Recently I was working with one of my flammable liquid clients who recently hired some new engineers who needed some flammable liquids training. During my 1-day “Flammable Liquids 101” course we touch on those flammable liquids that are “non-conductive,” and as usual this caused quite a stir among the attendees. Most of the attendees, including the engineers, wanted to challenge the concept that with non-conductive flammable liquids the basic bonding and grounding practices will not be adequate to control static generation. The new engineering manager was pushing back against my NFPA/API content regarding non-conductive flammable liquids, and said he would need to see this material directly in an NFPA or API standard before he could become a “believer.” Luckily the site safety engineer was in attendance, and he and I have been working to get this facility (and those within the company that are interested) up to speed on their handling/processing techniques for their non-conductive flammable liquids. And before I could pull up NFPA 77, the site safety engineer had pulled up the Safety Data Sheet (SDS) on this material to support the training content. I was so happy to see an SDS written as a SAFETY DATA SHEET! Here is what the SDS stated regarding handling this non-conductive flammable liquid:
(emphasis by me)
Eliminate sources of ignition. Avoid spark promoters. Ground/bond container and receiving equipment. These alone may be insufficient to remove static electricity.
The static-accumulating flammable liquid can become electrostatically charged even in bonded and grounded equipment. Sparks may ignite liquid and vapor may cause flash fire or explosion.
Handling operations that can promote accumulation of static charges include but are not limited to mixing, filtering, pumping at high flow rates, splash filling, creating mists or sprays, tank and container filling, tank cleaning, sampling, gauging, switch loading, vacuum truck operations. Restrict flow velocity according to API 2003 (2008), NFPA 77 (2007), and Laurence Britton, “Avoiding Static Ignition Hazards in Chemical Operations.” To reduce the potential for static discharge, ensure that all equipment is properly grounded and bonded and meets appropriate electrical classification requirements.
So on this SDS (as well as all this manufacturer’s non-conductive flammable liquids), they make a point, in three (3) different spots, about the fact that the essential bonding and grounding practices may not be enough to control the generation of static electricity. I was even more impressed when the SDS actually provided safety practices, such as restricting flow rates as called out in NFPA 77, to handle/process this non-conductive flammable liquid safely.
But this got me thinking… if the manufacturer of the hazardous material put this kind of information on their SDS, does this open the door for OSHA to issue citations against an employer who is not managing flow rates per NFPA 77 or API 2003.
(NOTE: SAFTENG members should see my article “Controlling flow rates of non-conductive flammable liquids“)
Did the manufacturer make NFPA 77 and/or API 2003 an enforceable standard by putting this language on their SDS? As a safety professional, I say this is the way an SDS is supposed to be written, but I have a feeling there will be some who disagree. What is written is 100% factual and MUST be followed to ensure safety while handling/processing these non-conductive flammable liquids; however, for those that do not practice process safety, the concept of adopting a Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) is foreign to most. I would have to imagine that if this hazardous material was involved in an accident that involved ignition of its vapors, which any investigator would look to find an ignition source. And if the user were not doing more than bonding and grounding to control the static generation, he/she would find it difficult not to rule out static electricity. And if the investigator was with OSHA or EPA, could they issue a citation against an SDS directive that the employer did not abide by?
Oddly enough, I am not sure what citation OSHA would issue using 1910.1200. Regardless of what OSHA would do or not do, it sure is nice to see SDS’s contain this kind of helpful information, after all, SDSs are our starting point in how we should be handling our hazardous chemicals, so having this kind of quality information starts the right discussion much earlier in the chemical approval process.