910.146 (c)(7) concerning reclassification
Example of non confined space – one that could be reclassified by 1910.146(c)(7)
API Tank Entry Supervisor Certification (TES)
Objective: Enhance the quality and competency of tank entry and maintenance activities Minimize the risks of confined space hazards Improve the overall safety performance of tank maintenance operations Process – combination of experience and examination 53
Project Planning
Scope of Work & Site Plan Materials & Equipment Information Safety & Emergency Response Personnel Qualification & Training Classification & Work Permits Hazards – Hazard Communication Tank Information
Tank Preparation
Facility Permits & Work Orders Position Equipment Remove Recoverable Product Isolate Tank Position, Bond & Start Eductor Open Manway & Remove Remaining Product
Ventilation and Atmospheric Testing
Identify supervisors & workers Ventilate Tank Conduct External Atmospheric Testing Continue Ventilation & Retest Issue Permits for Internal Testing
Enter to Visually Inspect and Evaluate
Assess, Identify & Address Hazards Implement CS Entry Program & Emergency Response Program Test & Obtain Permits to Enter Perform Pre-Clean Safety Inspection Verify or Revise Scope of Work Certify Tank Safe to Enter
Clean Tank
Implement Cleaning Plan & Permits Maintain Ventilation & Testing Identify & Address Special Hazards Monitor Activities & Security Cancel Permits, Stop Work & Exit Tank if Conditions Change Verify Completion of Cleaning
Entry for Repair
Implement Work & CS Entry Plans Identify, Address & Monitor Hazards Determine Classification of Tank Supervise & Monitor Work Activity Maintain Site & Tank Security Cancel Permits, Stop Work, Exit and Safe tank if Conditions Change
Return to Service
Inspect Tank Before Closing Verify Recommissioned as Planned Address Tank Changes Secure Tank & Clean Area Conduct Post-Entry Briefing
API RP 2009, Safe Welding, Cutting
and Hot Work Practices
Scope – Provide guidelines for safely conducting welding, cutting and other hot work activities in the petroleum and petrochemical industries Hot tapping is excluded and covered by API RP 2201 Hot work defined as any operation that can produce sufficient heat, flame, spark or other source of ignition with the energy to ignite flammable gas, vapor or dust
API RP 2009
Job analysis Hazard evaluation and risk reduction Implementation of safeguards Testing for hazards Hot work permits Hot work in confined spaces Work inside vessels Work on exterior Work on equipment in service Work in buildings and pits Work on piping
NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair Chapter 4 – Basic Precautions Chapter 5 – Preparation for Safeguarding Chapter 6 – Testing Procedures Chapter 7 – Control or Removal of Vapors Chapter 8 – Inspection and Certification of Tanks and Containers Chapter 9 – Procedures for Access to and Entry of Tanks Chapter 10 – Cleaning Tanks and Containers
NFPA 326 Purpose
Establishes minimum requirements for the safe opening, entry, and cleaning of a tank or container that contains or has contained flammable, combustible, or other hazardous substance vapors, liquids, or solid residues …the safe removal of flammable, combustible, or other hazardous substance vapors, liquids, or solid residues from tanks or containers and the safeguarding of these vessels for entry, cleaning, or repair …the minimum procedures that permit repair, hot work, or other operations that have the potential to create a fire, an explosion, or another hazard
Chapter 6 – Testing Procedures
Safe entry, cleaning, or repair work requires tests for oxygen, flammable/combustible, or other hazardous substance vapors, with an appropriate instrument: Before entry or re-entry Before start of alterations or repairs Before and during any hot work operations Continuously or periodically during the work After cleaning tanks to determine that cleaning is effective After any process or activity that might change conditions Precautions also taken to ensure that tanks or containers that have held liquids with high flash points do not become hazardous during cutting and welding operations
Chapter 8 – Inspection and Certification of Tanks and Containers
8.2.4 Hot Work Allowed Establishes atmospheric thresholds Oxygen enrichment – less than 23.5 % oxygen Flammable/combustible atmospheres – 0 % LFL Residues – removed sufficiently to prevent regeneration of dangerous concentrations of contaminants Adjacent spaces highlighted (as applicable)
NFPA Safe Tank Entry Training Summary
Establish safe work practices based on recognition, evaluation, and control principles Recognize hazards inherent to space design as well as use or function Recognize that work can change initial conditions Perform frequent atmospheric monitoring Use forced mechanical ventilation Establish permit system Train on safe work practices
Role for the Marine Chemist with AST
Might not always be called to establish initial entry Role of the attendant – frequent retesting of conditions Hot work Atmospheric monitoring expertise – especially for toxicity Recognized within the petroleum/petrochemical AST environment 68
OSHA Standards
1910.106 - Flammable and Combustible Liquids 1910.146 - Permit-Required Confined Spaces 1910.134 - Respiratory Protection 1910.147 - Control of Hazardous Energy 1910.1000 - Air Contaminants 1910.1200 - Hazard Communications
NFPA Codes & Standards
NFPA 30, Flammable and Combustible Liquids Code NFPA 326, Safeguarding Tanks or Containers for Entry, Cleaning or Repair Related informational documents – NFPA 306, Control of Gas Hazards on Vessels NFPA 69, Explosion Prevention Systems
Key API Standards & Recommended Practices
ANSI/API Standard 2015, Safe Entry and Cleaning of Petroleum Storage Tanks, 6 th Edition (2001) ANSI/API Recommended Practice 2016, Recommended Practice for Entering and Cleaning Petroleum Storage Tanks, 1 st Edition (2001) API Publication 2217A, Guidelines for Work in Inert Confined Spaces in the Petroleum Industry, 2 nd Edition (1997) API Publication 2219, Safe Operation of Vacuum Trucks in Petroleum Service, 2 nd Edition (1999)
Informational API Standards & Recommended Practices – Part I API Standard 653, Tank Inspection, Repair, Alteration, and Reconstruction (2001) API RP 2003, Protection Against Ignitions Arising out of Static, Lightning and Stray Currents (1998) API Publication 2009, Safe Welding, Cutting and Other Hot Work Practices in Refineries, Gas Plants and Petrochemical Plants (2002) API Publication 2026, Safe Access/Egress Involving Floating Roofs of Storage Tanks in Petroleum Service (1998)
Informational API Documents – Part II
API RP 2027, Ignition Hazards and Safe Practices for Abrasive Blasting in Atmospheric Storage Tanks in Hydrocarbon Service (2002) API Publication 2201, Procedures for Welding or Hot Tapping on Equipment in Service (1995) API Publication 2202, Dismantling and Disposing of Steel from Leaded Gasoline Aboveground Storage Tanks (1991) API Publication 2207, Preparing Tank Bottoms for Hot Work (1998)
Informational API Documents – Part III
API Publication 2220, Improving Owner and Contractor Safety Performance (1998) API Publication 2221, Manager’s Guide to Implementing a Contractor Safety Program (1996) API Publication 2350, Overfill Protection for Storage Tanks in Petroleum Facilities (1996)