UNDERSTAND BASIC ENGINEERING CODES

Herbert W. Cooper, Dynalytics / CodeLamp Corp.

Published in Hydrocarbon Processing

Houston, Texas, U.S.A.

August 2003, pages 73-80,

UNDERSTAND BASIC ENGINEERING CODES

Herbert W. Cooper, Dynalytics / CodeLamp Corp.

rocess safety and risk management programs, safety audits and similar activities are being increasingly used in the United States within the industrial sector, and are indeed leading to a safer workplace. The incidence of workplace injuries and

illnesses in the goods-producing sector of private industry has dropped each year, from 9.9 per 100 full-time workers in 1997 to 7.9 in 2001.1 The benefits these programs bring are possibly even more significant considering industry's increasingly severe processing conditions (temperatures, pressures, corrosivity) and increasingly complex operations of new facilities, and the aging of existing ones.

P Unfortunately however, design, construction and operational flaws continue to lead to fatalities, disabilities and serious property losses every year. Each year there are approximately 5,000 workplace fatalities in the United States, other than from homicides.1 Within the industrial and manufacturing sector, there are approximately 17,000 fires per year, causing 20 fatalities, 550 serious injuries and a direct economic loss (excluding those from the September 11, 2001 World Trade Center attack) of approximately 7.8 billion dollars in the United States.2 Many serious safety-related problems can be avoided by fully complying with the provisions of appropriate codes and standards that have been developed, made widely available and adopted as requirements by many private and governmental organizations. Full compliance is usually required to obtain the necessary construction and operating permits as well as adequate insurance coverage. Currently, in response to financial pressures, many companies are losing experienced engineering staff by attrition or reduction-in-force, and are adjusting by increasing their outsourcing of critical activities. Although the subcontractors may understand safety issues and indicate that they have manuals, training programs and procedures, responsibility for plant safety remains with plant management. In many cases, however, they unfortunately have not internalized the knowledge necessary to effectively oversee safety aspects of subcontractors’ performance. It is therefore quite possible that workplace safety will not continue to improve. It may even deteriorate with occasionally devastating consequences. An overview of the nature, use and limitations of codes follows, intended to help orient new and infrequent code users in the industrial sector.

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efinition of terms. Succinctly put by the International Organization for Standardization (ISO)3, D

Standards are documented agreements containing technical specifications or other precise criteria to be used consistently as rules, guidelines, or definitions of characteristics, to ensure that materials, products, processes and services are fit for their purposes.

Standards are documents whose requirements may be met on a voluntary basis unless and until they are incorporated into a governmental regulation. Codes, as discussed below, are legal requirements. Related classes of documents are “Recommended Practices” and “Guidelines.” These normally present material that, while not codified and not quite a standard, has been found to be helpful and may be used on a voluntary basis, or may be ignored. System and equipment design engineers servicing the process industries are most interested in the Codes, Standards, Recommended Practices and Guidelines that have been developed to define the properties and testing of materials of construction, and the design, installation and testing of complete equipment assemblies and facilities. Personnel in companies that produce or process materials such as oil, chemicals, foods or metals are generally interested in additional documents that cover lockout/tagout, entering confined spaces, product testing, emission testing, and mandated reporting of emissions, discharges and accidents to appropriate governmental agencies. Requirements for Risk Management Programs and testing of mechanical integrity also must be properly addressed. A particular document may cover one or more of these.

ode Producers. At the federal level, Congress passes an Act (law), whose text is a Public Statute. Certain governmental agencies, such as the following, are authorized

to create Regulations. These are the specific rules necessary to put the law into practice and define what is legal and what is illegal. While each state and local municipality may promulgate regulations, minimum technical requirements that have major impacts on the industrial sector generally arise from three United States Agencies:

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Environmental Protection Agency (EPA)

The EPA is a large agency with a budget of $7,724,000,000 and a staff of almost 18,000.4 It has passed a great many rules, many of which are very complex, covering allowable compositions and quantities of gaseous emissions, liquid discharges and solid wastes, test methods and reporting requirements. EPA regulations may be found in the Code of Federal Regulations (CFR) Title 40 Protection of Environment. They include, as an example, design and testing requirements for emission- and accidental release-control for storage tanks.

