2017 NFPA Conference & Expo Dangers of Hot Work: Key Lessons from CSB Investigations Presented by: Samuel A. Oyewole, PhD. Office of Investigations U.S. Chemical Safety Board Washington, DC 1
Disclaimer 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 2 www.csb.gov
Presentation outline 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 3 www.csb.gov
CSB Overview 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) 4 www.csb.gov
CSB Overview Five-member board Presidential appointment Senate confirmation Five year terms Staff positions Investigators Recommendations Outreach 5 www.csb.gov
CSB Incident Selection Public fatalities & injuries Employee fatalities & injuries Public evacuation or nuisance External property damage Internal property damage Ecosystem damage Potential for greater consequences Potential for learning Public/Stakeholder concern Company or facility history Congressional request 6 www.csb.gov
CSB Investigation Process 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. 7 www.csb.gov
CSB Investigation Update (Hot Work Incidents)
Presentation Goals 1. 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.
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
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.
Hot Work Sources: http://www.hotworktraining.com/ http://rmehs.fullerton.edu/healthandsafety/occupationalsafet yandhealth/hotworkpermits.php http://riskconversation.com/blog/business/2013/10/22/worktoo-hot-to-handle/
Hot work incidents continue to occur Sunoco Logistics, 2016 Motiva Enterprises, 2001
CSB Hot Work Investigations & Deployments Deployment/Investigation Location Date Consequence Motiva Enterprise Refinery Bethune Point Wastewater Plant Delaware City, Delaware Daytona Beach, Florida July 17, 2001 January 11, 2006 1 fatality/8 injuries 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 Lessons Not Learned 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
Hot Work Incident Screening Employees Contractors Total Significant Injuries 80 24 104 Fatalities 28 20 48 85 relevant incidents recorded between 2010-2013 33% 26% 55 gal drums Oil field type tanks Vehicle Fuel tanks 7% 15% 19% Tanker trucks Other
Hot Work Safety Bulletin Available at: http://www.csb.gov/seven-key-lessons-toprevent-worker-deaths-during-hot-work-in-and-around-tanks/ www.csb.gov
CSB Investigation Key Lessons 1. Use Alternatives Whenever possible, avoid hot work and consider alternative methods. Use of cold work Designated hot work area Remove/isolate flammable materials Bethune Point Wastewater Plant Explosion, 2006
CSB Investigation Key Lessons 2. Analyze the Hazards Prior 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 www.csb.gov
CSB Investigation Key Lessons 3. Monitor the Atmosphere Conduct 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 4. Test the Area 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. EMC Used Oil Corporation, 2008
CSB Investigation Key Lessons 5. Use Written Permits Ensure 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 www.csb.gov
CSB Investigation Key Lessons 6. Train Thoroughly Train 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 www.csb.gov
CSB Investigation Key Lessons 7. Supervise Contractors Provide safety supervision for outside contractors conducting hot work. Inform contractors about site-specific hazards including the presence of flammable materials. Partridge Raleigh Oilfield, 2006
Good Practice Guidelines Gleaned From Industry Standards and Regulations April 14, 2017 Note [to be deleted]: This image may be replaced with a grayscale image of the subject facility.
Good Practice Guidelines Avoid hot work when possible. Consider all alternative methods to hot work... Source: http://www.thecuresafety.com/caution_hot_work_permit_required_large_p/c526pb.htm www.csb.gov
Good Practice Guidelines 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 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 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.
Good Practice Guidelines 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 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/m assive-flash-fire-during-welding-of.html 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)
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
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.
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
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
U.S. Chemical Safety Board 1750 Pennsylvania Ave, NW Suite 910 Washington, DC 20006 202-261-7600 www.csb.gov www.csb.gov
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