Hazardous Materials

Where does it require I have an Oxygen Monitor when I use liquid Nitrogen?

OSHA may use its General Duty Clause (GDC) to require employers to install oxygen monitors in areas where inert cryogenics are stored or used.  But I like to use codes/standards (e.g., RAGAGEPs) to guide my safety engineering for these hazardous processes, even though PSM/RMP does not cover them.  To do this, I turn to the…...

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Liquid Nitrogen and the IFC (Part I)

This week, we saw OSHA issue two willful and three serious violations totaling $122,602 to a sperm bank for bulls (cattle) after an employee was asphyxiated while filling freezers with Liquid Nitrogen.  And back in 2017, we saw another sperm bank, this one for humans, have a Nitrogen incident which claimed the life of a…...

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Requirements for when rooms or buildings exceed the maximum allowable quantity per control area for flammable liquids

5705.3.7 Rooms or buildings for quantities exceeding the maximum allowable quantity per control area.Where required by Section 5705.3.5.3 or 5705.3.6.1, rooms or buildings used for the use, dispensing, or mixing of flammable and combustible liquids in quantities exceeding the maximum allowable quantity per control area shall be in accordance with Sections 5705.3.7.1 through 5705.3.7.6.3…. Membership...

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Alarming Trends Found on Fixed Gas Detection Systems (USCG Safety Alert)

The United States Coast Guard issued a Marine Safety Alert after they discovered three (3) separate Liquefied Natural Gas (LNG) carriers with issues with their fixed flammable gas detection systems that resulted in the issuance of deficiencies and delay of cargo operations. While witnessing tests, multiple sensors measured outside the tolerances established by the manufacturer…...

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Separation Distances in NFPA Codes and Standards (Final Report)

Have you ever wondered where all the “separation distances” we see in OSHA Standards, NFPA Codes, Fire Codes, etc. come from?  Who came up with them, what are they based on, etc.?  All legitimate questions and you are NOT alone!!   Many of these requirements have historical undocumented origins. Guidance, which may inform a sound technical…...

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When ventilation is your engineering control, it should meet IMC Section 500

When we have a hazardous material that poses either a physical hazard such as a flash fire/explosion or a health hazard we need to manage this hazard using our hierarchy of controls.  The first control is to see if we can use a “safer alternative” which we call “Elimination/Substitution”.  But if this is not possible…...

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CO2 Cylinder Rupture

A gas cylinder was found in the parking lot of an event facility by staff arriving at work. The cylinder had launched from the concessions area the night before…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Compressed Gas Cylinders, OSHA and your AHJ with the IFC

Have you taken the 3 minutes to read OSHA’s expansive Compressed Gas Standard 1910.101?  After all, the standard is three sections long and references Compressed Gas Association (CGA) pamphlets that are no longer in print.  One of the most requested standards I get from SAFTENG members and clients is for CGA P-1 (1965): Safe Handling…...

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A look at back at fire safety

It seems every generation is destined to have its own structure fire tragedy; ours being the Station Nightclub fire in West Warwick, Rhode Island in 2003.  In less than 30 minutes, 100 people lost their lives that night (February 20, 2003).  I had just started consulting and I can remember it well as almost all…...

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UN’s proposal for modification of the classification criteria and hazard communication for flammable gases

The Joint TDG-GHS informal working group (IWG) dealing with the categorization of flammable gases was organized in Brussels from 9 to 11 March 2015 by the Belgian and the Japanese delegations to the TDG and GHS sub-committees.  The participants (physically/by phone) list can be found in Annex 1of this report.  The purpose of this IWG…...

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Does ASME B31.1 require pressure/leak testing on PSV vent piping to atmopshere?

The requirement for pressure and leak testing on PSV vent piping depends entirely on whether the piping is classified as Boiler External Piping (BEP) or Non-Boiler External Piping (NBEP). If the vent line is part of the BEP (directly attached to the boiler safety valves under the jurisdiction of ASME Section I), the testing requirements…...

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When bollards look good, but fail miserably

Bollards – a safety engineer’s best friend and a facility engineer’s worst nightmare.  I am not quite sure how we lost our way in such a simple design for such a significant safeguard.  But the International Fire Code (IFC) since the early 1990’s when I began using it has remained consistent in the design of…...

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