Occupational Safety and Health Administration (OSHA) of the Department of Labor The OSHA is a mid-size government agency with an annual budget of approximately $445,000,000.5 It has focused largely on preventing and reporting accidents in the

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workplace, and conducts about 36,000 inspections per year.5 OSHA regulations may be found in CFR Title 29 Labor. Typical rules are related to signage, safety harnesses, safety guards, cages for ladders, lockout of equipment being inspected, exposure to chemicals, respirator systems, accident reporting and the like. Plant design engineers and operating staff are strongly affected by OSHA rules covering exposure to noise and to hazardous materials. As a broad generalization, where the EPA and OSHA cover the same situations, their technical requirements are the same. The EPA, however, is generally concerned with a plant’s impact outside of its boundaries, while OSHA is generally concerned with activities within the plant’s boundaries.

The Department of Transportation (DOT) The DOT is a very large government agency with a 2002 budget of approximately $58,400,000,000 dollars and 61,000 employees. It is responsible for the safety of interstate transportation, including aviation, highway and pipelines. See CFR Title 49 Transportation for its regulations. The DOT regulates, among other items, the design, maximum allowable filling densities, relief valves, loading and unloading of cylinders, portable tanks and tank cars. Requirements for transporting hazardous materials are detailed in 49 CFR 179. These include considerations of thermal protection, venting and safety relief, materials of construction and insulation. The DOT’s Office of Pipeline Safety has issued regulations pertaining to design, testing and operating the pipelines that transport liquids and gases throughout the United States. These may be found in 49 CFR Parts 186-199. The U.S. Coast Guard, which regulates various safety aspects of water-borne shipping, has been transferred in November 2002, together with the Transportation Security Administration, to the new Department of Homeland Security.

tandards Producers. Non-Governmental agencies have historically had a major role in developing standards. Many not-for-profit bodies have committees that focus on

detailed design, inspection, installation and operating requirements for rather narrow well-defined equipment, processes or situations in their specific sector. These bodies’ members frequently have experience and expertise not present in governmental agencies. Their standards are generally accepted since they follow the procedural requirements of the American National Standards Institute (ANSI)6; all affected parties may provide input and decisions are arrived at transparently by consensus. The following sample includes representative specialized major industrial standards-writing groups; there are hundreds of others.

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American Petroleum Institute (API) American Society of Heating, Refrigerating and Air-Conditioning Engineers,

Inc. (ASHRAE) American Society of Mechanical Engineers (ASME) ASTM International

(formerly American Society for Testing and Materials (ASTM) The Chlorine Institute Compressed Gas Association (CGA)

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National Association of Corrosion Engineers (NACE) National Fire Protection Association (NFPA) Petroleum Equipment Institute (PEI) Steel Tank Institute (STI) Underwriters Laboratories Inc. (UL)

The standards produced by these non-governmental agencies are not legal documents and have no legal standing until and unless adopted by governmental bodies. Many industrial standards are "incorporated by reference" in laws; they thus take on a legal status and become codes. For example use of NFPA 37 has become a legal requirement since 29 CFR 1910.110(b) (20) [OSHA requirements for appliances] (iv)(c) states

All commercial, industrial and agricultural appliances or equipment shall be installed in accordance with the requirements of …(c) Standard for the installation and use of Stationary Combustion Engines and Gas Turbines-NFPA 37-1970.

