This week, OSHA posted an LOI regarding terms used in the PSM Standard, and this LOI has generated some discussions amongst some SAFTENG members, most notably…
How are we required to document our HAZLOCs?
In OSHA’s LOI, it referenced 1910.307 Hazardous Locations standard which simply states: (emphasis by me)
|
1910.307(b) Documentation All areas designated as hazardous (classified) locations under the Class and Zone system and areas designated under the Class and Division system established after August 13, 2007 shall be properly documented. This documentation shall be available to those authorized to design, install, inspect, maintain, or operate electric equipment at the location. |
My HAZLOC RAGAGEPs have always been NFPA 497 and NFPA 70. However, we should view 497 as more of a workbook (and the best one available) for DEFINING and QUANTIFYING our HAZLOCs. It does not specify the means by which these HAZLOCs have to be documented. But I have ALWAYS included the Figures from Chapter 5 in my PSI/Documentation, as these Figures/Diagrams do an excellent job depicting the VERTICAL and HORIZONTAL distances for my HAZLOC. CLICK HERE to view NFPA 497 and its figures/Diagrams. SAFTENG Members can see one of these figures below; it is from my training courses on Process Safety and Flammable Liquids/Gas Safety…
So the question remains… what does “properly documented” look like in real terms?
There is a simple test that I apply in my hazard assessments and audits regarding how HAZLOCs are DEFINED, QUANTIFIED, and DOCUMENTED. After validating that the Class, Division, and Group (e.g., DEFINING) are correct, I look to see if these areas are properly QUANTIFIED in BOTH VERTICAL and HORIZONTAL distances. Once this work has been validated as correct per NFPA 497/499 (the RAGAGEPs I use vs .307), I grab a process/unit/department engineer and see if they will approve me installing a light fixture within a HAZLOC using ONLY the facilities documentation on that HAZLOC. They can NOT refer to any other document. How they answer the critical question will tell us if the HAZLOC is “properly documented.”
When a facility has only a written description that does NOT DEFINE and QUANTIFY its HAZLOCs, this basic question almost always leads to an internal debate, showing that even the workers/engineers responsible for managing HAZLOCs within their unit/department/plant can’t agree on the answer without a stiff debate. There should be NO debate once the “documentation” is in place and has been VALIDATED as being accurate (regardless of whether this is a PSM area).
And think about it this way, my test is based on a fixed object being installed within the process/unit/department; which should be much easier to control. If we fail to pass this simple test with a fixed object, how are we suppose to have any confidence that portable/mobile devices are being properly managed within the process/unit/department?