2017 NFPA Conference & Expo

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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

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• 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

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• 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

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CSB Overview

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• Five-member board– Presidential appointment– Senate confirmation– Five year terms

• Staff positions– Investigators– Recommendations– Outreach

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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

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• 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”

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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.

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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

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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

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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

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Hot Work Safety Bulletin

Available at: http://www.csb.gov/seven-key-lessons-to-prevent-worker-deaths-during-hot-work-in-and-around-tanks/

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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

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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

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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

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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

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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

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• “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

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• 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

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• 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

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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.”

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• 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

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• “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

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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)

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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

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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.

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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

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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

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U.S. Chemical Safety Board1750 Pennsylvania Ave, NW

Suite 910Washington, DC 20006

202-261-7600

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2017 NFPA Conference & Expo