We have discussed all the requirements for transferring flammable liquids and gases (i.e., NFPA Flammable “4”); however, I have not mentioned the requirements for transferring TOXIC and HIGHLY TOXIC LIQUIDS that have an NFPA 704 Health Rating of 3 or 4. We see these issues in our Chlorine work where Cl2 is a “utility” to the business and is sort of “out of sight – out of mind” until there is a LOPC event. Many facilities also overlooked their state fire code requirements as a great baseline RAGAGEP for their “primary containment” systems, such as piping.
The IFC provides us with some excellent baseline line designs that should be incorporated into our process, regardless of whether or not the State Fire Marshal enforces the requirements. We do these things to IMPROVE PROCESS SAFETY (not PSM/RMP compliance!), not to make the SFM happy.
(Emphasis by me)