A review of our 2013/2014 audits showed that pipe labeling is a problem across all industries and all types of hazardous materials. Out of 39 audits, 19 had issues with pipe labeling, with the vast majority of those issues being “labeling not meeting a RAGAGEP or company standard.” During audits, it all boils down to having a code/standard/directive/procedure that we can show the facility is not complying with; however, most companies have a section in their HAZCOM program that covers the topic, although many fall short of their own internal requirements. This article provides some excellent resources for how pipe labeling can be achieved and some codes beyond OSHA that your facility may need to address.
Without a doubt, the most recognized and generally accepted good engineering practice (RAGAGEP) for pipe labeling is ASME A13.1. This document, literally a whopping two pages, makes pipe labeling simple and to the point. If your facility has a PSM/RMP covered process, this RAGAGEP is the most popular for ensuring your pipe labeling meets or exceeds OSHA/EPA requirements (i.e., RAGAGEP). But OSHA’s PSM and EPA’s RMP standards allow us to adopt any chosen RAGAGEP, so we may very well choose to adopt some other scheme for our pipe labeling, and this would be fine if we only had to meet OSHA and EPA requirements.
In comes the state fire and HAZMAT codes; if the state the facility is located has adopted the International Fire Code (IFC), we may not have a choice, as the IFC, for the last several decades, has required that piping conveying a “hazardous material” be labeled per ASME A13.1 (no year listed). And some of the codes actually spell out the methods of labeling required for that specific hazardous material rather than reference ASME A13.1.
Almost all of these labeling requirements are NOT based on quantities, as the codes use the phrase “Piping, tubing, valves, fittings, and related components” in their language, so the argument that it is only a 0.25″ pipe/tube is NOT valid when it comes to labeling HAZMAT pipe/tube/hose!!! Need I remind us that one of the recent fatalities that have garnered a lot of attention involved a phosgene “hose”. So some of these highly toxic materials can be fatal in small quantities!
Here are some examples of the IFC code labeling requirements:
Chapter 50 – Hazardous Materials-General Provisions
SECTION 5003 GENERAL REQUIREMENTS
5003.2.2 Piping, tubing, valves and fittings.
…
2. Piping and tubing shall be identified in accordance with ASME A13.1 to indicate the material conveyed.
Chapter 53 – Compressed Gasses
SECTION 5303 GENERAL REQUIREMENTS
…
5303.4.3 Piping systems.
Piping systems shall be marked in accordance with ASME A13.1. Markings used for piping systems shall consist of the content’s name and include a direction-of-flow arrow. Markings shall be provided at each valve; at the wall, floor or ceiling penetrations; at each change of direction; and at a minimum of every 20 feet (6096 mm) or fraction thereof throughout the piping run.
Exceptions:
1. Piping that is designed or intended to carry more than one gas at various times shall have appropriate signs or markings posted at the manifold, along the piping and at each point of use to provide clear identification and warning.
2. Piping within gas manufacturing plants, gas processing plants, refineries, and similar occupancies shall be marked in an approved manner.
Chapter 57 – Flammable and Combustible Liquids
SECTION 5703 GENERAL REQUIREMENTS
5703.5.2 Location.
Signs shall be posted in locations as required by the fire code official. Piping containing flammable liquids shall be identified in accordance with ASME A13.1.
So that shows us the need to label our hazardous materials piping (even that piping that is NOT part of a PSM/RMP covered process!) and I hope we can see the value in doing so other than making some compliance agency happy! Labeling our HAZMAT piping is the second step in controlling the hazards associated with conveying these hazardous materials (the first being design/installation). So let’s discuss the means to label our piping…
As I pointed out above, the IFC, as well as ASME A13.1, provide some very specific rules for how the piping is to be labeled:
Markings used for piping systems shall consist of the content’s name and include a direction-of-flow arrow. Markings shall be provided at each valve; at the wall, floor or ceiling penetrations; at each change of direction; and at a minimum of every 20 feet (6096 mm) or fraction thereof throughout the piping run.
Anyone who has ever had to walk down a piping run in a complex process knows how valuable good pipe labeling is. Throw in our Line Break Permitting process with contractors, and we can clearly see the value in proper pipe labeling. I have written about several line break accidents over the years, which were traced back to the workers opening the WRONG pipe!
