Report on Comments – June 2011
_______________________________________________________________________________________________ Mindy Wang, Ampco Safety Tools 30-257 To add new text to read as follows: 29.3.18 Mechanical work shall not be performed on the wharf during cargo transfer, except under special authorization based on a review of the area involved, methods to be employed, and precautions necessary. Tools used to perform
mechanical work shall be spark resistant. In response to the original proposal the Committee expressed multiple concerns
. The following is
intended to discuss each of these concerns:
1. The Committee cites “the work of the American Petroleum Institute (API 2214), which refuted the need for non-sparking tools, except in very special circumstances.” However, information presented below shows API 2214 is misleading and undermines safe work practices.
FM Approvals LLC, formerly Factory Mutual Research Corporation (FM) is an international organization recognized
by the U.S. government as a Nationally Recognized Testing Laboratory (NRTL) for scientific research and product certification. Product approval from a NRTL assures that products meet consensus-based standards of safety to provide the assurance, required by OSHA, that these products are safe for use in the United States workplace. FM Approval Standard 7910, Spark Resistant Tools is used as guidance to evaluate tools intended for use in environments where there is a risk of ignition of flammable materials, dusts or vapors resulting from sparks created by iron and steel hand tools. These tools prevent the ignition of flammable materials, dusts or vapors by mechanical sparks created by the use of iron and steel hand tools slipping or striking a surface. American Petroleum Institute (API) Publication 2214 contradicts NRTL research and product certification as evidence in FM Approvals granted for spark resistance tools. FM has conducted a test as covered in Report Job Identification No. IN4A0.AF in accordance with the requirements of Safety Tools Approval Test Procedure, Class 7910 and test results show:
Sparks created from steel plates ignited carbon disulfide saturated pads, eight of eight tests, ethyl ether pads, five
of eight tests, and naphtha VM&P four of eight tests.
No sparks were observed and no ignition of the flammable liquids mentioned above from approved safety
Other investigations also contradict API’s conclusion on non-sparking tools. A paper published in the Fire Protection
Journal, “The Danger of Incendive Sparks”, stated that after API’s conclusion on “non-sparking” tools, Institute of Petroleum sought the advice of the Fire Research Board Committee on Industrial Fires and Explosion. This committee came to certain conclusions, one of which was “Until…evidence is obtained to show that the impact of steel hand tools on steel is safe, it is advisable to use non-sparking tools in situations where flammable atmospheres are unavoidable”.
The NFPA Fire Protection Handbook, 20th edition, published in January 2008, does not support the conclusion that
API 2214 represents. In fact, many NFPA codes
the use of “non-sparking” tools in flammable atmospheres.
According to NFPA Fire Protection Handbook, “When flammable and combustible liquids are stored or handled, the liquid is usually exposed to the air at some stage in the operation, except where the storage is confined to sealed containers that are not filled or opened on the premises or where handling is in closed systems and vapor losses are recovered. Even when the storage or handling is in a closed system, there is always the possibility of breaks or leaks,
which permit the liquid to escape. It is a
to eliminate sources of ignition in places where low flashpoint
flammable liquids are stored, handled, or used, even though no vapor may ordinarily be present.”
OSHA Flammable and Combustible Liquids regulation, 29 CFR Parts 1910.106(b) on tank storage, paragraph
(b)(6) states that precaution shall be taken to eliminate or control sources of ignitions including frictional heat
and mechanical sparks to prevent the ignition of flammable vapors.
NFPA 921, Guide for Fire and Explosion Investigations 2008 Edition, Chapter 5 Basic Fire Science Table 184.108.40.206
Reported Burning and Sparking Temperature of Selected Ignition Sources under Mechanical Sparks lists a Steel tool temperature at 2550°F. When working with flammable gases, liquids or vapors, a potential hazard arises because of the possibility that sparks produced by steel or iron tools can become an ignition source.
Recognizing the potential for steel tools to be an ignition source in flammable environment, the Occupational Safety
& Health Administration (OSHA) provides guidance in booklet 3080 Hand and Power Tools, 2002 revised, “iron and steel hand tools may produce sparks that can be an ignition source around flammable substances. Where this hazard exists, spark-resistant tools should be used.”
In OSHA regulation 29 CFR 1910.146 Permit-Required Confined Spaces, Appendix D Confined Space Pre-Entry
Check List, non-sparking tool is listed as one type of entry equipment. OSHA 29 CFR 1910.146 Standard
Printed on 9/16/2010