Managing Hazardous Materials: The Missing Link
Neither OSHA nor EPA focuses on hazmat management as a general issue; this is where the hazmat sections of the various fire codes come into play.
MANAGING hazardous materials in a safe and compliant fashion can be a complex and daunting task unless proper planning and procedures are in place. Many environmental, health & safety (EHS) professionals turn immediately to OSHA and EPA regulations to determine what is required, then provide guidance to those who will ultimately be held responsible for proper use and storage of the hazardous materials.
Unfortunately, some of the most rigorous requirements that apply to hazardous materials management do not reside in OSHA or EPA regulations, but rather in the various fire codes that apply at both industrial and non-industrial facilities. Also unfortunately, many organizations, small, medium, and large, miss these important requirements, creating both potentially unsafe and non-compliant work environments through their hazardous materials handling practices.
How Many Fire Codes are There?
Several fire codes may apply at a given location, depending upon the state in which the business resides, and even the city or county in which it resides. Currently, portions of at least 32 states have adopted the International Fire Code (IFC)1 at the state or local government level, and in all between 35 and 40 states have adopted either the IFC or the Uniform Fire Code (UFC)2. The remaining states have adopted either the National Fire Code (NFC)3, other proprietary codes, or in a very few cases, no formal code at all.
Many major changes are occurring in the world of fire codes, including the integration of the UFC into the NFC (NFPA 1)4, resulting in a single code for implementation. When the dust settles, it is likely that 24 to 28 states will finalize adoption of the IFC, 20 to 23 will adopt the NFC, and the rest will adopt either a proprietary code or no formal code. This means that 90 percent plus of the states will eventually operate under code requirements that closely resemble the current IFC/UFC models; what does this really mean?
OSHA, EPA and Hazmat Management
While both OSHA and the EPA have promulgated regulations that affect hazardous materials, the actual application at most facilities is minimal. OSHA most certainly requires proper communication of the hazards related to these materials (29 CFR 191.1200), and in many cases it has established permissible levels of exposure (29 CFR 1910.1000). Additionally, for more hazardous and or complicated processes, OSHA requires implementation of rigorous hazmat and process management techniques through the process safety management standard (29 CFR 1910.119).
Finally, OSHA has established regulations pertaining to specific hazardous chemicals or processes that may or may not apply to any given industrial facility (29 CFR Subpart H)5. EPA, on the other hand, focuses on off-site and or long term on-site impacts of hazardous materials, and the better portion of regulations promulgated by this agency focuses on those issues. Examples include the management of hazardous wastes (RCRA), stormwater and other water discharge management (CWA), the control of air emissions (CAA), and other similar requirements.
Neither OSHA nor EPA, however, focuses on the management of hazardous materials as a general issue; this is where the hazmat sections of the various fire codes come into play.
Fire Codes and Hazmat Management
Because of space constraints, this article will not attempt to discuss all of the requirements that may be applicable within the various fire codes. However, because ultimately most industrial facilities will need to struggle with meeting the requirements currently included in the IFC and UFC, we will discuss the more common requirements included in these codes; more specifically, we will discuss the more salient portions of Article 80 of the UFC and Chapter 27 of the IFC.
Maximum Allowable Quantities
Both the IFC (Section 2703) and the UFC (Section 8001), based on type of occupancy (occupancy being a descriptor of the types of activities at the site), establish the maximum quantities of hazmats, by hazard class, that can be stored, dispensed, used, or handled within a control area (a control area is a space within a building that is enclosed and bounded by exterior walls, fire walls, fire barriers and roofs, or a combination of all of these).
As an example, the IFC limits the storage of Class IA flammable liquids in a non-"H occupancy" building, without sprinkler protection, to 30 gallons of cumulative volume. If the building is sprinklered and or if the flammable liquids are stored in approved storage cabinets, the allowable quantities can increase 100 percent--or even 200 percent if both conditions are met.
A careful review of the requirements, including the presence of existing controls, is required to determine maximum allowable quantities. Automotive and maintenance shops, for example, are locations where maximum allowable quantity limitations are frequently exceeded.
Systems, Equipment, and Processes
The IFC (Section 2703) and the UFC (Section 8001) both establish requirements for "systems, equipment and processes." These requirements include design and construction criteria for containers, cylinders, and tanks, as well as piping, tubing, valves, and fittings. The two sections noted often refer to other portions of the IFC and the UFC, where requirements are further specified. Both deal in a fairly significant amount of detail with alarms, maintenance, installation and maintenance of underground storage tanks, and required signage.
