Article Archive
Not all fires are the same
The importance of hazard assessments
Vol. 26 Winter

When it comes to protecting workers from the hazards of industrial fires, there is no such thing as a “typical” fire. Workers in different industries are susceptible to many different types of fires and it is the responsibility of the employer and typically the task of the site Industrial Hygienist or Safety Manager to understand the potential hazards their workers may face and to protect them accordingly. This article will discuss the regulatory and procedural issues associated with protecting workers from the hazards of fires in today’s workplace.

In the U.S., the federal Occupational Safety and Health Administration (OSHA) is at the top level of the regulatory structure pertaining to protecting workers from fires in the workplace. Under the OSHA general duty clause (1970 OSH Act, Sec. 5. Duties) it is the responsibility of the employer to identify and quantify any hazards to workers and provide the appropriate control measures, procedures and protective equipment to minimize the risk of injury to workers. OSHA occasionally provides specific guidelines for a particular industrial group (such as the March 19th 2010 memorandum regarding OSHA Personal Protective Equipment (PPE) regulations in 29 CFR 1910.132 as applied to flame resistant Clothing in Oil and Gas Drilling, Well Servicing, and Production-Related Operations); however, in most cases OSHA will refer to National Consensus Standards or recognized organizations representing industrial centers for process safety that exist for specific industries for hazard assessment guidance. In the case of industrial fires, the National Consensus Standards that OSHA has recognized are NFPA 2112 and 2113. In addition, OSHA also cites the AIChE Center for Chemical Process Safety as an organization that provides the industry with guidelines and analysis tools for fire hazard risk and mitigation. Moreover, OSHA publishes a variety of reference articles, such as OSHA 3071 – Job Hazard Analysis, to help safety professionals with the task of quantifying hazards in the workplace.

When discussing protection from industrial fires, it’s important to understand that the same approach needs to be followed as with any other workplace hazards. OSHA has cited NFPA 2113 as an industrially recognized National Consensus Standard that provides clear guidelines and references to tools to help with this task. There has been some confusion in this area and many safety professionals incorrectly believe that they should follow NFPA 2112. NFPA 2112 is a minimum performance specification that garments must meet to be considered flame resistant (FR).  NFPA 2112 does not address any of the actual workplace conditions that must be considered for hazard assessment and the protection of workers.

When following NFPA 2113, safety professionals must examine many aspects of the workplace and potential hazards in order to develop an accurate analysis. We will review some of those items for consideration in the following sections. This section is not intended to be a definitive list of required considerations, especially as each workplace and hazard is unique, but includes common examples of items for consideration. Ultimately, it is the responsibility of the employer and their designated safety professionals to identify all potential factors that need to be included in their particular hazard analysis to ensure its accuracy and completeness.

  • Fuel type and quantity available. The materials that can potentially ignite vary widely in the amount of energy that they release; an important part of the hazard analysis is to accurately quantify the amount of heat energy potential for a given material. There are many tools available to help with this process, including the SFPE Handbook of Fire Protection Engineering. This resource (available from NFPA) includes detailed information on fire fundamentals, dynamics, hazard calculations, design calculations, and fire risk analysis. It can be used to execute vapor cloud and liquid fuel fire energy potential calculations and identifies references for more in-depth analysis. When addressing fuels, both the type of material and the quantity available must be considered. For example, the energy potential will be very different for a natural gas leak from a low pressure residential line versus an underground 26 inch LNG transmission main. In this case we have the same fuel with the same combustion characteristics, but with very different total energy release potentials.
  • Work being performed in the area and it’s potential to cause release: When conducting a hazard analysis, it’s important to consider the job functions taking place in the area where flammable materials exist and the likelihood that these activities could trigger a release and provide a source of ignition. Are workers performing line breaks? Is there the potential for static discharge? Are workers operating equipment such as forklifts, trucks, or lift equipment in an area where they could inadvertently contact a line, valve, or fitting that could rupture?
  • Engineering controls in place to mitigate a release: Evaluate the safety procedures and mechanisms that are in place to stop the flow of the flammable material(s) in the event of a release. Once again, in the instance of natural gas, the rupture of an underground transmission line may require a person to drive to the next upstream valve and manually operate it to stop the flow of fuel to a leak. This situation differs considerably from a release at a manufacturing facility with an automated control room that can quickly close a shut-off—the same fuel can require very different response times to mitigate a release can result in very different energy potentials. 
  • Egress routes for the worker(s) involved: A hazard analysis should consider how workers would escape an incident in the event of a release and ignition. During that escape process, how much of the time would they potentially be exposed and to what level of thermal energy? During egress, how much exposure would be expected in the fire from full engulfment and how much would be expected outside the fire from radiant heat (decreasing as the distance from the incident increases)?
  • Accident histories: This is a study area that safety managers can benefit greatly from as it can reflect a broader industrial experience beyond their particular industry, site, or organization. There have been many industrial releases and accidents that were thoroughly examined by various investigators, such as the U.S. Chemical Safety Board (CSB). Their findings are generally available to all in industry and provide valuable learning experiences with broad and specific industrial hazard mitigation recommendations. For example, there are numerous incident investigations conducted by the CSB that highlight engineering, procedural, and systems failures where significant escalation had occurred, These investigations include examples not commonly considered, such as when an initial fire event results in damage to nearby equipment thereby triggering additional releases of flammable materials and a substantial increase in event severity. There are volumes of case histories available and it is time well spent for safety professionals to review past incidents at similar type organizations and operations to glean valuable learnings into hazard recognition and potential mitigation.

