Chemical Safety Board Issues Hot Work Safety Bulletin
The Chemical Safety Board (CSB) has developed recommendations following its investigation of a triple fatality accident that occurred when welding on a tank containing hydrogen, due to bacteria digesting organic matter within, sparked an explosion. The seven key lessons learned from CSB's recent hot work accidents are:
1. Use alternatives when possible
2. Analyze the hazards
3. Monitor the atmosphere even in areas where a flammable atmosphere is not anticipated
4. Test the area whenever work is done near other tanks containing flammable liquids or gases.
5. Use written permits (Editorial comment: there are places where Hot Work permits aren't used? In 2010?
6. Train thoroughly
7. Supervise contractors - Provide safety supervision for outside contractors conducting hot work. Inform contractors about site-specific hazards including the presence of flammable materials.
CSB notes that while OSHA does not explicitly require the use of a combustible gas detector it is good practice to do so. The American Petroleum Institute and FM Global both have long stressed the need for combustible gas detectors to prevent fires and explosions.
As an aside, your writer learned, shortly after being admitted to the practice of law in 1986, that the oil and chemical companies here in Southeast Texas were using such gas detectors by the 1960s. In fact, in the case of one of my clients, a major refiner, its very first recorded fatality occurred in the 1930s when a man was killed by a manhole cover thrown through the air as the result of an explosion caused by hot work near a sewer. After its investigation the company paid to have someone develop a gas detector and it instituted a hot work permitting system more than 60 years ago.
