presentation at asse 2016

1. OSHA 1910.106, NFPA 30 and
Recent Fire Incidents
John Newquist
johnanewquist@gmail.com
815-354-6853

2. Objective
• Identify key requirements in the 2015 NFPA 30
• Describe seven flammable liquid hazards
• Discuss solutions and prevention to flammable
or combustible storage of liquids.

3. NFPA Standards Form Basis for Safety
• Started in 1912
• Hazard control
• Prevent or limit leakage
• Prevent ignition of hazardous
atmosphere
• Limit consequences of the fire to
acceptable levels (mitigation
control)

4. Hazard Analysis
• Analysis of fire and explosion hazards of the
operation
• Analysis of emergency relief from process
vessels
• Analysis of facility design requirements
• Analysis of liquid handling, transfer and use
• Analysis of local conditions such exposure from
adjacent properties, weather, earthquakes
• Analysis of emergency response issues
Section 6.4

5. 51
59
63
64
130
119(d)(3)(ii)
107(b)(5)(i)
106(e)(6)(ii)
107(g)(2)
101(b)
Hazardous Materials
[1910.101 – .126]
5
COMPRESSED GASES – HANDLING STORAGE AND USE
SPRAY BOOTH – AIR VELOCITY
CLASS I LIQUIDS – DISPENSING
SUBPARTH
SPRAY AREAS – CLEANING WITH NON-SPARKING TOOLS
DOCUMENTATION OF EQUIPMENT WITH GOOD ENGINEERING PRACTICES

6. 1910.101(b)
• "Compressed gases." The in-
plant handling, storage, and
utilization of all compressed
gases in cylinders, portable
tanks, rail tank cars, or motor
vehicle cargo tanks shall be
in accordance with
Compressed Gas Association
Pamphlet P-1-1965, which is
incorporated by reference as
specified in Sec. 1910.6.

11. 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.
What could be the weaknesses
in citing this?

12. 1910.106(e)(2)(iv)(d)
• Flammable liquids shall be drawn
from or transferred into vessels,
containers, or portable tanks within
a building only through a closed
piping system, from safety cans, by
means of a device drawing through
the top, or from a container or
portable tanks by gravity through
an approved self-closing valve.
• Transferring by means of air
pressure on the container or
portable tanks shall be prohibited.

13. September 2014

14. Ether accident
• Drop filling
• Worker sees sparks in
funnel
• Next thing he knows
he is on fire with
invisible flames

15. Self-Closing Safety Faucet
• Bonding wire
between drum and
container
• Grounding wire
between drum and
ground
• Safety vent in drum

16. Safety Pump
• Faster and safer than using a
faucet
• Spills less likely
• No separate safety vents in
drum required
• Installed directly in drum
bung opening
• Some pump hoses have
integral bonding wires

17. 1910.107(b)(5)(i)
• The spraying operations
except electrostatic spraying
operations shall be so
designed, installed and
maintained that the average
air velocity over the open
face of the booth (or booth
cross section during spraying
operations) shall be not less
than 100 linear feet per
minute.

18. 1910.119(d)(3)(ii)
• The employer shall
document that
equipment complies
with recognized and
generally accepted
good engineering
practices.

19. 1910.119(d)(3)(ii)
• OSHA considered, but
rejected, publishing a list of
RAGAGEP providers
• The employer (not OSHA!)
selects the applicable and
protective RAGAGEP it will
use / comply with!

20. Ammonia - IIAR (International
Institute of Ammonia
Refrigeration)
Bulletin 107 - Guidelines for: Suggested
Safety and Operating Procedures when
Making Refrigeration Plant Tie-Ins
Bulletin 108 - Guidelines for: Water
Contamination in Ammonia
Refrigeration System
Bulletin 109 - Guidelines for: IIAR
Minimum Safety Criteria for a Safe
Ammonia Refrigeration System
Bulletin 110 - Guidelines for: Start-Up,
Inspection and Maintenance of
Ammonia Mechanical Refrigerating
Systems
Potential Sources of RAGAGEP

21. Ammonia - IIAR
Bulletin 111 - Guidelines for:
Ammonia Machinery Room
Ventilation
Bulletin 112 - Guidelines for:
Ammonia Machinery Room
Design
Bulletin 114 - Guidelines for:
Identification of Ammonia
Refrigeration Piping and
System Components
Bulletin 116 - Guidelines for:
Avoiding Component Failure
in Industrial Refrigeration
Systems Caused by Abnormal
Pressure or Shock
Potential Sources of RAGAGEP