Should we have a written program for pipe and vessel labeling?
Absolutely we should. I always used my written HAZCOM program for this. Still, some PSM/RMP facilities have found it useful to have a separate and detailed program specific to pipe and vessel labeling when vessels are in a “batch process.” Either way, we MUST ensure that ALL personnel on site (including contractors) are trained and knowledgeable in our labeling schemes. Some facilities are comfortable with merely having a copy of ASME A13.1 on file at the facility; this I think, may be setting us up for some failures. Having a written program that lays out responsibility for maintaining the pipe labeling is KEY to continued success in our Hazardous Communication efforts. In fact, ASME A13.1 states:
Existing schemes for identification shall be considered as meeting the requirements of this Standard if
(a) such schemes are described in writing
(b) employees are trained as to the operation and hazards of the piping systems
If I meet ASME A13.1 requirements, will l need several thousand of dollars to complete all my pipe labeling?
Yes, this is true. I have overseen several major projects at my facilities, and just the labeling of the piping for these projects was over $10,000 each. One major expansion cost was over $50,000. And yes, each step of the way, management was trying to cut costs, and “pipe labeling” was ALWAYS on the list to cut. And I always denied the cuts, as we would have had to “pencil whip” our PSSR since it had a line item that required the engineering manager to sign off on the “Pipe Labeling met ASME A13.1”. But we should not be surprised when workers/management fail to see the value in spending the $ and oftentimes the resources to apply (and maintain) these labels. Labeling the process once the HHC/EHS has been introduced just increases the costs since now we have HAZLOC(s) we have to work in, permits have to be issued for the work, aerial lifts are introduced into the process area, fall hazards increase, etc. So doing the labeling as part of your Pre-Startup makes things go more smoothly, as well as making operator and maintenance training much more effective.
How big do my labels have to be?
This always seems to be an issue for most facilities. Yes – the pipe is labeled, but the label is so small that it can not be read from the ground. It should be a reasonable expectation that a label in a pipe rack/bridge that is only 25’ high be legible from the ground level. But in comes ASME A13.1, Section 3.4 “Type and Size of Letters” specifies the type and size of lettering based on pipe diameter.
Contrast shall be provided between color field and legend for readability. Use of letters of standard style, in sizes 1⁄2 in. (13 mm) and larger, is recommended. See Table 3 for specific size recommendations. For identification of materials in pipes of less than 3⁄4 in. (19 mm) in diameter, and for valve and fitting identification, the use of a permanently legible tag is recommended.
NOTE: the code recommends “Sans Serif Gothic” BOLD style lettering for high readability; however, any PLAIN BOLD font such as Arial will work as well. Just stay away from cursive letters and the likes. Remember this is all about READABILITY and not a beautification effort; hence I have had debates with some managers about how the “labeling looks” on their new shiny process!
Does ASME 13.1 incorporate a color coding scheme?
Yes, they do; but the code does NOT permit color coding the pipe as the SOLE means to identify the contents. Section 3.2 states:
Color should be used to identify the characteristic hazards of the contents. Color should be displayed on, or contiguous to, the piping by any physical means, but its use shall be in combination with a legend. Color may be used in continuous, total length coverage or in intermittent displays. Colors preceded by the word “Safety” shall meet the requirements of ANSI Z535.1. See Table 2.
NOTE: ANSI Z535.1 is the combination of ANSI Z53 on Safety Colors with the ANSI Z35 on Safety Signs to form the ANSI Z535 on Safety Signs and Colors.
If your piping spec or RAGAGEP, such as ANSI B31 series, requires the piping to have a coating then we strongly recommend that the entire pipe is painted with the applicable color. But if the pipe spec does not require a “coating” then we suggest NOT to use a pipe color scheme and abide by the labeling color scheme. Our experience is that painting pipe gets done initially, but over the years the painting is not maintained or even more common of a problem we see is that the pipe gets painted some color that is not in the pipe color scheme established at the plant or the wrong color that conflicts with the color scheme. For instance, we have seen fire water systems painted red (the correct color for fire water) and right next to the fire water is a flammable liquid line that the facility wanted to be painted red for high visibility – NEITHER pipe had a label! Imagine the surprise when the sprinkler pipe fitter opens his fire water line to find it full of a flammable liquid!
