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Report on Comments – June 2011


atmosphere is at or above the 10% LFL. For concentrations at or above 10% LFL, paragraph (d) would


employer to incorporate safe work procedures to address the flammable/explosive hazard (such as equipment approved

for hazardous locations) in the entry plan for those spaces. Electrical equipment as well as other sources of ignition

(non-sparking hand tools)

be considered and addressed for the hazardous atmosphere.”

  • U.S. Environmental Protection Agency (EPA) has identified hazardous wastes from industry specific sources known

as the K-List. Under petroleum refining section, used hydrotreating catalyst (K171) and used hydrorefining from petroleum refining operations (K172) are identified as ignitable hazardous wastes. EPA also identifies solvents such as xylene, acetone, ethyl acetate, ethyl benzene and ethyl ether commonly used in all industries (the F-list) and discarded commercial chemical products such as acetone, benzene, ethyl ether and xylene (the P-list and U-list) as ignitable hazardous wastes. OSHA regulation 29 CFR Parts 1910.120, Hazardous waste operations and emergency response, paragraph 1910.120(j)(2)(v) requires that “When there is a reasonable possibility of flammable atmospheres being present, material handling equipment and hand tools shall be of the type to prevent sources of ignition.

  • Even API members such as ExxonMobil and Chevron as well as others in the petroleum industry such as Valero,

CITGO Petroleum Corporation, Chem-Supply, Pty Ltd, Irving Oil Ltd, Petrol Star Inc, Nova Chemicals and El Paso Corporation list “non-sparking” tools under Accidental Release Measures and Handling and Storage sections in the MSDS’s for their petroleum products. These companies clearly recognize the need for “non-sparking” tools in working with and around flammable materials. Clearly, API 2214 conflicts with OSHA regulations, Accredited Standards Developer’s standards and safe work practices.

2. The Committee stated that “the Committee is not aware of any pattern of fire incidents that can be linked to the use of ferrous tools. This is anecdotal information that does not indicate a significant fire hazard pattern.” The Report of the BP U.S. Refineries independent Safety Review Panel, also known as the Baker Panel Report, states that “Preventing process accidents requires vigilance. The passing of time without a process accident is not necessarily an indicator that all is well and may contribute to a dangerous and growing sense of complacency.” Listed below are accidents caused by sparks from metal tools demonstrating that ferrous tools can be an ignition source in flammable environments.

  • OSHA inspection # 300965795, an employee in the process of cleaning loose material from drill piping with a

metal hammer. While striking the pipe with a hammer, an explosion occurred. Employee was killed in the explosion on site.

  • OSHA inspection # 2272953, two employees were assigned the job of tending a 100 gallon (water jacket)

reactor kettle of methyl methacrylate in the mixing room. Employee #1 used a metal wrench (visegrips) to pry open the cover of a kettle. The wrench handle struck the angle iron support for the agitator motor, producing a spark. Employee #2 noticed the spark, which was immediately followed by a massive “fire ball”. Both employees were engulfed in the fireball. Employee #3 came to the area to assist the other employees. The investigation states that non-sparking tools were not provided for the employees. All three employees received first and second degree burns on their face, arms and abdomen. Employee #2 also received some third degree burns. All three employees were hospitalized.

  • OSHA inspection # 124728437, Employee #1 and a coworker, both maintenance mechanics, were working in a

30 inch by 36 inch manhole at a gas station. Employee #1 was trying to change a fuel pump, while the coworker watched from outside the manhole. Employee #1 was using an Allen wrench to loosen the bolts on the fuel pump lead when he created a spark that ignited the gas fumes in the manhole, causing an explosion. Employee #1 suffered burns to his face, hands, arms and legs in the explosion and was hospitalized.

  • OSHA inspection # 111109237, Employee #1 or #3 attempted to cut a metal pipe with a metal saw while

Employee #2 was standing on top of one of two 5,000 gallon gas tanks, trying to remove a tank fitting. Sparks from the saw, the pipe wrench, or another unknown source ignited the gas vapors, which exploded. Employees #1 and #3 were killed of burns at the scene. Employee #2 died at the burn center as a result of burns sustained in the explosion.

  • OSHA inspection#102826625, Employee #1 worked for a company that cleans paints and replaces valves in

LP and MAPP gas cylinders. Before removing an old valve, Employee #1 would open the valve to let the residual gas leak out on the loading dock. Where there was a large quantity of cylinders, Employee #1 would invert the cylinder so the residual gas could vent faster. Employee #1 had an accumulation of a gas and air mixture around his work area. The vapors were ignited either by a spark from the metal screwdriver he was using to open a damaged valve or by an open flame burner approximately 40 feet away. There was a fire and explosion. The employee sustained 2nd and 3rd degree burns on the lower half of his body and was hospitalized.

  • OSHA inspection # 607366, an employee was sawing an airplane wing into sections with a portable powered

hand saw, the saw created a spark that caused an explosion of gasoline vapors in the wing fuel tank. Employee #1 killed and Employee #2 injured in explosion and was hospitalized.

These examples of OSHA documented accidents illustrates that accidents do happen when proper safety measures are not taken against mechanical sparks from steel tools as a possible ignition source. We are not equipped to show

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