22. The Chlorine Institute
Numerous Standards for:
Chlorine
Sodium hypochlorite
Hydrogen Chloride
Hydrochloric Acid
Many pamphlets
available for free
download
– www.chlorineinstitute.org
Potential Sources of RAGAGEP

24. API – American Petroleum Institute
ASME – American Society of
Mechanical Engineers
NBIC – National Board Inspection
Code, The National Board of Boiler
and Pressure Vessel Inspectors
CCPS – American Institute of
Chemical Engineers, Center for
Chemical Process Safety
NFPA – National Fire Protection
Association
Potential Sources of RAGAGEP
Boiler leak

25. ANSI – American National
Standards Institute
NIOSH – National Institute for
Occupational Safety and Health
ASNT – American Society for
Non-Destructive Testing
ISA – International Society of
Automation
ISA-TR84.00.04 – Safety
Instrumented Systems
EPRI – Electric Power and
Research Institute
Potential Sources of RAGAGEP

26. Safety Management Systems
NFPA standards are increasingly incorporating
requirements for safety management system elements,
for example:
• Hazard Analysis
• Operating Procedures
• Training
• Emergency plans and procedures
• Management of Change

27. Control of Ignition
Sources
• 6.5.1 General. Precautions shall be taken to
prevent the ignition of flammable vapors by
sources such as the following:
• (1) Open flames
• (2) Lightning
• (3) Hot surfaces
• (4) Radiant heat
• (5) Smoking
• (6) Cutting and welding
• (7) Spontaneous ignition
• (8)*Frictional heat or sparks
• (9) Static electricity
• (10) Electrical sparks
• (11) Stray currents
• (12) Ovens, furnaces, and heating equipment

28. Issues?

29. Emergency Planning
• Written Emergency
Action Plan
Procedures for
• Notifying the fire
department in case of
fire, release of liquids or
vapors.
• Evacuation
• Control and
extinguishing fire
Headcount? Safe Location?

30. Fire Protection
John Newquist
Draft 7 2 2016

31. May 2014
Location?

32. Jan 2016
• Issue?

33. Equipment Maintenance
Procedures for maintenance and
operation of:
• Fire protection equipment and
systems
• Drainage and containment systems
• Dispersion and ventilation
equipment systems

34. Emergency Planning
Procedures for:
• Shutting down and
isolating equipment to
reduce, mitigate, or stop
the release of liquids or
vapors
• Assigning plant
personnel responsible for
maintaining critical plant
functions or shut down of
plant processes and safe
start up following
isolation or shut down.

35. Inspection and Maintenance
• Maintenance and
operating practices shall
be established and
implemented to control
leakage and prevent
spillage of flammable
and combustible liquids

36. Management of Security
• Risk base approach with
the following objectives:
• Identification and
evaluations of security
risks
• Evaluations of security
performance
• Security Vulnerability
Analysis
• Emergency Action Plan
• Evaluation of protection
of employees,
• the facility itself,
• the surrounding
community, and
• the environment
• Security Management
Review after an incident

37. 2009 Empress Casino Fire
• $340 million in damage
• Lawsuit blames the fire
on general contractor and
five other companies
• The suit claims a welder
inadvertently sparked the
blaze in the kitchen area,
which ignited greasy
cooking residue and
spread flames throughout
the attic and truss space.

38. NFPA 30 Contents
• Chapter 16 Fire
Protection
• Chapter 17 Processing
Facilities
• Chapter 18 Dispensing
• Chapter 19 Specific
Operations
• Chapter 21-25 Tank
Storage
• Chapter 27 Piping
• Chapter 28-29 Bulk and
wharves
• Chapter 1-4
Administrative and
Definitions
• No chapter 5, 8, 20, 26
• Chapter 6 Fire Explosion
and Risk Control
• Chapter 7 Electrical
• Chapter 9 General
Storage of Liquids in
Containers
• Chapter 10-15 Specific
Storage Requirement

39. March 2015
• Used Brake cleaner at auto shop w pit.
• Putting it in a spray bottle and it flashed from the 55 gallon
drum.

40. Combustible Liquid Accident 2012
• Willowbrook, IL
• Worker were
installing carpet
• Liquid caught on fire

41. Combustible Liquids
• Storage, processing,
handling, and use of
combustible liquids
above its flash point can
produce ignitable vapors.
• 11/22/2006
• Vapor cloud at ink mfr.
• Tank left overnight with
steam heat.

