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The Journal for Employee Protection
The Journal for Employee Protection
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The first question posed to the author by a peer who reviewed an early draft of this article was, “What exactly is common sense?” So let’s begin by explaining that.This article provides a summary of common knowledge about flameretardant clothing (FRC).
You have heard “everybody knows…” Well, everybody may not know, which is why this article summarizes basic knowledge readily available in the U.S. Occupational Safety and Health Administration (OSHA), National Fire Protection Association (NFPA) and American Petroleum Institute (API) standards. You’ll also find regulations that apply to the entire oil and gas industry (Class I, Division I areas), power generation and chemical manufacturing. Plus, two regulations are specifically written to address FRC design, testing and use.
Knowledge of FRC issues common among safety, health and environmental (SH&E) professionals in the oil and gas industry can be summarised in a few sentences. To start, FRC is personal protective equipment (PPE), which is the last line of defense after engineering controls and administrative controls. FRC are designed to protect against a flash fire that only lasts three to five seconds.
It is not protective beyond that point except for the fact that it is selfextinguishing. Flash fires occur when a person is inside a flammable vapour cloud above the lower explosive limit (LEL) concentration in proximity to an ignition source. This situation occurs because engineering controls and administrative controls were inadequate.
What exactly is comm on sense? This is where debate often begins. Why did the vapour cloud appear? Was a job safety analysis (JSA) completed? Was a JSA required since it was a routine task? Was the injured party a smoker? Was the tank grounded? Was the person using a cell phone? Did s/he need an LEL meter and hot work permit? Would FRC have prevented the injury? Could the supervisor have predicted the ignition source? How many times have we read an incident report with the statement “Ignition source could not be determined.”
The real problem is that people are getting hurt in flash fires. Survey any group of SH&E professionals who have worked in the industry for more than a few years and see how many have helped investigate a flash fire injury.
The number of injuries and fatalities attributed to flash fires by OSHA might surprise you. This statement is made to keep the reader focused on preventing injuries, not on details of regulations. Often, we hear that someone was hurt because they were not wearing FRC. This sounds like blaming the FRC for the flash fire. FRC does not prevent a flash fire. It lessens the severity of the injury. Pay attention to the number of vendors marketing new FRC materials and clothing designs. Logic dictates that with increased awareness and better FRC products, the incident rate should improve.
But is this really the case? The quality of available FRC is not a problem. Hazard recognition (or lack thereof) is a much greater problem than PPE will ever be. If people are working in an environment where LEL is commonly exceeded, it is only a matter of time before a flash fire will occur. Some people in our industry unwittingly promote the idea that it is acceptable for workers to be knowingly exposed to flammable gas vapours.
Over the past few months, OSHA has cited several companies for FRC use (or lack of use). OSHA does not have an FRC regulation, so how does this happen? Lack of job planning is the central issue for OSHA-that is, lack of engineering controls and inadequate administrative controls.
It is obvious that everybody does not know, otherwise injuries would not occur, and the citations would all be vacated (or never written in the first place). API, the American National Standards Institute (ANSI) and NFPA have all provided useful guidance that should help prevent flash fire injuries. “Everybody knows” is an interesting concept, especially considering the level of conviction people have on the details of this subject. Heated debates have taken place between SH&E professionals of comparable experience in the industry regarding whether their employees need FRC.
It is important to note the difference between compliance and consensus standards. Compliance standards are legal requirements, enforceable by OSHA, the U.S. Environmental Protection Agency (EPA) or some other authority. Consensus standards are an attempt by a nominated committee to identify industry best practices on a particular topic. Generally, the sponsoring agency will nominate industry representatives who are felt to best represent the initiative behind the new or revised standard. Consensus standards can be incorporated by reference, but in the case of FRC standards, this has not been the case.
American Petroleum Institute (API) collaborates with the industry to produce consensus standards. API RP 500, Recommended Practice for Classification of Locations for Electrical Installations at Petroleum Facilities Classified as Class I, Division I and Division 2, identifies areas that present a fire hazard to employees and, therefore, require PPE. These areas include work in Class I, Division I areas and work where a process is opened to increase the likelihood of flammable gases or vapours to 10% of the lower flammable limit (LFL). If you perform work in a Class I Division I area or open a process that contains flammable vapours, then API RP 500 identifies the need for FRC.
