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2017 NFPA Conference & Expo
1
Dangers of Hot Work: Key Lessons from CSB Investigations
Presented by:
Samuel A. Oyewole, PhD.Office of Investigations
U.S. Chemical Safety BoardWashington, DC
www.csb.gov2
• This presentation is given by Dr. Samuel A. Oyewole, Chemical Incident Investigator at the United States Chemical Safety and Hazard Investigation Board on June 4, 2017, to the public audience at the National Fire Protection Association Conference & Exposition is for general informational purposes only. Users of this presentation should also note that the contents were compiled solely for this presentation.
• The presentation is, the view of, Dr. Oyewole. References, conclusions or other statements about current CSB investigations may be preliminary and may not represent a formal, adopted product or position of the Board. For information on completed CSB investigations, please refer to the final printed versions on the CSB website:
www.csb.gov
Disclaimer
www.csb.gov
• Overview of the Chemical Safety Board• CSB Hot Work Investigations Update • CSB Hot Work Investigation Key Lessons• CSB Hot Work Safety Video• Good Practice Guidelines• Existing Codes, Standards and Regulatory
Requirements• Conclusion• Questions and Answers
Presentation outline
3
www.csb.gov
• Independent, non-regulatory U.S. federal agency charged with investigating chemical accidents and hazards Investigates major chemical accidents Conducts scientific root cause investigations Conducts safety studies
• Modeled after the National Transportation Safety Board (NTSB)
CSB Overview
4
www.csb.gov
CSB Overview
55
• Five-member board– Presidential appointment– Senate confirmation– Five year terms
• Staff positions– Investigators– Recommendations– Outreach
www.csb.gov
CSB Incident Selection
• Public fatalities & injuries
• Employee fatalities & injuries
• Public evacuation or nuisance
• External property damage
• Internal property damage
• Ecosystem damage6
• Potential for greater consequences
• Potential for learning
• Public/Stakeholder concern
• Company or facility history
• Congressional request
www.csb.gov7
• Conduct interviews• Collect evidence and test equipment• Publicize key findings (preliminary and
final) and lessons learned – E.g. public meetings, full report, case study, video
• Issue recommendations to improve safety and for prevention.
CSB Investigation Process
CSB Investigation Update (Hot Work Incidents)
www.csb.gov
Presentation Goals1. To Understand the hazards associated
with hot work – The importance of monitoring the atmosphere
in the work area before and during hot work– Site-specific training on the hazards of hot
work and supervision during hot work.
2. To provide information on how you can safely apply the lessons learned from these cases to your site.
www.csb.gov
What is Hot Work? • NFPA 51B (2014 Edition) defines hot
work as: “(w)ork involving burning, welding, or a similar operation that is capable of
initiating fires and explosions.” Hot work includes other activities with the potential to create a source of ignition such as cutting, brazing, grinding, and soldering”
www.csb.gov
Hot Work• Work involving burning, welding, or a similar
operation that is capable of initiating fires or explosions.
• Hot work also includes other activities with the potential to create a source of ignition such as cutting, brazing, grinding, and soldering.
• Workers are at risk in the oil and gas industry, but also in many other sectors within general industry, such as food production, paper, and wastewater treatment.
www.csb.gov
Hot Work
Sources: • http://www.hotworktraining.com/• http://rmehs.fullerton.edu/healthandsafety/occupationalsafet
yandhealth/HotWorkPermits.php• http://riskconversation.com/blog/business/2013/10/22/work-
too-hot-to-handle/
Hot work incidents continue to occur
Motiva Enterprises, 2001
Sunoco Logistics, 2016
www.csb.gov
CSB Hot Work Investigations & Deployments
Lessons Not
Learned
Deployment/Investigation Location Date Consequence
Motiva Enterprise Refinery Delaware City, Delaware July 17, 2001 1 fatality/8 injuries
Bethune Point Wastewater Plant Daytona Beach, Florida January 11, 2006 2 fatalities/1 injury
Partridge-Raleigh Oilfield Raleigh, Mississippi June 5, 2006 3 fatalities/1 injury
Packaging Corporation of America Tomahawk, Wisconsin July 29, 2008 3 fatalities/1 injury
MAR Oil La Rue, Ohio October 19, 2008 2 fatalities
EMC Use Oil Corporation Miami, Florida December 2, 2008 1 fatality/1 injury
ConAgra Foods, Boardman Boardman, Oregon February 16, 2009 1 fatality
A.V. Thomas Produce Atwater, California March 31, 2009 2 injuries
TEPPCO Partners, LP Garner, Arkansas May 12, 2009 3 fatalities
E.I. DuPont de Nemours & Co. Inc. Buffalo, New York November 9, 2010 1 fatality/1 injury
Long Brothers LLC El Dorado, Arkansas May 21, 2012 3 fatalities
Omega Protein Moss Point, Mississippi July 28, 2014 2 fatalities
www.csb.gov
Hot Work Incident ScreeningEmployees Contractors Total
Significant Injuries 80 24 104Fatalities 28 20 48
26%
19%15%
7%
33%
85 relevant incidents recorded between 2010-2013
55 gal drumsOil field type tanksVehicle Fuel tanksTanker trucksOther
www.csb.gov
Hot Work Safety Bulletin
Available at: http://www.csb.gov/seven-key-lessons-to-prevent-worker-deaths-during-hot-work-in-and-around-tanks/
www.csb.gov
Whenever possible, avoid hot work and consider alternative methods.