42. Definitions
• Class I are areas where
flammable gases may be
present in sufficient
quantities to produce
explosive or flammable
mixtures.
• Class II locations can be
described as hazardous
because of the presence of
combustible dust.
• Class III locations contain
easily ignitable fibers
A flammable painting room would be
Class I

43. Definitions
• Flammable liquid means
any liquid having a
flashpoint at or below
199.4 °F (93 °C).
Flammable liquids are
divided into four
categories as follows:
• Category 1 shall include
liquids having
flashpoints below 73.4 °F
(23 °C) and having a
boiling point at or below
95 °F (35 °C).
NFPA 30 3.3.33.2* Flammable
Liquid. Any liquid that has a
closed cup flash point below
100°F (37.8°C)
Class IA Liquid — Any liquid
that has a flash point below 73°F
(22.8°C) and a boiling point
below 100°F (37.8°C)

44. Definitions
• Category 2 shall include
liquids having
flashpoints below 73.4 °F
(23 °C) and having a
boiling point above 95 °F
(35 °C).
Many flammable paints
and inks are Class 1B
Class IB Liquid — Any
liquid that has a flash point
below 73°F (22.8°C) and a
boiling point at or above
100°F (37.8°C)

45. Definitions
• Category 3 shall include
liquids having
flashpoints at or above
73.4 °F (23 °C) and at or
below 140 °F (60 °C).
When a Category 3
liquid with a flashpoint at
or above 100 °F (37.8
°C) is heated for use to
within 30 °F (16.7 °C) of
its flashpoint, it shall be
handled in accordance
with the requirements for
a Category 3 liquid with
a flashpoint below 100
°F (37.8 °C)
Class IC Liquid — Any liquid that
has a flash point at or above 73°F
(22.8°C), but below 100°F (37.8°C)

46. Definitions• Category 4 shall include
liquids having
flashpoints above 140 °F
(60 °C) and at or below
199.4 °F (93 °C). When a
Category 4 flammable
liquid is heated for use to
within 30 °F (16.7 °C) of
its flashpoint, it shall be
handled in accordance
with the requirements for
a Category 3 liquid with
a flashpoint at or above
100 °F (37.8 °C).
Class II Liquid — Any liquid
that has a flash point at or
above 100°F (37.8°C) and
below 140°F (60°C) (2) Class
III Liquid — Any liquid that
has a flash point at or above
140°F (60°C)
(a) Class IIIA Liquid — Any
liquid that has a flash point
at or above 140°F (60°C),
but below 200°F (93°C)
(b) (b) Class IIIB Liquid —
Any liquid that has a flash
point at or above 200°F
(93°C)

47. Flammable Liquid Storage
Flammable storage cabinet
capacities:
• 1910.106(e)(2)(ii)(b)
• The quantity of liquid
that may be located
outside of an inside
storage room or storage
cabinet in a building or
in any one fire area of a
building shall not exceed:
• 25 gallons of Category 1
flammable liquids in
containers

48. Let’s count
• Cabinet or no
cabinet?

49. Inside Storage Room Requirements
• Fire resistant
construction
• Sprinklers
• Raised sills or
trench
• Fire doors
• Liquid tight
(floor to wall)
• Windows
• Capacity ratings
• Electrical
• Ventilation
• Storage
requirements
• Egress
• Leak procedures
• 29 CFR
1910.106(d)(4)

50. Industrial Fire Resistive Construction
• Walls per NFPA 251
• 29 CFR 1910.106(e)(3)(iii),
Flammable and Combustible
Liquids; Industrial Plants;
Unit Physical Operations;
Chemical Processes;
establishes that a firewall
may have a 2-hour fire
resistance rating.
• NFPA Chapter 9 & 11
applies.
NFPA 30 is quite different and
may require 4 hour walls in some
cases.

51. Openings – Flammable Storage
• Non-combustible, liquid-
tight sills or ramps – 4”
• Open-grated trench in
alternative
• Storage area floor 4”
below surrounding floor,
in alternative
• NFPA 30 Chapter 9.3
offers more alternatives
and more requirements
NFPA 30 requires the discharge
not to go in public sewers,
waterways, or adjoining
properties.

52. Flammable Storage Rooms
• Self closing fire door, per
NFPA 80-1968
• Floor to wall
construction shall be
liquid-tight
• NPFA 30 Chapter 9.9
requires doors to closed
in the event if a fire.

