Much of my work involves helping clients achieve more than “compliance” with minimum government standards. I typically do this using RAGAGEPs; however, those may be too much to handle in some situations. So, I will propose another government standard that applies to the process/hazard. For example, unloading flammable liquid railcars. Canada has some of the…...
Railcar Loading and Unloading operations (Canada) Read More »
In the old days, the secondary containment around flammable liquid storage tanks could be a single system in which all the storage tanks sat. Today, that is NOT the case. Both NPFA 30 and IFC Chapter 57 require the secondary containment to be such that an LOPC from one tank can NOT impact the other…...
Old secondary containment design vs. New secondary containment design Read More »
In terms of Fire and Building Codes, we have five (5) recognized areas associated with handling hazardous materials. We refer to these high-hazard areas/occupancies as “Group H”. High-hazard Group H occupancy includes, among others, the use of a building or structure, or a portion thereof, that involves the manufacturing, processing, generation or storage of materials…...
Differences between a H-2 and H-3 occupancy Read More »
One mistake many businesses make is their assumptions about how their flammable liquids will behave once they are outside of their primary containment. I have seen companies spend millions of dollars to classify an area as a HAZLOC when it was not even close to being necessary, and I have seen some PSM businesses claim…...
When do I need to consider desinging and managing an area as a HAZLOC? Read More »
On January 13, 2022, workers inside the company’s fabrication shop performed a “wet test” on a newly built tank truck to check for leakage. This entailed running diesel test fuel through different tank compartments and other truck components. This was a routine operation at the workplace. Workers knew never to use gasoline, and the company…...
I have written several articles on the topic of when we store our flammable liquids BELOW their flash points with the aid of refrigeration and how that makes our “refrigeration/chiller” a critical utility if we wish to take credit for storing the flammable below its FP. I have also discussed processing a Class IIIB/Cat 4…...
Operating above the solution’s Flash Point Read More »
Are “safety cans” created equally? Nope, and which UL standard they meet will dictate how much “safety they provide.” OSHA’s 1910.106 defines a “safety can” as Safety can shall mean an approved container, of not more than 5 gallons capacity, having a spring-closing lid and spout cover and so designed that it will safely relieve…...
Safety Cans… did you know? Read More »
Have you ever walked up to a atmopsheric storage tank and seen the paint bubbling and the hazard signs/placards faded/peeling off? Look up and you will most likely see the atmopsheric vent line on that side of the tank. What are these indicators of? The tank being over filled, which is a serious event and…...
“Over-Fill” requirements for Flammable Liquid Storage Tanks Read More »
Although it is done often, most state Fire Codes PROHIBIT the use of DOT tank vehicles and tank cars as “Flammable Liquid Storage Tanks.” We call this “dropping trailers,” and my 2014 Article “Dropping Trailers of Flammable Liquids” got quite the debate going. But trust me, there are sound engineering reasons why we can not…...
This is another opportunity for facility sitting to apply specific metrics to the exercise. Just as the distances for Tank Truck and Rail Car Unloading/Loading facilities are intended to protect our bulk storage tanks, this is intended to prevent BLEVE(s) that could impact the above-ground storage tank. (emphasis by me) 1910.106(b)(2)(ii)(f) The MINIMUM SEPARATION between…...
Facility Siting – LPG Containers and Flammable Liquid Tanks (OSHA & NFPA) Read More »
In some cases, we can actually put specific measurements in our “facility siting” analysis. Take, for example, an old but often missed distance between the tank truck/railcar and the closest aboveground tank. (emphasis by me) 1910.106(e)(4) Tank vehicle and tank car loading and unloading. 1910.106(e)(4)(i) Tank vehicle and tank car loading or unloading facilities shall…...
Facility Siting – Tank vehicle and tank car loading and unloading (OSHA & NFPA) Read More »
A common question we get regarding flammable liquids is: Do we have to ground and bond non-conductive containers smaller than 5 gallons? The proper question should be… what do we need to do to SAFELY transfer flammable liquids into non-conductive containers that are 5 gallons and smaller? The British Columbian Worker’s Compensation Board…...
