OSHA Compliance

Can I max out the MAQs for each of my hazardous material classes in a single control area and still not have to do an H occupancy?

Yes, we can absolutely max out the Maximum Allowable Quantities (MAQs) for multiple different hazard classes within a single control area and still avoid triggering a Group H (Hazardous) occupancy. However, there is also a major caveat regarding how those materials are categorized and whether they pose overlapping physical or health hazards. Here is how […]

Understanding the three (3) methods of protecting piping supports in flammable liquids service (IFC 5703.6.8 Piping supports)

5703.6.8 Piping supports have three (3) recognized methods to protect piping that may be exposed to a “pool fire”. First lets look at the code language: 5703.6.8 Piping supports. Piping systems shall be substantially supported and protected against physical damage and excessive stresses arising from settlement, vibration, expansion, contraction or exposure to fire. The supports

Properly applying NFPA 496 Pressurized Enclosures in a HAZLOC

NFPA 496 (Standard for Purged and Pressurized Enclosures for Electrical Equipment) is one of the most powerful engineering tools available for hazardous locations, but it is also one of the most abused standards for HAZLOCs. Like the Combustible Gas Detection System (CGDS) provisions in NFPA 70, NFPA 496 allows a facility to install ordinary, non-classified

Understanding the LIMITATIONS of NFPA 70, Article 500.7(k) Combustible Gas Detection System (CGDS)

In NFPA 70 (National Electrical Code / NEC), the use of a Combustible Gas Detection System (CGDS) is a highly specialized engineering provision. It essentially acts as a “get out of jail free” card—or more accurately, a reclassification tool—for specific industrial locations. When you install a qualified CGDS, the NEC allows you to lower the

The history of “weak seam welded roof” as a means of emergency venting atmospheric storage tanks

The concept of the weak seam welded roof—officially referred to in modern engineering standards as a frangible roof joint—has been a foundational safety mechanism for atmospheric storage tanks for over 90 years. NOTE: In 2015, NFPA 30 Section 22.7 was amended to eliminate the use of a weak roof-to-shell seam as an allowed means of

Failing to CLOSE a PRCS Entry Permit properly can have Process Safety implications months after the entry

As most of you know, PRCS Entry is one of the specific SWPs called out in the PSM and RMP standards. But many programs fail to meet 1910.146(f)(4), and a recent CSB accident report tied the requirement for canceling a permit to a catastrophic explosion event. 1910.119(f)(4) The employer shall develop and implement safe work

The 15-Year Service Life Debate for Composite Cylinders (SP 16320)

The most significant friction point involves PHMSA and SCBA Fully Wrapped Carbon-Fiber Reinforced (CFFC) aluminum-lined cylinders on Special Permit 16320 and the use of Modal Acoustic Emission (MAE) testing to extend the life of composite cylinders. Fully Wrapped Carbon-Fiber Reinforced (CFFC) aluminum-lined cylinders have a 15-year service life. PHMSA has investigated and granted limited special

FRC must be the outer layer – NYLON Hi-Vis vest are a problem

In today’s workplaces, it’s hard to find a large business that does not require Hi-Vis Vest/Workwear. What is not hard to find is a business with HAZLOCs where workers are required to wear FRC but are wearing nylon Hi-Vis vests OVER their FRC. I am all for making workers more visible to powered industrial trucks

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