53. Flammable Storage
• Where other portions of
the building, or other
properties are involved,
protected windows are
required per NFPA 80-
1968
• NFPA 30 Chapter 9.9.2
requires openings to
match fire resistance of
wall.
Flammable Storage rooms should
never have normal windows.

54. Storage Room Capacity
• Reference Table H-13 in
1910.106(d)(4)
• Capacity is dependent
on:
- room size
- fire resistant rating
- if fire protection is
available
(gals/cubic feet/floor area)
Electrical lighting of this type and
windows not allowedNFPA 30 Chapter 9.6 specifies
max quantities for control area.

55. Electrical
• Electrical installations
(lighting, receptacles,
etc) for Class I liquids
must meet Class I,
Division 2 Hazardous
location requirements in
Subpart S
• NFPA 30 Chapter 9.11
has Electrical System
Requirements

56. Ventilation
• Gravity or mechanical
• Six air changes/hour
• Locate switch outside of
room – wired with
lighting
• NFPA 30, Chapter 18.6
has much more extensive
ventilation requirements.
• Safe Location for vented
air.
• 1 cfm/sqft but not less
than 150 cfm.

57. Inside Storage Rooms
• Minimum 3’ wide aisles
• No stacking of containers
over 30 gal
• Approved pump or self-
closing faucet for
dispensing
• NFPA 30 Chapter 9.3
requires means of egress
to meet NFPA 101. NFPA 30 Chapter 18.4 covers
dispensing, handling, transfer
and use.

58. Dec 2015
• Issues?
• Diesel.

59. Basic Requirements
59
SUBPARTE
• Exit routes must meet the
following design and
construction requirements:
– Must be a permanent
part of the workplace.
– Separated by fire
resistant materials.
– Have limited openings.

60. Exit Marking
• Exits marked with a
readily visible sign
• "Not an Exit" on
confusing doors
• Signs with exit directions
in rooms where exit not
apparent
• Signs lit by 5 foot-
candles

61. Exit Marking
• 1910.37(b)(4) If the
direction of travel to the
exit or exit discharge is
not immediately
apparent, signs must be
posted along the exit
access indicating the
direction of travel to the
nearest exit and exit
discharge. Additionally,
the line-of-sight to an
exit sign must clearly be
visible at all times.

62. Issue?

63. Egress
• Cannot block or limit
safe egress (access to
exits)
• 1910.37(a)(3) Exits were
not free and
unobstructed.
• NFPA 30 Chapter 9.3
requires means of egress
to meet NFPA 101.

64. Exit Door Access
• Must be unlocked.
• Must be able to open from
inside at all times without
keys, tools, or special
knowledge.
– Panic bar that locks only
from the outside is
permitted.
• Must be free of any device
or alarm that could restrict
use if device or alarm fails.

65. Door Hinges
• Must be side-hinged.
– Door must be used to
connect any room to
an exit route.
• Must swing in direction
of travel if room is
occupied by more than
50 people, or room is a
high hazard area
(contains contents likely
to burn with extreme
rapidity or explode).

66. Exit Routes
66
SUBPARTE
• The number of exit routes must
be adequate - at least two.
• Must be far enough apart so
that if one is blocked by fire or
smoke, the other is available for
evacuation.
• More than two may be required,
depending on the size of the
building and its occupancy.
• Single exit permitted where the
number of employees, building
size, and occupancy is such that
all employees can evacuate.

67. Exit Route Capacity
• Must be adequate.
• Must support the maximum
permitted occupant load for
each floor served.
• Capacity may not decrease
in direction of travel to exit
discharge.
• Note: Information
regarding “occupant load”
is located in NFPA 101-
2015, Life Safety Code.

68. Fire Prevention Plans
• Requires housekeeping
to prevent accumulation
of flammable and
combustible waste
material and residue
• Plan made available for
employees to view
• Requires training of
employees in the plan

69. Sprinklers
• Storage should be 18 inches
below head
• Sprinkler heads kept dust,
lint, and grease free
• Sprinkler heads and piping
in good condition
• Main drain flow test annually
• Inspector’s test valve opened
every two years (most do it
annually)

70. Flammable Drums
• Empty drum containing
old xylene vapors
exploded when torch cut.

71. Ether accident
• Drop filling
• Worker sees sparks in
funnel
• Next thing he knows
he is on fire with
invisible flames

72. PPE
• Hazard Assessment
required under
1910.132
• Fire Resistant
Clothing?

73. 2013• State fire investigators
think a sparking forklift
ignited a cloud of
propane in a storage
yard about 10 p.m. July
29, touching off a blast
felt a mile away.
• Five employees were
hospitalized for months
with severe burns.
• One of the workers
awoke from a coma a
month after the accident

74. Some specific NFPA 30
requirements.

75. Oxidizers
• 25 foot separation
from flammable and
combustible liquids

76. Detached Unprotected Buildings
• 1000 ft. separation
from most
occupancies. (Except
business, industrial,
mercantile, and
storage.)
• Want to avoid
assembly and health
care being too close.

