Last week I wrote about how either distance or a barrier is necessary to CONTROL hazards. OSHA’s made a great case in 2020, explaining how the separation distances in 1910.110 is a PASSIVE MITIGATION measure. (emphasis by me)
| OSHA concludes that NFPA 58 (2017), Sections 6.28.2 and 6.28.3, do not provide an equivalent level of safety as provided by the greater separation distance (a PASSIVE MITIGATION MEASURE) required in 29 CFR § 1910.110(b)(6)(ii) and Table H-23. |
The Q&A was concerning shortening the distance between an LPG storage tank and “important buildings”. NFPA 58, sections 6.28.2 and 6.28.3, allows the LPG tank to be closer because the code requires LPG containers for stationary engines to have a fill valve with an integral manual shutoff valve. Because of this PREVENTION SAFEGUARD for filling the tank, the code allows for the separation distance to be cut in half. However, OSHA points out that other release scenarios would still need the minimum separation distances. So the integral manual shutoff valve is a SAFEGUARD for filling operations, but not the other release scenarios – so DISTANCE is still needed.
Source: https://www.osha.gov/laws-regs/standardinterpretations/2020-07-20