The plan also must include requirements establishing time to clean local spills or short-term accumulations, and to allow for the elimination of the spilled mass or accumulations derived from implementation of the Section 6.1 methodologies. Tables in Annex A provide guidance on the time allowed for such cleanup activities.
Section 184.108.40.206 mandates performing a documented risk assessment to determine the level of housekeeping consistent with any flash fire or dust explosion protection measures in Section 6.4, Deflagration Venting of the Room, and Section 11.22, Personal Protective Equipment (PPE), if the facility is operated at dust levels that exceed the chosen criterion in Section 6.1. (Chapter 11 includes new requirements for PPE where a room or building is judged to present a dust flash fire or explosion hazard.)
TRAINING AND PROCEDURES
Three specific areas have received important revisions:
• Written emergency response plan. There is a new requirement to develop a written emergency response plan for preventing, preparing for, and responding to work-related emergencies, which include fires and explosions. This plan must be reviewed annually or as required by process changes.
• Contractors and subcontractors certification. A significant number of incidents have been attributed to inadequate training of contractors or subcontractors. The owner of the facility ultimately is responsible for the actions of personnel performing activities on its site. The standard now mandates employing only qualified contractors possessing the requisite craft skills for work involving the installation, repair or modification of buildings (interior and exterior), machinery and fire protection equipment. Examples of the skill sets required are provided in the Annex and include applicable American Society of Mechanical Engineers (ASME) stamps and professional licenses.
In addition, contractors involved in the commissioning, repair or modification of explosion protection equipment must be qualified as specified in Chapter 15 of NFPA 69, "Standard on Explosion Protection Systems." Basically this requirement includes both training and authorization by the specific explosion-protection-system manufacturer.
• Contractor training. The standard now requires that contractors operating owner/operator equipment be trained and qualified to operate the equipment and perform the work. Written documentation must be maintained on the training provided and the individuals trained. In addition, any contractor working on or near a given process must be made aware of potential hazards from exposures to fire, explosion or toxic releases. That individual also must comply with the facility's safe work practices and policies, including (but not limited to) equipment lockout/tagout permitting, hot work permitting, fire system impairment handling, smoking, housekeeping and use of PPE. Contractors also must be trained on the facility's emergency response and evacuation plan, including (but not limited to) emergency reporting procedures, safe egress points and evacuation areas.
The 2013 revision of NFPA 654 imposes several new administrative requirements designed to improve safety, including:
1. reporting of incidents;
2. providing PPE for employees working in areas where a flash fire or explosion hazard exists;
3. implementing a housekeeping program designed to prevent dust flash fire or explosion hazards in buildings or rooms;
4. developing an emergency response plan; and
5. establishing contractor qualification and training.
Familiarity and understanding of these requirements will enable an operator/owner to take the steps necessary to comply with the revised standard. Expert help may be required in some cases.
STEVEN J. LUZIK, PE, CFEI, is senior process safety specialist for Chilworth Technology, Inc., Princeton, N.J. E-mail him at email@example.com.