• Use of cold work
• Designated hot work area
• Remove/isolate flammable materials
1. Use Alternatives
Bethune Point Wastewater Plant Explosion, 2006
CSB Investigation Key Lessons
www.csb.gov
2. Analyze the HazardsPrior to the initiation of hot work, perform a hazard assessment that identifies the scope of the work, potential hazards, and methods of hazard control.
Packaging Corporation of America, 2008
CSB Investigation Key Lessons
www.csb.gov
3. Monitor the AtmosphereConduct effective gas monitoring in the work area using a properly calibrated combustible gas detector prior to and during hot work activities, even in areas where a flammable atmosphere is not anticipated.
CSB Investigation Key Lessons
www.csb.gov
In work areas where flammable liquids and gases are stored or handled, drain and/or purge all equipment and piping before hot work is conducted.
4. Test the Area
EMC Used Oil Corporation, 2008
CSB Investigation Key Lessons
www.csb.gov
5. Use Written PermitsEnsure that qualified personnel familiar with the specific site hazards review and authorize all hot work and issue permits specifically identifying the work to be conducted and the required precautions. MAR Oil, 2008
CSB Investigation Key Lessons
www.csb.gov
6. Train ThoroughlyTrain personnel on hot work policies/procedures, proper use and calibration of combustible gas detectors, safety equipment, and job specific hazards and controls in a language understood by the workforce.
ConAgra Foods, 2009
CSB Investigation Key Lessons
www.csb.gov
Provide safety supervision for outside contractors conducting hot work. Inform contractors about site-specific hazards including the presence of flammable materials.
7. Supervise Contractors
Partridge Raleigh Oilfield, 2006
CSB Investigation Key Lessons
April 14, 2017
Note [to be deleted]: This image may be replaced with a grayscale image of the subject facility.
Good Practice GuidelinesGleaned From Industry Standards
and Regulations
www.csb.gov
• “Avoid hot work when possible. Consider all alternative methods to hot work ...”
Good Practice Guidelines
Source: http://www.thecuresafety.com/CAUTION_Hot_Work_Permit_Required_Large_p/c526pb.htm
www.csb.gov
• American Petroleum institute (API) Recommended Practice 2009 – “Safe Welding, Cutting and Hot Work Practices in the Petroleum and Petrochemical Industries” p. 13 states: – “(t)he permit process should indicate who is
responsible for inspecting the work site, conducting gas testing, and approving the permit allowing hot work to be done.”
Good Practice Guidelines
www.csb.gov
• American Petroleum institute (API) Recommended Practice 2009 – “Safe Welding, Cutting and Hot Work Practices in the Petroleum and Petrochemical Industries,” p. 12 states:– “(a) competent person using an appropriate
combustible-gas meter should perform tests to determine flammable vapor concentrations before hot work is started. An oxygen reading is needed before doing flammability testing for confined spaces.”
Good Practice Guidelines
www.csb.gov
Good Practice Guidelines• The National Fire Protection Association’s
“Standard for Fire Prevention During Welding, Cutting and Other Hot Work,” NFPA 51B (2014 Edition) requires:– “training on safe operation of the equipment
and in the safe use of the process,”
• Furthermore:– “(d)evelop a hot work training curriculum for
all management, full time and temporary employees, and contractors.”
www.csb.gov
• Industrial research shows the risk of fire can increase over 100% when outside contractors are involved in hot work without facility supervision.”
Good Practice Guidelines
www.csb.gov
• “Protect all permanent storage tanks or piping (that cannot be moved or drained) against physical contact and heat from hot work equipment.
• Preferably all equipment that is within reach of the hot work equipment (grinder, welding rod holder, cutting torch, etc.) will be drained, purged and inerted.”
Source: http://metroforensics.blogspot.com/2016/08/massive-flash-fire-during-welding-of.html
Good Practice Guidelines
www.csb.gov
Existing Codes and Statutes
• OSHA 29 CFR 1910.252 Welding, Cutting, and Brazing- General Requirements
• OSHA 29 CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals
• NFPA 1 Uniform Fire Code (2015)• ICC International Fire Code (2015)
www.csb.gov
OSHA 1910.252, NFPA 51B• Welding, Cutting and Brazing• Proscriptive not Preventative• Ex: 1910.252(a)(1)(ii) “Guards. If the object to be welded or cut cannot be moved and if all the fire hazards cannot be removed, then guards shall be used to confine the heat, sparks, and slag, and to protect the immovable fire hazards.”http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9853
www.csb.gov
NFPA 326, 2015 Edition• Standard for the
Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair.
• Requirements for testing before and during hot work and continuous or periodic monitoring by qualified personnel.
• Not incorporated by reference in federal standards.
www.csb.gov
Conclusion• CSB has continued to advocate for
best practices and recommended improvements of consensus standards, specifications, recommended practices, technical reports and codes to address hot work activities. Recently provided comments to NFPA
for the next edition of NFPA 51B
www.csb.gov
Conclusion• CSB has continued to push for the
adoption of its recommendations aimed at preventing hot work incidents Emphasizing the need for increased
hot work hazard awareness Stronger oversight and responsibility
for hot work activities. Designated safe hot work practices as
a Driver of Critical Chemical Safety Change Program
www.csb.gov
U.S. Chemical Safety Board1750 Pennsylvania Ave, NW
Suite 910Washington, DC 20006
202-261-7600
www.csb.gov
CEUs: To receive CEUs for this session, scan yourbadge at the back of the room before leaving
Evaluation: Complete a session evaluation on the mobile app. (Search app store for ‘NFPA 2017 C&E.’)
Handouts: Handouts will be available via the mobile app and at nfpa.org/conference
Recordings: Audio recordings of all sessions will be available free of charge via NFPA Xchange.
2017 NFPA Conference & Expo