Those who follow my posts closely know I am a massive fan of bollards for physically protecting hazardous materials processes. These simple and inexpensive posts have saved my butt over my career more times than I can count, and yet so many still are unaware of their need and requirements. But these bollards are for “ground-level protection” from powered mobile equipment.
Recently, I had a client inquire about protecting a hazardous material process that has piping running below the ceiling. The business was installing a “gantry crane” nearby, and there was some concern about the crane’s proximity to some piping carrying a highly hazardous chemical in a PSM/RMP-covered process.
In the IFC and State Fire Code, there is an exemption from some code requirements if the facility is utilizing OSHA’s PSM and/or EPA’s RMP requirements. It is called the Performance-Based Design Alternative (5001.3) and simply regurgitates the 14-elements of a Process Safety Management System (PSM/RMP). And inside this “exemption,” there lies this requirement:
5001.3.3.6 Protection of hazardous materials.
Safeguards shall be provided to minimize the risk of exposing hazardous materials to a fire or physical damage, whereby such exposure could endanger or lead to the endangerment of people or property.
This section directs the designer and operator to review and ensure that vessels or systems containing hazardous materials are not exposed to or are protected
from damage by external sources such as contact and fire. The design should focus first on reducing the possibility of fire or other hazards, such as vehicular impact, and second on isolating hazardous materials from exposure to unsafe conditions, such as a fire. All process areas and systems should be formally reviewed to find and correct any sources of exposure to fire, including the following:
Fire-resistance-rated barriers.
Nearby storage of combustibles.
Nearby hot work operation.
Nearby vehicular operation.
All systems subject to fire exposure should be formally reviewed to ensure adequate protection, including the following:
Sprinkler installation
Insulation of equipment