For those of you that follow my ramblings have heard me rant on about ASME A13.1 and how pipe labeling begins LONG BEFORE a process becomes a PSM/RMP covered process. ALL Hazardous Materials piping has to be labeled! And yes I am well aware of OSHA’s position on pipe labeling and their Globally Harmonized System for Hazardous Communications…
Container means any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical. For purposes of this section, pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are NOT considered to be containers.
But the standard also says…
1910.1200(e) Written hazard communication program.
1910.1200(e)(1) Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, safety data sheets, and employee information and training will be met, and which also includes the following:
1910.1200(e)(1)(i) A list of the hazardous chemicals known to be present using a product identifier that is referenced on the appropriate safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas); and,
1910.1200(e)(1)(ii) The methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas.
So we can debate all day as to whether OSHA requires pipe labeling, I think it is a silly debate to have, but if we go back one step in compliance requirements and look at the State Fire Codes, almost all of them are using some version of the International Fire Code (IFC). This code has, for many many years, required ALL hazardous materials piping to be labeled per ASME B13.1.
5003.2.2.1 Design and construction.
Piping, tubing, valves, fittings and related components used for HAZARDOUS MATERIALS shall be in accordance with the following:
1. Piping, tubing, valves, fittings and related components shall be designed and fabricated from materials that are compatible with the material to be contained and shall be of adequate strength and durability to withstand the pressure, structural and seismic stress and exposure to which they are subject.
2. Piping and tubing shall be identified in accordance with ASME A13.1 to indicate the material conveyed.
As for the above-ground storage tanks, the IFC requires (as does OSHA):
5003.2.4.2.1 Marking.
Above-ground stationary tanks shall be marked as required by Section 5003.5
....
5003.5 Hazard identification signs.
Unless otherwise exempted by the fire code official, visible hazard identification signs as specified in NFPA 704 for the specific material contained shall be placed on stationary containers and aboveground tanks and at entrances to locations where hazardous materials are stored, dispensed, used or handled in quantities requiring a permit and at specific entrances and locations designated by the fire code official.
On July 30, 2019, EPA conducted an inspection of a Terminals facility located in PA to determine compliance with the Risk Management Plan (RMP) regulations promulgated at 40 C.F.R. Part 68 under Section 112(r) of the Clean Air Act (the Act or CAA). EPA found that the Respondent had violated regulations implementing Section 112(r) of the Act, specifically for:
- failing to label process piping and tanks in accordance with ASME A13.1 for piping and the International Fire Code and NFPA 704 for storage tanks
- failed to certify its compliance audits every three years
This week, the EPA posted the Expedited Settlement Agreement (ESA) for this inspection, and although the fine was only $2,700, the cost of fixing the pipe and tank labeling issues was $89,952.
CLICK HERE for the ESA