API summarizes RP 500 as follows: This recommended practice provides guidelines for determining the degree and extent of Class I, Division 1 and Class I, Division 2 locations at petroleum facilities for the selection and installation of electrical equipment. Basic definitions provided in the National Electric Code (NEC) have been followed in developing this document, which applies to the classification of locations for both temporarily and permanently installed electrical equipment. RP 500 is intended to be applied where there may be a risk of ignition due to the presence of flammable gas or vapour, mixed with air under normal atmospheric conditions.
In 1991, NFPA members approved two standards relevant to this discussion. NFPA 2112 and 2113 were approved by ANSI and are now identified as American National Standards.
NFPA 2112, Standard on Flame- Resistant Garments for Protection of Industrial Personnel Against Flash Fire, dictates the design, performance and testing criteria for materials used as FRC. NFPA 2113, Standard on Selection, Care, Use and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire, is more relevant to the current discussion since it provides detailed guidance on selection of FRC for personnel protection. The standard identifies a need for employees to wear FRC if they are exposed to flash fire hazard. The description in the standard is lengthy and goes into great detail, with an evaluation of risk based on predictable exposure to known hazards. The known hazards are based on materials classifications identified in NFPA 704, Standard System for the Identification of the Hazards of Materials for Emergency Response, and the exposure is separated into task exposures versus area/facility exposure.
It is important to be familiar with NFPA terminology. Hazard rating is from 0 to 4, with 4 being most hazardous. Do not confuse the hazard rating with liquid classes. Liquid classes include Class I, II and III with subsets (A, B, C). Class IA is most flammable.
NFPA 704 provides guidance for identifying an area or facility that presents a risk of flash fire. If the area is likely to have flammable vapours during normal operations, then FRC is required for all personnel in that area. Remember that Hazard Level 4 materials will have flammable vapours at standard temperatures, and Hazard Level 3 or 2 presents a flash fire hazard if heated above the flash point. The flash point for all Hazard Level 3 materials is below 100°F (approximately 38°C) while some have a flash point below 73°F (approximately 23°C).Flash point is the temperature at which flammable vapours are released. Natural gas vapours are lighter than air, H2S vapours are heavier than air and liquid fuel vapours are heavier than air.
The standard also provides guidance for identifying a specific task or job that presents a risk of flash fire. Criteria are the same as the area/facility evaluation, with the difference being loss of containment. If personnel perform a job where a Hazard Level 4 vapour will be released if the containment fails, then FRC is required. If personnel work in proximity to a Hazard Level 3 or Hazard Level 2 material that is heated above its flash point, be concerned. FRC is required if the product would be released from failed containment.
The NFPA fire hazard rating for natural gas is 4, and the NFPA fire hazard rating for crude oil is 3.
OSHA’s PPE standard (29 CFR 1910.132) states: The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE. If such hazards are present, or likely to be present, the employer shall select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment.
Think through the implications of this standard. As employer, the duty is to “protect the affected employee from the hazards.” If a hazard assessment does not identify flash fire and someone gets burned, is the employer subject to an OSHA penalty because its hazard assessment was faulty? On the other hand, if the employer prescribes basic FRC and the employee is burned severely because FRC was inadequate, isn’t the company in the same situation?
Would it not be more practical to focus on better engineering of the system and more effective hazard assessments? Use FRC where a moderate risk of flash fire exists and do not allow operations that pose risk of fire and explosion.
Heat stress is another issue. If the hazard assessment is thorough, all hazards associated with the job will be assessed. In certain locations, heat stress is a recognized hazard from April through September. This issue does not minimize the hazards of flash fire exposure, but it must be evaluated at the same time. In addition to the PPE requirements, OSHA has specific requirements regarding confined space entry procedures. The preamble to OSHA’s confined space regulations states, “OSHA considers an atmosphere to pose a serious fire or explosion hazard if a flammable gas or vapour is present at a concentration greater than 10 percent of its lower flammable limit.”
Those involved in power generation or electrical installation and repairs should review the content of 29 CFR 1910.269, Electric Power Generation, Transmission and Distribution as well.
Any time a new standard is published, it makes headlines for a while, then most people return to business as usual. Many have overlooked this issue for a long time. Here are the facts: 1994: OSHA produces the PPE standard. 2001: NFPA produces and ANSI approves 2112 and 2113. 2002: API RP 500.
The problem is people are getting hurt, and it may have to do with lack of hazard recognition. The hazards are not new, the PPE is not new, and permits and JSAs are in place, so what exactly is overlooked?
