Some clients have their processes/storage in the middle of a neighborhood, and I mean in the middle of a neighborhood, as we see on TV and postcards. Beautiful tree-lined streets with kids riding their bikes and moms pushing their baby strollers. Of course, the facility came first, in the 1950’s, and then the encroachment. As a safety engineer, it is not my job to judge who is right or wrong; I’m hired to identify risks and offer solutions. And ss many of you know, I am a big proponent of using the International Fire Code (IFC) when OSHA has failed to address specific hazards. I simply hate using the “General Duty Clause” (5a1) when I can find a reference/solution in the IFC/IMC/IBC.
Most of my clients are chemical facilities that handle, store, and process Toxic and Flammable Liquids and Gases. Unfortunately, OSHA is way behind in making its standards on these hazards relevant to today’s businesses, so I am always working in the IFC, Chapters 50-61. Note: I do not do work in reactives, which are covered in Chapters 62-67. Recently, we came across a “facility siting” issue related to 20% Aqua Ammonia Storage. This material will actually fall under BOTH a “toxic liquid” (Chapter 60) and a “corrosive liquid” (Chapter 54), and just to be clear, all hazardous materials start with meeting the requirements found in Chapter 50 – HAZARDOUS MATERIALS—GENERAL PROVISIONS.
In chapter 60, section 2.3.1 Location, the facility is RESTRICTED just where “outside” they can store their “toxic liquid”…