It is, as another example, very likely that an electrical system that does not conform to the NFPA 70 National Electric Code does not meet the requirements of State and Local ordinances and is thus illegal.

omponents of Standards and Codes. Although there are legal differences, for brevity, the terms "codes" and "standards" will be used interchangeably in what

follows. C They will contain the Effective Date and the Edition, presenting the date of adoption of the promulgating body. Individual codes are revised periodically to reflect new technological demands, newly available materials, systems or analytical capabilities, and changed consensus on appropriate requirements. Codes are now also being revised to reflect the preferred style of ISO. It is not unusual for the code-writing body to issue errata and/or clarifications. You must obtain and review them to help assure the safety of your project. Importantly, many jurisdictions, including OSHA and local building departments, require use of a particular edition, even though it is not the latest one. This may lead to conflicts or omission of provisions incorporated in the latest versions. As an example, the OSHA regulations for installing a stationary combustion engine or gas turbine discussed above require adherence to the provisions of the 1970 edition of NFPA 37; the current edition is that of 1998. All codes contain a Scope, which may be a few sentences or may be many paragraphs. For example, NFPA 30 (Flammable and Combustible Liquids Code) contains

1.1 Scope.

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1.1.1* This code shall apply to the storage, handling, and use of flammable and combustible liquids, including waste liquids, as herein defined and classified.

The Scope then continues with

1.1.2 This code shall not apply to the following: (1)* Any liquid that has a melting point equal to or greater than 100oF (37.7oC)… (2) Any liquefied gas or cryogenic liquid as defined in… Etc.

Scope thus defines both what is covered and what is specifically excluded. (The “*” refers to material included in Explanatory Material in an appendix that is not part of the requirements but is included only for informational purposes.)

Officials (authorities having jurisdiction) must have discretion to approve systems, methods or devices that are equivalent or superior to those prescribed in the code. They also need the discretion to impose more stringent requirements to meet special situations where appropriate. These are normally accommodated by an Equivalency provision found in many codes. Definitions are important for avoiding ambiguity, confusion and misuse of requirements caused by common usage and jargon that differs from one industrial sector to another, particularly where common words are used. For example, within NFPA 30 a Container and a Storage Tank are precisely distinguished from each other. A Container is defined as “Any vessel of 60 gal (227 L) or less capacity used for transporting or storing liquids” and a Storage Tank is defined as “Any vessel having a liquid capacity that exceeds 60 gal (227 L), is intended for fixed installation, and is not used for processing.” Atmospheric Tanks and Low-Pressure Tanks are, likewise, carefully defined in terms of the maximum internal design pressure. Process plant and utility power-plant designers and operators are likely to consider a boiler generating 200 psig steam to be a Low Pressure Boiler. In fact, a Low Pressure Boiler is defined in NFPA 31 (Standard for the Installation of Oil-Burning Equipment) as one for generating steam at pressures not in excess of 15 psig or for furnishing water at a maximum temperature of 250oF at a maximum gage pressure of 160 psi. One potential pitfall is that the same word may be defined one way in one code and another way in a different code. Definitions of two terms by OSHA and within NFPA 30 are as follows:

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TABLE 1 Comparison of Definitions

ITEM

OSHA 29 CFR 1926.64 (b)

NFPA 30 – 2000 Ed.

Atmospheric

Tank

…designed to operate at pressures from atmospheric through 0.5 psig.

…designed to operate at pressures from atmospheric through 1.0 psig … measured at the top of the tank.

Boiling Point

…the 10 percent point of a distillation performed in accordance with… ASTM D86-62.

…the 20 percent evaporated point of a distillation performed in accordance with ASTM D86…

The numerical differences are not trivial. They lead, for example, to different technical requirements for gasoline storage tanks. You absolutely must therefore always review the Definition of terms that is included in virtually all codes. The bulk of any code is its Requirements. These are most often prescriptive, having the form:

If the situation is “A”, then you must do (or not do) “B”

An example from 2.2.7.4.1 of NFPA 30: “Vent pipes that are provided for normal tank [in an aboveground vault] venting shall terminate outside and at least 12 ft (3.6 m) above ground level.” Less specific rules are occasionally encountered, often of the form:

If the situation is “C”, then you must consider “D.”

