How many of you work at a facility that requires “spark proof” tools in hazardous locations? Is this done as a “Best Practice” within the company or is this thought to be an OSHA and/or NFPA requirement? Well, the answer may surprise you…
First I know I am probably a day late and many dollars short in writing this post as many businesses have spent a ton of money on spark-proof tools over the years. Unfortunately, some have bought them because they were told, and in some cases by OSHA CSHOs, that they were required to have these non-sparking tools. Now don’t get me wrong, I am a HUGE PROPONENT of non-sparking tools, but the fact of the matter is that NEITHER OSHA or NFPA require non-sparking tools.
Here is NFPA’s official position on the matter…
A.6.5.1(8) With respect to frictional heat or sparks, it is recognized that there is a need to control sources of ignition, including mechanical sparks from hand tools, that have sufficient energy to ignite flammable vapors. Studies, anecdotes, codes, and referenced standards (e.g., API 2214, Spark Ignition Properties of Hand Tools) show that there is a potential for hand tool sparks to ignite flammable vapors from a limited number of chemicals and under certain unique conditions. These include flammable liquids with low minimum ignition energies, operations in which flammable or combustible liquids are heated, and atypical spark generation that can occur between specific types of hand tools and struck surfaces (i.e., thermite reactions or impact of steel tools on quartzitic materials). Even spark-resistant tools might not provide suitable protection against ignition. For example, hard metal particles can become embedded in the relatively soft metal of spark-resistant tools, and these particles can cause sparks when the tools are used.
NFPA 30 requires analyses, such as job safety analyses or activity hazard analyses, of the hazards and risks of a given task and the application of appropriate protective measures to prevent or mitigate the hazards and risks. This includes identification and mitigation of ignition risk from multiple sources, including hand tools. Due to the complexity of the numerous operations involving flammable liquids, NFPA 30 cannot address all conditions in which spark-resistant tools should be made mandatory, might be advisable, or are unnecessary to help control the ignition risk of any given operation.
Before the 2012 edition, there was no mention of spark-resistant tools in NFPA 30, although the 2008 edition of this handbook included the following statement as part of the commentary to 6.5.1: “Note that there is no mention in 6.5.1 of non-sparking tools. Over the years, it has become more accepted that ordinary steel hand tools cannot generate ignition-capable sparks, except under unusual circumstances. (See API RP 2214, Spark Ignition Properties of Hand Tools.)”
Based on a number of proposals to NFPA 30 to require spark-resistant tools in practically all operations, the NFPA 30 Technical Committee on Fundamentals decided to include this Annex A item to explain to the user that, although the use of spark-resistant tools is not mandated by the Code, there might be situations in which their use is warranted.
OSHA’s position is not so clear, as there are some specific OSHA standards that DO REQUIRE the use of “non-sparking” tools; however, some would argue it is NOT a requirement under OSHA General Flammable Liquid Standard 1910.106.
1910.106(e)(6)(i) “General.” Adequate precautions shall be taken to prevent the ignition of flammable vapors. Sources of ignition include but are not limited to open flames; lightning; smoking; cutting and welding; hot surfaces; frictional heat; static, electrical, and mechanical sparks; spontaneous ignition, including heat-producing chemical reactions; and radiant heat.
But in contrast, for example, OSHA’s Spray finishing using flammable and combustible materials, 1910.107, DOES REQUIRE the use of “non-sparking” tools in 1910.107(g)(2).
1910.107(g)(2) Cleaning. All spraying areas shall be kept as free from the accumulation of deposits of combustible residues as practical, with cleaning conducted daily if necessary. Scrapers, spuds, or other such tools used for cleaning purposes shall be of nonsparking material.
Believe it or not, 1910.107 is the ONLY “official language” in OSHA’s General Industry standards that require “non-sparking” tools. OSHA does make mention of the term “non-sparking tools” over 1,000 times in many presentations and guidelines and they even made sure to include the requirement to consider these tools when doing PPE Hazard Assessment.
With all that said, OSHA has issued citations to employers using the General Duty Clause (GDC) after accidents involving flammable liquids/vapors/gases where non-sparking tools were NOT being used. A propane distribution business was cited in 2003 after a worker opened a drain plug on a 250-pound container and spilled liquid propane inside a building, which quickly found an ignition source and flashed. OSHA cited the business for not using “non-sparking tools”, as well as a whole host of other flammable atmosphere issues.
So bottom-line… even though OSHA and NFPA may not “require” these non-sparking tools in the vast majority of the activities we do in flammable atmospheres, I will ALWAYS strongly suggest they be used when working around those flammable substances that have very small Minimum Ignition Energies (MIE). After all, if we are going to be concerned about static electricity, how can we convince ourselves that the tools being used at the source of the leak need not be non-sparking tools?