Here is the color coding scheme:
Fire-quenching fluids = Safety red
Toxic and corrosive fluids = Safety orange
Flammable fluids = Safety yellow
Combustible fluids = Safety brown
Potable, cooling, boiler feed, and other water = Safety green
Compressed Air = Safety blue
To be defined by the user = Safety purple
To be defined by the user = Safety white
To be defined by the user = Safety gray
To be defined by the user = Safety black
We can, of course, change the scheme, but this would REQUIRE us to have our OWN written program rather than merely reference ASME A13.1. Also, take note that ASME A13.1 provides four (4) OPEN colors for a facility to use as they see fit. I am not a fan of these colors as they are NOT bright enough to call out the level of attention I feel a hazardous material deserves.
One thing that deserves special acknowledgment… somewhere, we got on a track that Nitrogen pipes are supposed to be “Safety Green.” I worked at facilities where this was the case, and even then, I could not get a straight answer from engineering. This is another one of those “things” that “it is what it is,” and no one can seem to provide a logical explanation. We have seen a ramp-up of nitrogen lines being colored “green” after the CSB Alert on the “Hazards of Nitrogen.” My only guess is that we have always viewed Nitrogen as a “process utility,” much like water systems. Thus we put Nitrogen in the same group of hazards as “Potable, cooling, boiler feed, and other water.” I am not a fan of this logic, but as long as the facility makes it clear in their scheme that Nitrogen belongs to this color group AND they are complying with the NAME requirement on the pipe labels, then there is no compliance issue; however; those who merely reference ASME A13.1 which does not place N2 into any color scheme there may be an issue if plant personnel (including contractors) are not aware of this scheme.
It MATTERS where on the pipe the label is applied.
Basically, we want the labels to be visible from the “working position.” A pipe in a pipe rack should be labeled so that the label is viewable from the ground, so this means we want the label BELOW the horizontal line on the pipe. For the pipe that is below “waist height,” we want the label ABOVE the horizontal line on the pipe. Section 3.3 Visibility states:
Attention shall be given to visibility with reference to pipe markings. Where pipelines are located above or below the normal line of vision, the lettering shall be placed below or above the horizontal centerline of the pipe.
The code provides a great figure showing how this labeling will be applied to make it visible to personnel.
Can I use the chemical name and flow direction to meet the RAGAGEP?
Simple answer – NO. Would OSHA/EPA issue a citation if your pipe had only the content and flow direction, most likely NOT, but an incident involving a pipe and labeling was an issue, AND your PSM/RMP program sites that you follow ASME A13.1 there is an opportunity for them too. This is because ASME A13.1 states the following:
This Standard considers a legend to be primary and explicit for the identification of contents. Positive identification of the contents of a piping system shall be by lettered legend, giving the name of the contents in full or abbreviated form (see Table 1). Arrows shall be used to indicate the direction of flow. Where flow can be in both directions, arrows in both directions shall be displayed. Contents shall be identified by a legend with sufficient additional details such as temperature, pressure, etc., as are necessary to identify the hazard.
So if the material is at a “pressure” or “temperature” that increases or merely poses a hazard itself due to the high pressure or temperature, this data MUST be included on the label. A perfect example is water! Process water at temps above 140F is a hazard, whereas water in a fountain or sink is not! Water at 300 psi is also a hazard! This is a very common omission on many pipe labels, yet I am not aware of OSHA or EPA ever pushing these limits. Like me, I am guessing, they are just hoping for content and flow, as well as having enough labels to clearly identify the contents of the pipe!
Lastly, I learned a pipe labeling tip from one of the finest engineers and plant managers to walk the earth…
When labeling straight runs of several pipes, the code says that we have to label every 20’ or so. But when we have a pipe run that contains multiple HAZMAT pipes running parallel, we should label all the pipes in the run at the same location(s). So even though we are measuring 20’ and applying labels, when we get to a run with multiple pipes next to each other, the labels should be applied at the same locations on each pipe, regardless of what the technical reading of the code states.