FREE DOWNLOAD of ANSI Z49.1:2012 Safety in Welding, Cutting, and Allied Processes
In my world of Process Safety I often hear OSHA being blamed for not being specific enough and if the OSHA standards were more specific… “these horrible accidents would be fewer”. I wholeheartedly disagree with this line of thought. Case in hand… in my incident alerts this year there have been numerous fatalities from workers doing hotwork on used drums and tanks. This week three workers in AR died by doing hotwork on a tank that contained flammable vapors! If OSHA is really the problem because they write vague standards, how is this even remotely close to being vague…
1910.252(a)(3) Welding or cutting containers.
1910.252(a)(3)(i) Used containers. 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.
When OSHA uses a phrase like “absolutely certain”, it cannot be put more clearly; so how does one find a way to blame OSHA for these types of accidents. Do we really believe that OSHA is too vague in 1910.252(a)(3)(i)?
I will grant anyone the other side of the argument that it is RARE to find this definitive type of text in OSHA standards. But the facts are clear in this example – OSHA cannot be more clear in the requirement and yet we are still blowing up workers who weld on used drums and tanks. Accurate Safe Work Practices, Training, and Enforcement of the SWPs and the training is where we have the breakdown in safety!
We can NOT rely on OSHA to protect us. That is the employer’s job; OSHA just sets the bare minimum standards! The employer hires safety professionals to help navigate the safety standards AND more importantly they are hiring us to lead the business to EXCEED the minimum safety standards found in the OSHA standards. A safety professional can NOT pick-up any hotwork/welding safety standard and not find where welding/cutting/brazing on used containers is prohibited. The American Welding Society makes their ANSI Welding Safety Standard (ANSI Z49.1:2012 Safety in Welding, Cutting, and Allied Processes) available for FREE!!! This ANSI standard states the following about welding on tanks:
E6.4 All containers should be considered unsafe for welding or cutting unless they have been rendered safe, r declared safe by a qualified person. When welding or cutting containers, there is the possibility of explosions, fires, and the release of toxic vapors or fumes. Containers include jacketed vessels, tanks, drums, covered parts or other equivalent situations. Seemingly empty containers might have materials hidden in cracks and crevices, which will release hazardous fumes when heated by welding or cutting. By-products of corrosion can result in explosive atmospheres (hydrogen) in a container. Even a water tank should be considered hazardous unless a qualified person has declared it safe to weld or cut. Information on preparing containers that have held hazardous substances can also be found in NFPA 326, Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair, and several API documents. See Annexes B and C for details.
With these accidents still occurring we, as a profession and as individual safety professionals, need to up our game and draw a line in the sand when someone comes up the idea of cutting into a tank. The most effective way we can do this is to ensure that any welding/cutting/brazing training includes these PROHIBITED acts and some of us may even want to revise our hotwork permit to include a warning statement about welding on vessels. Whatever we are doing – we need to do more.
CLICK HERE to download this FREE ANSI Welding Safety Standard (2012 Edition).