This is where recent OSHA activity becomes relevant. Some citations have been for failure to perform a hazard assessment and to identify appropriate PPE for the task at hand. If workers have not been involved in a hazard assessment, how can they tell an OSHA inspector whether FRC is required for their job?
Flash fire hazard assessment and mitigation in this industry can be complicated, especially if some of the variables faced are combined: upstream, pipeline or processing operation; aboveground, below grade or down-hole; oil, gas or water; operator, service company or contractor; company facility, landowner-controlled site or right-of-way access, etc.
Evaluate flash fire statistics for a particular operation as hazard assessments are performed. OSHA has limited incident data available in fatality reports and citation investigation reports, the International Association of Drilling Contractors has surveyed members recently, and other peer groups are actively researching this issue. Be aware that flash fire incident data are frequently intermixed with fire and explosion incident data.
In summary, NFPA/ANSI requires FRC if a hazard assessment identifies any of the following:
• A Class I, Division I area
• An area that is likely to have flammable vapours
• A task/job where people can come in contact with flammable or combustible liquids if released from failed containment
This article focuses on FRC use in dayto- day operations. The assumption is that a company has engaged the services of competent engineers and made every effort to engineer out fire hazards and has completed a hazard assessment for the facility and tasks.
Common comments include “they were burned severely” or “the fire lasted much longer than five seconds, and FRC would not have made a difference.” These may be correct, but what do they have to do with anything? It is impractical to put anyone in standard FRC and expect them to work in an extreme fire. These types of fires occur because someone overlooked a significant hazard. Either the engineering solution was inadequate, or safe work practices were not followed.
Do not wear standard FRC if the expectation is exposure to a major fire. That is like putting a person in a Tyvek suit and asking him/her to handle rusty hazardous waste drums on a HAZWOPER site with a hand dolly. HAZWOPER technicians complete 40 hours of training and wear a Level A suit. Extreme firefighters wear extreme FRC gear and extinguish big oilfield fires safely. One company has battled oilfield fires with no OSHA recordable injuries for more than a decade.
Hazardous material cleanups and oilfield fire plans begin with a hazard assessment. One cannot determine what PPE is appropriate until the hazards are clearly identified. Again, recent OSHA citations identified as “FRC citations” are actually for failure to perform a hazard assessment.
This issue is just as complicated as one wants to make it. One path to a solution could be to simplify the issue. We have heard the phrase “one size does not fit all” in the oil and gas industry. Some companies have made one size fit everyone anyway. All employees, contractors and visitors wear FRC any time they are on location. Some companies perceive this approach to be cost-prohibitive, especially the part about all contractors wearing FRC all the time.
This article does not address the logistics of managing a worker clothing program. This article intends to give the reader a good overview of the common issues, the regulations applicable to FRC and some food for thought on the topic.
This article provides an abbreviated summary of several lengthy industry and compliance standards. The nice thing about summaries is that they are short. The bad thing is that they leave out many details, not to mention the fact that the summary is subject to the interpretation of the author. Read the applicable standards.
As a minimum, ensure that the company operates in a legal manner. A simple starting point is the OSHA regulations. Do not look for loopholes. The intention of OSHA regulations is usually spelled out in the scope, preamble or first few pages. If you are not sure, ask a peer, search the American Society of Safety Engineers’ (ASSE) body of knowledge or contact an ASSE Oil and Gas Practice Specialty member.
Either be accountable for the safety of your workforce or wait for OSHA and the court system to hold you accountable. Several FRC-related citations have reportedly involved contractors as well as controlling employers. If you employ contractors, read Clyde Jacob’s article on the Summit case and its impact. If you are an operator, ensure that you communicate known hazards to contractor companies working for you. At that time, you ensure that their management can be responsible as an employer to protect their employees from known hazards.
It sounds easy if you keep is simple. Know the rules, identify the hazards, engineer them out if possible, use good administrative controls (e.g., permits, JSAs), provide adequate PPE and inform all personnel of the hazards. ×
Michael R. Farris, CSP, serves as an environment, health and safety (EHS) operations manager at Range Resources in Canonsburg, Pennsylvania. He is also the American Society of Safety Engineers (ASSE) Oil and Gas Practice Specialty Administrator.
Published: 10th Feb 2010 in Health and Safety Middle East
Michael Farris, CSP, EHS Operations Manager at Range Resources, ASSE Oil and Gas Practice Speciality Administrator
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