PLEASE ensure your “life safety” contractor inspector for Exits, Fire Extinguishers, EW/SSs, etc., is FULLY trained on the hazards of the area(s) they will be working in. This year, we have found two (2) national companies that provide these inspection services using electronic devices NOT rated for the hazardous areas where they are working.
We got every excuse anyone could come up with as to why they are allowed to use non-rated devices in Class 1, Div 1 and 2, Group D Hazardous Locations (HAZLOCs). None were worth our time to even discuss.
This failure falls on the host facility. They hired and paid the inspection company to convert their paper inspection system into an electronic system, “saving both time and money”. Yet violating the basic requirements for working in a HAZLOC.
I would say that, in terms of square footage, 50% of this facility is either a Class 1 or 2 HAZLOC, so the Corrective Action Plan (CAP) for this finding will be costly.
LESSON LEARNED: USE YOUR MOC TOOL to help navigate these changes. What sounds like a “great idea” can create some serious risks, both real and compliance-related.
I learned this error the hard way during one of my VPP assessments back in the 1990’s. We were so proud of using the latest and greatest tech (Palm Pilots) in our Life Safety inspection process and some MI work orders. We presented this in our presentation to the OSHA team upon their arrival for our VPP assessment, and they were impressed and even declared it may be a “best practice”. Until the ChemE on the team was doing his walk-through of our flammable liquids process, and was focused on the equipment used in it. As we stood there chatting with an operator and inspecting her flashlight and radio for proper certifications, another operator walked by with the palm device and began inspecting a fire extinguisher. This caught the CSHO’s attention, and the CSHO quickly ended the interview and followed the operator to the next extinguisher. I was OBLIVIOUS to what was about to happen. He asked to see the device and began looking at all sides of the device, and then I’ll never forget the look he gave me while asking how to shut down the device. I knew then how bad I had F’ed up. We got STAR, but one of the 90-day recommendations was to improve our MOC awareness. Nothing wrong with the MOC process; we were just missing a lot of changes. Our MOC Hazard Assessment specifically asked about HAZLOC impacts; we just did not do one on “improving our life safety inspections”.