Hazardous Materials

On 3/28/2016, for reasons unknown, the EPA withdrew its notice of proposed rulemaking (NPRM) at the Office of Information and Regulatory Affairs (OIRA) regarding possible modifications to reportable quantities. The NPRM was submitted on 3/6/2018. … Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

In my line of work, I come across a lot of areas that have a “ventilation system” that intends to reduce exposure and control flammable gases/vapors.  The vast majority of these systems are “sized” properly, meaning they move enough air to meet the code/standard they were built to; however, one aspect of the system we…...

To quote the IFC committee, “the purpose of performance-based design criteria is to promote innovative, flexible and responsive solutions that optimize the expenditure and consumption of resources while preserving social and economic value.”  Section 5001.3 Performance-based design alternative is intended to be compatible with EPA’s RMP and OSHA’s PSM requirements, so it would reduce the burden…...

This recent event is an excellent example of why vessels have Minimum Design Metal Temperatures (MDMT) and what can happen when they are exceeded.  It also is a nice example of how API RP 579-1 / ASME FFS-1, Fitness-For-Service standard can be used to ensure a vessel is fit for continued service.   On January 22, 2018,…...

I am not quite sure why they did this, but the ICC decided that the requirements for “leak detection” and “emergency shutoff” for high hazard gases and liquids ONLY apply when the “maximum allowable quantity per control” area is exceeded.  This was done by moving these requirements from Section 5003 where they applied to any quantity…...

Due to the potential environmental impact, there has been a shift to consider use of natural refrigerants, which have a lower Global Warming Potential (GWP) than traditional fluorocarbon based refrigerants. One type of natural refrigerant are hydrocarbons (e.g. propane), which are classified as Class A3 refrigerants per ASHRAE Standard 34. The Environmental Protection Agency (EPA) has a charge limit…...

This week the state of Oregon removed the prohibition of citizens fueling their own vehicles at gas pumps; leaving the state of New Jersey as the sole state that prohibits their citizens from pumping their own gas.  Here is an excellent article explaining how these prohibitions began in New Jersey.  But the reaction of the…...

In 2007 the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) revised their standard #34 to include a new Flammability Classification called “2L” Refrigerants.  This new class is based on burning velocities and their lower pressure rise when they are ignited.  The IFC 2018 Edition has caught up and now includes some specific requirements and exemptions for…...

In our line of work, we come across some real doozies when it comes to fire protection arrangements. One of the more common issues we come across is the obstruction of sprinkler heads. Since 1980 OSHA has required that we maintain our storage at least 18″ below any sprinkler head. 1910.159(c)(10) Sprinkler spacing. The employer…...

I am working on a code evaluation project, and the client had a different interpretation (more strict) that I did so I reached out to the Ohio Fire Marshal to settle the discussion.  The question arose as to how much flammable solid(s) can one store without having to raise the occupancy classification to an “H.” TABLE 307.1, Maximum…...