Section 8003 of the UFC and Section 2704 of the IFC describe storage requirements for hazardous materials, including the storage of incompatible materials and the requirements for secondary containment.
- Incompatible materials. One of the most commonly overlooked requirements of the fire codes is the requirement for the separation of incompatible materials. (Note: Incompatible materials are defined as "materials which, when in contact with each other, have the potential to react in a manner that generates heat, fumes, gases or byproducts which are hazardous to life or property.") The IFC and the UFC have the same requirement, which requires the storage of incompatible materials and the storage of materials incompatible with materials in use to be separated when the stored materials are in containers having a capacity of more than 5 pounds or a half gallon. The separation can be accomplished by:
1) Segregation of incompatible materials by a distance of not less than 20 feet;
2) Isolation of incompatible materials by a noncombustible partition extending not less than 18 inches above and to the sides of the stored materials;
3) Storage in hazardous materials storage cabinets; or,
4) Storage of compressed gases in gas cabinets or exhausted enclosures.
(Note: Incompatible materials may not be stored within the same cabinet or exhausted enclosure.)
An important point to note here is the use of the word "storage." While this may seem to be a "loophole," the fire code definition of "storage" is "the keeping, retention or leaving of hazardous materials in closed containers, tanks, cylinders, or similar vessels; or vessels supplying operations through closed connections to the vessel." This definition will require that most processes meet the separation requirements.
Common examples of improper storage of incompatibles include: the storage of Glacial Acetic Acid (an organic acid) in cabinets with oxidizing mineral acids such as Nitric Acid; acetylene cylinders stored in the same racks as oxygen cylinders; and, incompatible cleaning materials (acids and caustics) stored together. Attention to detail and knowledge of chemical properties in necessary to ensure proper storage.
- Spill control and secondary containment. Both fire codes require that "rooms, buildings or areas used for the storage of hazardous materials liquids in individual vessels having a capacity of more than 55 gallons (208.2 L) or when the aggregate capacity of multiple vessels exceeds 1,000 gallons (3785 L) shall be provided with spill control to prevent to the flow of liquids to adjoining areas." The codes further describe construction requirements for floors in indoor locations.
In addition to spill control requirements, the codes require secondary containment for hazardous materials liquids and solids. The requirements for secondary containment are very specific within both standards as to the construction of containment, monitoring for releases, etc. The standards also require that drainage systems be constructed of materials that are compatible with the materials stored and requires that incompatible materials be separated from each other with the drainage system.
Use, Dispensing, and Handling
Finally, Section 2705 of the IFC and Section 8004 of the UFC specify the requirements for the "use, dispensing and handling" of hazardous materials. These requirements include separation from the storage of hazardous materials (as discussed above), as well as:
1) The use of non-combustible, liquid-tight floors;
2) Appropriate spill control and secondary containment;
3) High level, low level, temperature, and pressure limit controls;
4) Standby and emergency power; and,
5) Other various requirements such as lighting, signage, etc.
Requirements vary greatly depending upon the specific hazmats handled, the application of "closed" versus "open" systems, and other variations.
The Missing Link
As you can see, the safe and compliant management of hazardous materials goes well beyond the coverage of OSHA and EPA. A good understanding of the applicable fire codes and implementation of sound practices and procedures is imperative to ensuring safe operations and overall compliance.
References1. The International Fire Code (IFC) is published by the International Code Council (ICC). ICC was established in 1994 as a nonprofit organization dedicated to developing a single set of comprehensive and coordinated national model construction codes. The founders of the ICC are Building Officials and Code Administrators International, Inc. (BOCA), International Conference of Building Officials (ICBO), and Southern Building Code Congress International, Inc. (SBCCI).
2. The Uniform Fire Code (UFC) originally was published by the Western Fire Chiefs' Association, which was formed in 1891 by a group of fire chiefs concerned about how to keep pace with the increasing demands on their limited resources.
3. The National Fire Code (NFC) is published by the National Fire Protection Association (NFPA).
4. In 2003, the UFC was integrated with the existing NFC to create NFPA 1. The resulting merged fire code is American National Standards Institute (ANSI) compliant and has gone through NFPA's consensus code development process.
5. The most detailed of these--29 CFR 1910.106--was the starting point for many of the original fire codes that covered hazardous materials. However, the codes have "moved on" and have more stringent requirements for flammable materials and hazardous materials in general.
This article originally appeared in the July 2004 issue of Occupational Health & Safety.