Both OSHA and NFPA state that if the pipe does NOT terminate within the space, the pipe does NOT have to be evacuated to consider the contents of the pipe a “potential” to generate a HAZ ATM. In a recent OSHA LOI, OSHA used several thresholds that the employer should/must use in its evaluation of this pipe…
Response: The OSHA permit required confined space standard is a performance-oriented standard and requires an evaluation be made per 29 CFR 1910.146(c)(1) to determine if any "confined spaces" are "permit-required confined spaces", as defined by the standard. If the spaces in question meet the definition of a permit required confined space, and entry is authorized, 29 CFR 1910.146(d)(3)(iii) requires employers to isolate the permit space prior to entry. Piping that contains flowable materials such as water or steam must be isolated when the employer's evaluation determines that due to the condition of the piping, valves or flanges, manipulation and/or work performed related to the valve or flange, work done adjacent to the piping, valves and flanges, or for other reasons there exists a potential for the piping inside the space to rupture or leak into the space and potentially result in engulfment, burns, or other serious safety or health hazard to an entrant. If the employer's evaluation of the space determines that the piping does not terminate in the space and that no potential exists for rupture or leakage of materials into the space, then isolation of the piping is not required.
In other words, we can have a pipe that “passes through” a space full of hazardous material; as long as no work is being done on said pipe(s), the pipe (s) do NOT have to be isolated and evacuated.
But OSHA’s standard for reclassifying the space to a non-PRCS states:
1910.146(c)(7)(i) If the permit space poses no actual or potential atmospheric hazards and if all hazards within the space are eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated.
I wonder what assurances the employer would expect to say there is “no potential”?
- Schedule of Pipe?
- Age of Pipe?
- Installation of pipe was to B31 series (certified welder, visual inspection, pressure/leak test records)?
- Is the pipe in some type of mechanical integrity inspection/testing program?
My position is, if there is a hazardous material within the space, there is ALWAYS a “potential” for its release. Not until we isolate the piping and evacuate the hazardous material can we say there is “no potential”. I see tons of HAZMAT piping that was NOT installed to any engineering standard, such as the ASME B31 series, and it’s never been inspected/tested during its 10/20/30/40-year life span. The answer we almost always get is “the pipe is not in a PSM/RMP-covered process, so none of that ‘stuff’ is required”; yet the employer claims to have assurances the pipe will not fail/leak during the entry. We see this on PSM/RMP-covered chemicals, just that the process does not exceed the PSM/RMP threshold. SO we could have a 1″ Chlorine pipe at 150 psig STILL IN SERVICE and passing through a space, and OSHA’s position is to “evaluate” the risks of this arrangement.
PURE INSTANTIY! I bet we could not get 10 safety people to agree on the level of this evaluation and what documentation they would request in order to perform this “evaluation” before signing off on the “reclassification” documentation.
I will remind everyone of the official definition of “potential”…
"Potential" means capable of growing, happening, or becoming real in the future. It describes a hidden or unused ability or a possibility that something might exist or happen.
Source: NFPA 350, 8.6.5 and OSHA’s latest PRCS LOI (https://lnkd.in/eC6QF8EZ)