77. Outdoor Storage
• Kept free of weeds,
debris and other
combustible material
within 10 feet

78. Processing Facilities
• Drainage to a safe
location to prevent
liquids accumulating
under vessel or load
bearing support

79. Flammable Liquid Use
• Flammable liquids
shall be kept in closed
tanks or containers
when not in use

80. Underground Storage Tanks
• Overfill prevention
equipment installed to
alert the transfer
operator that tank is
no more than 90%
full.

81. Bonded Grounded
• 6.5.4.2
• All metallic equipment
such as tanks, machinery,
and piping where the
potential exists for an
ignitible mixture to be
present shall be bonded
and grounded.

82. April 2016
• "He told our investigators, upon questioning, that he intentionally set the fire by
means of a small lighter and a piece of shipping paper. So he lit the paper and then
dropped it on some furniture," said Tom Ahern, a spokesman for the Bureau of
Alcohol, Tobacco and Firearms and Explosives. "He had just had a heated argument
with his superiors, who were going to dock him some vacation days because he had
failed to show up for work on a number of occasions."
Woodridge IL
65 employees
were in the
warehouse

83. Mar 2016

84. Hot Works
combustible
material and
hazardous gases
should be
detected in
buildings closer
than 35 feet (10.7
m) from the point
of welding.

85. "Hot work"
means work involving
electric or gas welding,
cutting, brazing, or
similar flame or
spark-producing
operations.
What is Hot Works?
Danger in the Oil Field

86. Aug 2016
• Nederland, Texas
• An incident that injured
seven workers –
including three critically
• Sunoco Logistics
Partners, a terminal
facility
• According to initial
inquiries the incident
involved a flash fire
during welding – also
referred to as hot work -
activities at the facility.

87. November 2015
• Lytton Iowa
• Thirty-four-year-old Earl
Moore of Milford Center,
Ohio was inside a large
storage tank and was going to
patch weld a seam in the tank
when the explosion
occurred.

88. NFPA Read only access
• www.nfpa.org
• Set up alerts

89. Questions?
• Facebook
• Linked-in
• Twitter

90. Background
• Classes: OSHA 10/30 Hour, Incident
Investigation, Confined Space,
Excavation Safety, Cranes Signaling and
Rigging, Fall Protection, Scaffold Safety,
and many more
• Services: Mock OSHA Inspections, Site
Safety Audits, OSHA Litigation
Consultation,
• Since 1990, he has trained OSHA
compliance officers in numerous areas
including OSHA policy, safety and
health regulations, safety and health
management systems, legal aspects of
investigations, and enforcement
strategies.
90
• 36 years working with
top companies to
achieve ZERO injuries

91. Disclaimer
• While the information contained in this Presentation is believed to be accurate, the Preparers have not conducted any investigation
with respect to such information. The Preparers expressly disclaim any and all liability for representations or warranties,
expressed or implied, contained in, or for omissions from, this Presentation or any other written or oral communication
transmitted to any interested party in connection with this Presentation so far as is permitted by law. In particular, but without
limitation, no representation or warranty is given as to the achievement or reasonableness of, and no reliance should be placed on,
any projections, estimates, forecasts, analyses or forward looking statements contained in this Presentation which involve by their
nature a number of risks, uncertainties or assumptions that could cause actual results or events to differ materially from those
expressed or implied in this Presentation. Only those particular representations and warranties which may be made in a definitive
written agreement, when and if one is executed, and subject to such limitations and restrictions as may be specified in such
agreement, shall have any legal effect. By its acceptance hereof, each recipient agrees that none of the Preparers nor any of their
respective Representatives shall be liable for any direct, indirect or consequential loss or damages suffered by any person as a
result of relying on any statement in or omission from this Presentation, along with other information furnished in connection
therewith, and any such liability is expressly disclaimed.