An example from 2.2.5.2.2 of NFPA 30 regarding emergency relief venting: “If unstable liquids are stored, the effects of heat or gas resulting from polymerization, decomposition, condensation, or self-reactivity shall be taken into account.” There is, however, no indication of how to take these effects into account. Codes often contain Appendices (or Annexes) that present explanatory material and/or recommended practices. An appendix may be part of the requirements, or may be included for informational purposes only and its contents not required. Additionally, codes may include a Referenced Publications section that lists all publications referred to in the requirements.

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sing Codes. Codes may be difficult to use for several reasons. Often the subject they cover is inherently complex.

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For example NFPA 31 (Standard for the Installation of Oil-Burning Equipment – 2001 Ed) is an example of an average code, consisting of 52 two-column pages of text, 19 tables and 15 diagrams. It applies to industrial-, commercial- and residential-type steam, hot water, or warm air heating plants; domestic-type range burners and space heaters; and portable oil-burning equipment, all accessory equipment and control systems, and all electrical wiring connected to oil-fired equipment. It also applies to the installation of oil storage and supply systems connected to oil-fired equipment and to multi-fuelled appliances in which fuel oil is one of the optional fuels. For this wide range of equipment, it presents requirements and prohibitions for fuels, air for combustion and ventilation, venting of flue gases, fuel oil tanks, piping systems and components, and installation. The International Boiler and Pressure Vessel Code of the ASME is a prime example of an extremely comprehensive and complex code, consisting of 11 sections in 30 volumes, and costing $7,900 for a printed copy of the complete set.7 It presents requirements for virtually all aspects of the materials of construction, design, fabrication, testing and installation of boilers and pressure vessels. A useful Expert System, The Code Counselor, is available that asks questions interactively, evaluates your answers and immediately produces a report containing the verbatim text of only the sections of various code documents that apply to your specific project.8

Sections of codes frequently refer to other sections of the same code or to a second code with or without specific sections being indicated. The second code may then refer to various sections of itself or additional codes. You may therefore to spend hours, days, months or years reviewing all mentioned requirements. This is, of course, impractical. At some point you must rely on your own judgement or that of more experienced individuals or perhaps outsiders such as a governmental agency’s staff member, the Help Desk offered by professional societies or reputable equipment vendors. A large amount of data such as physical and chemical properties, plant and equipment dimensions, and building characteristics may be required. Table 2 presents, as an example, a complete list of all of the liquid properties required for evaluating all of the requirements of NFPA 30. Many collections of specialized data are available in addition to those contained in traditional handbooks. For example, the NFPA publishes two documents9,10 containing properties related to fire protection and a tabulation of hazardous chemical reactions.11 The AIChE publishes an extensive collection of physical properties in hard copy and electronic format.12

Although values of all required properties can be obtained in advance of applying a code such as NFPA 30 to a specific project, the effort would most likely be needlessly time-

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consuming and costly, since not all of them are required in all cases. The pertinent ones depend on the situation being investigated.

TABLE 2 Physical Properties required by NFPA 30

API Gravity Boiling Point Boil-over prone? (Yes/No) Fire Point Flammable Limit – Lower Flammable Limit – Upper Flash Point Gel, thicken or solidify when heated? (Yes/No) Health Degree Hazard Rating Heat of Combustion Latent Heat of Vaporization (at Boiling Point) Melting Point Molecular Weight Rate of Burning Reactivity Degree Hazard Rating Specific Gravity Stable or Unstable? Vapor Pressure at 100 deg F Vapor Pressure Vs Temperature Viscosity Water-miscible? (Yes/No) Water-reactive? (Yes/No)

You may encounter errors and inconsistencies in tables and databases of physical properties. These are encountered frequently enough for the NFPA to have established a Physical and Chemical Data Consistency Advisory Committee to review published values of properties such as flash points and flammability limits and recommend changes where appropriate.

hich Safety-Related Codes are Used in the Chemical Processing Industry? A

recommeW lthough code applicability is project-specific, the following codes (and

nded practices) are commonly encountered. The hundreds of documents that

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specify chemical composition and physical properties of materials of construction, while obviously also important, have not been included. Similarly, neither building codes nor equipment testing standards nor standards of other countries have been included.

