As I say each year, the International Fire Code (IFC) is being used in 42 states, D.C., Guam, and Puerto Rico. This code, dating all the way back to 1993 when I began my career in chemical processing, has always required much of what we apply in OSHA PSM/EPA RMP to processes that operate FAR UNDER the PSM/RMP TQs. For example, any hazardous material that poses a physical or toxic hazard falls under Part V – Hazardous Materials. Then the code piggybacks more specific requirements for process design with Chapters 51 – 67. These codes FAR OUTPERFORM anything OSHA has on the books and actually are required in those 42 states, DC, and Territories. For a specific example of what I am trying to convey, let’s talk about piping the HAZMAT is in.
5003.2.2.2 Additional regulations for supply piping for health-hazard materials. Supply piping and tubing for gases and liquids having a health-hazard ranking of 3 or 4 in accordance with NFPA 704 shall be in accordance with ASME B31.3 and the following: 1. Piping and tubing utilized for the transmission of highly toxic, toxic or highly volatile corrosive liquids and gases shall have welded, threaded or flanged connections throughout except for connections located within a ventilated enclosure if the material is a gas, or an approved method of drainage or containment is provided for connections if the material is a liquid. 2. Piping and tubing shall not be located within corridors , within any portion of a means of egress required to be enclosed in fire-resistance-rated construction or in concealed spaces in areas not classified as Group H occupancies. Exception: Piping and tubing within the space defined by the walls of corridors and the floor or roof above or in concealed spaces above other occupancies where installed in accordance with Section 415.11.7.4 of the International Building Code for Group H-5 occupancies.
This would include some very common chemicals used in many types of workplaces, such as Caustic and Sulfuric Acid. I spent many years upgrading these systems in my plants to meet ASME B31.3, and now I spend about 20% of my time working with clients to upgrade their systems to meet this baseline requirement. A lot of companies have HHCs/EHSs BELOW the PSM/RMP thresholds, and many believed they have no responsibility for the integrity of that process since they got below the TQ, until that day when it fails.