It is evident that there are many factors that must be considered when evaluating exposure potentials.  Industrial fires can range greatly in both their duration and severity and it is the responsibility of the employer and their designated safety personnel to quantify all potential exposure scenarios. Once the hazard analysis is complete, the final step is the development and implementation of a Fire Safety Program. Keep in mind that any safety program needs to be dynamic and evergreen. Things change in the workplace (new products, new equipment, new personnel, new facilities, etc.), the regulatory standards and guidelines are updated, new and improved engineering controls are developed, and new research is conducted that can offer additional guidance in protecting workers.

NFPA 2113 is a valuable source of information that will help the safety professional develop a meaningful and comprehensive fire safety program. A good program can include, but is not limited to: 

  • Engineering controls to eliminate hazards(s)
  • Administrative controls such as standardized Operating Procedures and Practices designed to reduce the exposure potential
  • Preventative maintenance, inspections, and other process integrity programs aimed to identify issues before they occur
  • Employee involvement through the use of focus groups, safety inspections, and feedback systems
  • Operational, safety, and equipment usage training programs
  • A comprehensive PPE program where the hazard cannot be completely removed

The elements of the PPE program for fire should be firmly based on the hazard analysis. It should identify garment systems that have been tested and meet the mitigation requirements for the work environment and the exposure levels identified. It should address the proper foot, hand, eye and head protection, as well as specific garment designs appropriate for the work being done. Once specified, employee training in the proper use of PPE should be planned with a program that verifies continuous understanding and utilization. In addition, a care and maintenance program is also required to assure that the effectiveness of the PPE has not diminished over time or use.

At the end of the day, protection from fires must be approached just like any other workplace hazard – an analysis must be conducted to accurately quantify the risks and a program developed to mitigate those risks appropriately. As no two industrial fires are the same, no two fire safety programs are likely to be the same. Each must be custom tailored to each particular organizations unique environment. 

When it comes to protecting workers from the hazards of industrial fires, there is no such thing as a “typical” fire. Workers in different industries are susceptible to many different types of fires and it is the responsibility of the employer and typically the task of the site Industrial Hygienist or Safety Manager to understand the potential hazards their workers may face and to protect them accordingly. This article will discuss the regulatory and procedural issues associated with protecting workers from the hazards of fires in today’s workplace.

In the U.S., the federal Occupational Safety and Health Administration (OSHA) is at the top level of the regulatory structure pertaining to protecting workers from fires in the workplace. Under the OSHA general duty clause (1970 OSH Act, Sec. 5. Duties) it is the responsibility of the employer to identify and quantify any hazards to workers and provide the appropriate control measures, procedures and protective equipment to minimize the risk of injury to workers. OSHA occasionally provides specific guidelines for a particular industrial group (such as the March 19th 2010 memorandum regarding OSHA Personal Protective Equipment (PPE) regulations in 29 CFR 1910.132 as applied to flame resistant Clothing in Oil and Gas Drilling, Well Servicing, and Production-Related Operations); however, in most cases OSHA will refer to National Consensus Standards or recognized organizations representing industrial centers for process safety that exist for specific industries for hazard assessment guidance. In the case of industrial fires, the National Consensus Standards that OSHA has recognized are NFPA 2112 and 2113. In addition, OSHA also cites the AIChE Center for Chemical Process Safety as an organization that provides the industry with guidelines and analysis tools for fire hazard risk and mitigation. Moreover, OSHA publishes a variety of reference articles, such as OSHA 3071 – Job Hazard Analysis, to help safety professionals with the task of quantifying hazards in the workplace.

When discussing protection from industrial fires, it’s important to understand that the same approach needs to be followed as with any other workplace hazards. OSHA has cited NFPA 2113 as an industrially recognized National Consensus Standard that provides clear guidelines and references to tools to help with this task. There has been some confusion in this area and many safety professionals incorrectly believe that they should follow NFPA 2112. NFPA 2112 is a minimum performance specification that garments must meet to be considered flame resistant (FR).  NFPA 2112 does not address any of the actual workplace conditions that must be considered for hazard assessment and the protection of workers.

When following NFPA 2113, safety professionals must examine many aspects of the workplace and potential hazards in order to develop an accurate analysis. We will review some of those items for consideration in the following sections. This section is not intended to be a definitive list of required considerations, especially as each workplace and hazard is unique, but includes common examples of items for consideration. Ultimately, it is the responsibility of the employer and their designated safety professionals to identify all potential factors that need to be included in their particular hazard analysis to ensure its accuracy and completeness.