TABLE 3 Frequently Used Codes

Organization Number Code Title A S H R A E 15 Safety Standard for Refrigeration Systems – 2001 A N S I B31.1 Power Piping – 2001 A N S I B31.3 Process Piping – 2002 A N S I B31.4 Pipeline Transportation Systems for Liquid

Hydrocarbons and Other Liquids – 2001 A N S I B31.5 Refrigeration Piping and Heat Transfer Components –

2001 A N S I B31.8 Gas Transmission and Distribution Piping Systems –

2000 A P I API 620 Recommended Rules for the Design and Construction

of Large Welded, Low Pressure Storage Tanks – 2002 A P I API 650 Welded Steel Tanks for Oil Storage – 1998 A P I API 653 Tank Inspection, Repair, alteration and Reconstruction

– 2003 A P I RP-520 Sizing, Selection and Installation of Pressure Relieving

Devices in Refineries – 2000 ASME International Boiler and Pressure Vessel Code – 2001

Section VIII – Pressure Vessels Section X - FRP Pressure Vessels

N A C E RP 0169 Recommended Practice, Control of External Corrosion on Underground or Submerged Metallic Piping Systems – 2002

N A C E RP 0285 Recommended Practice, Corrosion Control of Underground Storage Tank Systems by Cathodic Protection – 2002

N F P A NFPA 30 Flammable and Combustible Liquids Code – 2002 N F P A NFPA 31 Standard for the Installation of Oil-Burning Equipment

– 2001 N F P A NFPA 37 Standard for the Installation and Use of Stationary

Combustion Engines and Gas Turbines – 1998 N F P A NFPA 54 National Fuel Gas Code – 1999

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N F P A NFPA 58 LP-Gas Code – 1998 N F P A NFPA 68 Guide for Venting of Deflagrations – 1998 N F P A NFPA 69 Standard on Explosion Prevention Systems – 1997 N F P A NFPA 70 National Electric Code – 2002 N F P A NFPA 85 Boiler and Combustion Systems Hazards Code – 2001 P E I RP100 Recommended Practices for Installation of

Underground Liquid Storage Systems – 2000 S T I F841.01 Standard for Dual Wall Underground Steel Storage

Tanks – 2001 U L UL 58 Standard for Steel Underground Tanks for Flammable

and Combustible Liquids – 1996 U L UL 142 Standard for Steel Aboveground Tanks for Flammable

and Combustible Liquids – 2002 U L UL 2080 Standard for Fire Resistant Tanks for Flammable and

Combustible Liquids – 2000 U L UL 2085 Standard for Protected Aboveground Tanks for

Flammable and Combustible Liquids – 1997 U L UL 2244 Standard for Aboveground Flammable Liquid Tank

Systems – 1999 U L UL 2245 Standard for Below-Grade Vaults for Flammable and

Combustible Liquids – 1999

The text of Federal and many State codes is very often available on their websites. Copies of documents produced by the non-governmental bodies are available from them either in print or electronic formats. Although the latter can usually be searched for key words or phrases using the popular word processing programs, non-experts may miss requirements since they often do not know what to search for. The Code Counselor, previously mentioned, avoids this problem by asking questions and evaluating your responses so that only relevant questions are asked, and all sections of the particular code that pertain to your project have been considered.8

Many associations such as the ASME and the NFPA offer seminars on using their codes. The best way to master a code is to join and actively participate in the committee responsible for its development and support. The association’s website or membership office will provide the appropriate contact information.

hich Codes Apply to My Project? Since there are usually many ways to carry out any process, a process flow sheet should always be developed as the first step.

