Hazardous Materials
The battle continues, this time outside process safety! I get these arguments routinely when people inquire if they can use their HHC/EHS as the media for pressure and leak testing. I can only assume that PHMSA is getting pushback by requiring water or other similar viscosity liquid to be used as the test medium. When hydrostatic pressure tests for cargo tanks are required in part 180, subpart H, the HMR requires that water or other similar viscosity liquid be used as the test medium (see § 180.407(g)(viii)). PHMSA understands that some stakeholders believe the requirement to use water—or other similar viscosity liquid—may be unduly restrictive. PHMSA has authorized the use of alternate test mediums for portable tank testing (e.g., DOT SP–20294, 20308, and 16163), but has not authorized this for cargo tanks. PHMSA requests comment on the following questions to evaluate authorizing additional liquids for hydrostatic testing cargo tanks: Read more ... Add new comment
The 2024 edition of the International Fire Code has a new "table" that lists several exemptions. These exemptions come with some limitations, such as... Exempted materials and conditions listed in this table are required to comply with provisions of this code that are not based on exceeding maximum allowable quantities in Here are a few of the exemptions that may be of interest:
The refrigerant in this accident is R-32 ( ), described as " a colorless, odorless, mildly flammable gas. "Its ASHRAE rating is A2L, making it a CAT1B flammable gas if OSHA adopts Rev. 7 of the GHS this year.These A2L "mildly flammable gases" are exempt from many of the requirements other flammable gases must meet (e.g., electrical classifications, mechanical exhaust ventilation, gas detection, etc.).
If you're an EHS pro, you have certainly seen these devices. They can add a level of safety for that loss of primary containment (LOPC) incidents or, in some cases, overfill events. image source: eagle manufacturing But these "Containment Pallets" come with some environmental limitations that are required for their safe use...
The most common RAGAGEP for pipe labeling is ASME A13.1, Scheme for the Identification of Piping Systems. It is referenced in dozens of hazardous material codes, from ICC to NFPA. In the ICC codes, specifically the International Fire Code (IFC), there is an interesting twist to the requirements for "Compressed Gases (Chapter 53). ASME is mentioned as the RAGAGEP of choice to follow, but then the code goes on to list WHERE labels must be applied. 99% of this verbiage is the same as we will find in A13.1, except for this little nugget (which is no longer stated in A13.1)...
One of the reasons I use the International Fire Code (IFC) for my hazardous materials code over OSHA standards is that the IFC gets updated every three (3) years. God only knows when OSHA may address lithium-ion and lithium-metal batteries. Also, the IFC and NFPA tend to be closely aligned in their design and practices expectations. Chapter 3, Section 320 is new in 2024, and it covers:
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