·      Fuel type and quantity available. The materials that can potentially ignite vary widely in the amount of energy that they release; an important part of the hazard analysis is to accurately quantify the amount of heat energy potential for a given material. There are many tools available to help with this process, including the SFPE Handbook of Fire Protection Engineering. This resource (available from NFPA) includes detailed information on fire fundamentals, dynamics, hazard calculations, design calculations, and fire risk analysis. It can be used to execute vapor cloud and liquid fuel fire energy potential calculations and identifies references for more in-depth analysis. When addressing fuels, both the type of material and the quantity available must be considered. For example, the energy potential will be very different for a natural gas leak from a low pressure residential line versus an underground 26 inch LNG transmission main. In this case we have the same fuel with the same combustion characteristics, but with very different total energy release potentials.

·      Work being performed in the area and it’s potential to cause release: When conducting a hazard analysis, it’s important to consider the job functions taking place in the area where flammable materials exist and the likelihood that these activities could trigger a release and provide a source of ignition. Are workers performing line breaks? Is there the potential for static discharge? Are workers operating equipment such as forklifts, trucks, or lift equipment in an area where they could inadvertently contact a line, valve, or fitting that could rupture?

·      Engineering controls in place to mitigate a release: Evaluate the safety procedures and mechanisms that are in place to stop the flow of the flammable material(s) in the event of a release. Once again, in the instance of natural gas, the rupture of an underground transmission line may require a person to drive to the next upstream valve and manually operate it to stop the flow of fuel to a leak. This situation differs considerably from a release at a manufacturing facility with an automated control room that can quickly close a shut-off—the same fuel can require very different response times to mitigate a release can result in very different energy potentials. 

·      Egress routes for the worker(s) involved: A hazard analysis should consider how workers would escape an incident in the event of a release and ignition. During that escape process, how much of the time would they potentially be exposed and to what level of thermal energy? During egress, how much exposure would be expected in the fire from full engulfment and how much would be expected outside the fire from radiant heat (decreasing as the distance from the incident increases)?

·      Accident histories: This is a study area that safety managers can benefit greatly from as it can reflect a broader industrial experience beyond their particular industry, site, or organization. There have been many industrial releases and accidents that were thoroughly examined by various investigators, such as the U.S. Chemical Safety Board (CSB). Their findings are generally available to all in industry and provide valuable learning experiences with broad and specific industrial hazard mitigation recommendations. For example, there are numerous incident investigations conducted by the CSB that highlight engineering, procedural, and systems failures where significant escalation had occurred, These investigations include examples not commonly considered, such as when an initial fire event results in damage to nearby equipment thereby triggering additional releases of flammable materials and a substantial increase in event severity. There are volumes of case histories available and it is time well spent for safety professionals to review past incidents at similar type organizations and operations to glean valuable learnings into hazard recognition and potential mitigation.

It is evident that there are many factors that must be considered when evaluating exposure potentials.  Industrial fires can range greatly in both their duration and severity and it is the responsibility of the employer and their designated safety personnel to quantify all potential exposure scenarios. Once the hazard analysis is complete, the final step is the development and implementation of a Fire Safety Program. Keep in mind that any safety program needs to be dynamic and evergreen. Things change in the workplace (new products, new equipment, new personnel, new facilities, etc.), the regulatory standards and guidelines are updated, new and improved engineering controls are developed, and new research is conducted that can offer additional guidance in protecting workers.

NFPA 2113 is a valuable source of information that will help the safety professional develop a meaningful and comprehensive fire safety program. A good program can include, but is not limited to: 

·      Engineering controls to eliminate hazards(s)

·      Administrative controls such as standardized Operating Procedures and Practices designed to reduce the exposure potential

·      Preventative maintenance, inspections, and other process integrity programs aimed to identify issues before they occur

·      Employee involvement through the use of focus groups, safety inspections, and feedback systems

·      Operational, safety, and equipment usage training programs

·      A comprehensive PPE program where the hazard cannot be completely removed

The elements of the PPE program for fire should be firmly based on the hazard analysis. It should identify garment systems that have been tested and meet the mitigation requirements for the work environment and the exposure levels identified. It should address the proper foot, hand, eye and head protection, as well as specific garment designs appropriate for the work being done. Once specified, employee training in the proper use of PPE should be planned with a program that verifies continuous understanding and utilization. In addition, a care and maintenance program is also required to assure that the effectiveness of the PPE has not diminished over time or use.

At the end of the day, protection from fires must be approached just like any other workplace hazard – an analysis must be conducted to accurately quantify the risks and a program developed to mitigate those risks appropriately. As no two industrial fires are the same, no two fire safety programs are likely to be the same. Each must be custom tailored to each particular organizations unique environment.

 
 

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