This should show all process equipment and piping, with materials of construction, operating pressures, temperatures, flow rates, and amounts of materials stored in tanks or bins. Relief valves, vents and drains must also be included.

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As you prepare your process flowsheet, several aspects of facility design and operation are particularly noteworthy. Although not an absolute limitation, OSHA indicates (29 CFR 1910.119 App A) the threshold quantities for highly hazardous chemicals, toxics and reactives above which there is a potential for a catastrophic event. Many chemicals commonly used in the process industries are included, such as acetaldehyde, chlorine, ethylene oxide and methyl chloride. There are, moreover, absolute limits to the amounts of many chemicals that may be stored in buildings. For example 29 CFR 1910.103 Subpart H (Hazardous Material - Hydrogen) presents the requirements for storing hydrogen, including maximum quantities in various types of buildings. Section 7.5.13 of NFPA 31, as another example, limits the amount of fuel oil in buildings to 1375, 10000, 15000 or 50000 gallons depending on the building design. Section 7 of ASHRAE 15 restricts the quantity of refrigerants that may be kept in occupied spaces. There are many additional examples of quantity limitations. OSHA also defines legally permissible exposure levels to many chemicals. Those for benzene, for example, are detailed in 29 CFR 1910.1028. Exposure limits recommended for numerous chemicals by other groups are also available.13, 14, 15, 16

Certain safety design parameters are determined within codes. The minimum emergency relief venting flow rate from aboveground storage tanks subject to fires, for example, depends on tank dimensions, insulation, spray systems, drainage and dike arrangements and the stored liquid’s properties. The minimum venting rate for stable liquids can be calculated from section 2.2.5.2 of NFPA 30. More complex methods, required for liquids that are reactive, are available from the AIChE’s Design Institute for Emergency Relief Systems. Although you generally can select materials of construction based on convenience and economic considerations, there are limits. As examples: NFPA 30 prohibits use of certain metals on tanks storing Class IIIB liquids in diked areas; NFPA 37 requires that fuel piping to engines and gas turbines to be steel or other metal; ASME B31.3 (323.4.2) enumerates various metallurgy that is specifically unacceptable in process piping; ASHRAE 15 (9.1.2 & 9.1.3) enumerates various metallurgy that is specifically unacceptable for contact with specific refrigerants. There are many additional examples of materials limitations. Valuable information about the proper design and operation of many specific types of facilities is available from the not-for-profit trade groups. For example, the Compressed Gas Institute17 publishes guides for handling widely used gases such as acetylene, anhydrous ammonia, hydrogen and oxygen. Information about safely handling chlorine, hydrogen chloride, sodium- and potassium hydroxides and related compounds is available from The Chlorine Institute.18

In order to assess safety requirements, you will need to know, among other items:

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how various physical areas of your installation have been classified; these are defined in NFPA 70.

the fire classification of each flammable or combustible liquid in your project. These may possibly found in references 9 or 10, or may be calculated by the method presented in NFPA 30 or by the technique presented by the Code Counselor as a free public service.8

Importantly, materials listed in 29 CFR 1910.119 App. A are, by OSHA definition, “Highly Hazardous Chemicals.” If you handle one of these materials, although the “Applicability” section lists exemptions, you may be required develop a Process Safety Management Plan and review it every five years. This plan must include the electrical classification, and the design codes and standards employed (as well as provisions for confirming the mechanical integrity of equipment such as vessels, pumps, piping systems, relief and vent systems, and emergency shutdown systems.) Similarly, the EPA’s concern about chemical accident prevention has led to its General Duty Clause of §112(r)(1) of the Clean Air Act. A Risk Management Plan is required under 40 CFR 68 Subpart G for facilities that process regulated toxic or flammable substances (listed in 40 CFR 68.130) or, even if not listed, other extremely hazardous substances.

etting started. Although code applicability is quite project-specific, the following starting points have been helpful. It will be useful and usually cost-effective to

utilize the services of a professional reference librarian. They have been educated to use a wide range of sources to find information quickly and efficiently. Many have the background to assess the timeliness, relevance, completeness and accuracy of their findings.

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Locate any specific federal requirements related to the material you are processing or

storing. Search the U.S. Code of Federal Regulations at www.CFR.gov using key words or phrases that correspond to your product, process or device. Certainly include the OSHA List of Highly Hazardous Chemicals (29 CFR 1910.119 Appendix A.) and the EPA list of regulated toxic and flammable substance (40 CFR 68.130.) Three other useful governmental websites are www.DOT.gov, www.OSHA.gov and www.EPA.gov.

Search the website of the logical trade groups. For example, if your project involves handling flammable petroleum products it would be sensible to visit www.API.org for codes and standards related to petroleum equipment and processing, www.steeltank.com for information about requirements for steel tanks, and www.NFPA.org for information about fire protection.

If your project includes handling and storing flammable materials, always search the website of the National Fire Protection Association (www.NFPA.org.)

Contact appropriate trade groups. Many of them have help-desks supported by knowledgeable staffs.

Contact appropriate State and Local regulatory agencies such as those with responsibility for environmental protection, utility services such as water and electricity, and local building and fire departments. In many cases, the codes of States and Local agencies contain requirements above and beyond those required by

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national codes. Local authorities-having-jurisdiction often will also insist that you incorporate various devices or practices they have found to be helpful, even though they are not specifically required by any code.

Discuss your project with your insurance carrier. The larger companies that provide coverage for industrial facilities have knowledgeable staffs.

Discuss your project with equipment and raw material suppliers. They are likely to be familiar with codes that apply to their products. You may, however, want them to first execute a Confidentiality Agreement.

After you have developed a list of project-specific applicable codes, it is critical to have qualified competent engineers review it for completeness; experience and judgement are required for this.

our Responsibilities. When you review a situation for safety or, more narrowly, for compliance with a particular code, you have both legal and ethical responsibilities to

fulfill. Y We do work in a litigious society, so if you have been involved, even remotely, in a project that has experienced a loss of life, disabilities or economic losses, you should not be surprised to find yourself subpoenaed as a witness or even as a defendant. You will serve your employer and yourself best by bringing any design, testing, installation or operating deficiencies to the attention of your supervisor, and/or the project manager. If you are not satisfied with their response, you must go further. In fact, the National Society of Professional Engineers makes this explicit in its Code of Ethics for Engineers. Part II (Rules of Practice) 1.a states unambiguously that

If engineers’ judgement is overruled under circumstances that endanger life or property, they shall notify their employer or client and such other authority as may be appropriate.

As unpleasant as they are, resignation and/or contacting governmental officials are options that may be justified by the possibility that catastrophic situations will arise. Remember that, although you may be ostracized within your company, “whistle blower” statutes legally protect you. Once a deficiency is detected it is important to carefully and clearly document it together with the course of action you proposed, to whom you proposed it and on what date. If you foresee a life-threatening or major property-loss situation arising, think defensively and develop an “audit trail,” particularly if your advice is rejected. This may help with a proper resolution of the danger, or may be critical for establishing that you did everything you reasonably could to avoid a dangerous situation. A great many, probably most, corporations and managers will act in a responsible way with respect to clear-cut safety issues, as has been demonstrated by their having undertaken voluntary product recalls and implementing Responsible Care programs for vetting and tracking the use of their products.

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The country’s reaction to the behavior of some in the energy and communications fields who may have willingly wiped out their employees’ and shareholders’ lifetime savings for their own benefits is having some positive effects. Many managers who are under strong pressure to produce profits have absorbed lessons about importance of their personal and corporate reputations, about an open two-way street communication policy, and about dealing straightforwardly with bad news. As long as you have a basic understanding of codes that apply to your facility and operations, you will probably not be placed in a compromising position, and can have the satisfaction of contributing to the safety of your coworkers, your community and society-at-large.

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Abbreviations AIChE American Institute of Chemical Engineers,

New York, NY ANSI American National Standards Institute,

Washington, D.C. API American Petroleum Institute,

Washington, D.C. App Appendix ASHRAE American Society of Heating, Refrigerating and Air-Conditioning Engineers,

Atlanta, GA ASME American Society of Mechanical Engineers,

New York, N.Y. ASTM ASTM International (formerly the American Society for Testing and

Materials), Conshohocken, PA

CFR Code of Federal Regulations CGA Compressed Gas Association

Chantilly, VA DOT [U.S.] Department of Transportation EPA [U.S.] Environmental Protection Agency Gal U.S. gallon ISO International Organization for Standardization, Geneva, Switzerland L Liter NACE National Association of Corrosion Engineers,

Houston, TX NFPA National Fire Protection Association,

Quincy MA OSHA [U.S.] Occupational Safety and Health Administration

(part of the U.S. Department of Labor) PEI Petroleum Equipment Institute,

Tulsa, OK Psi Pounds per square inch Psig Pounds per square inch gauge STI Steel Tank Institute,

Lake Zurich, IL UL Underwriters Laboratories Inc.

Northbrook, IL

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Literature Cited

1. OSHA, Workplace Injuries and Illnesses in 2001, USDL 02-687 2. National Fire Protection Association, The U.S. Fire Problem Overview Report,

p. 156, Quincy, MA, 2001 3. International Organization for Standardization, website www.ISO.org, March

2003 4. EPA, website home page www.EPA.gov, March 2003 5. OSHA website www.OSHA.gov, March 2002 6. ANSI, Paper IC N2382, January 2002 7. ASME website, www.asme.org, March 2003 8. CodeLamp Corp., The Code Counselor, website www.codelamp.com, March

2003 9. National Fire Protection Association, NFPA 49, Hazardous Chemicals Data,

Quincy, MA, 1994 10. National Fire Protection Association, NFPA 325, Fire Hazard Properties of

Flammable Liquids, Gases, and Volatile Solids, Quincy, MA, 1994 11. National Fire Protection Association, NFPA 491, Hazardous Chemical

Reactions, Quincy, MA, 1997 12. AIChE project at the Thermodynamics Research Center of Texas A&M

University, ongoing project with several products available 13. American Conference of Government Industrial Hygienists, A Manual of

Recommended Practice, 19th Ed. Cincinnati, OH, 1986 14. American Industrial Hygiene Association, OSH-DB Occupational Safety and

Health Database, Continually updated, Fairfax, VA 15. National Institute of Occupational Safety and Health, A Manual of

Recommended Practice, 19th Ed. Cincinnati, OH, 1986 16. NRC (National Research Council,) Emergency and Continuous Exposure

Guidance Levels for Selected Airborne Contaminants, National Academy Press, Washington, D.C., 1991

17. The Compressed Gas Association, Chantilly, VA [website: www.cganet.com] 18. The Chlorine Institute, Rosslyn, VA [website:www.cl2.org]

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he Author. Dr. Herbert W. Cooper has over forty years of experience with environmental, economic and technological aspects of power production, hydrogen

production, steel mills, petrochemical production, oil refining and similar industrial facilities. He has been the president of Dynalytics Corp. since 1969; a company whose clients have included major engineering firms, equipment vendors, oil & chemical, and aerospace companies. Currently, he is the Chairman of CodeLamp Corp., a spin-off of Dynalytics, that has successfully integrated plant design experience and expert systems technology with the communications capabilities of the Internet to provide project-specific information about fire codes.

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He received his Bachelor and Masters degrees in Chemical Engineering from the City College of New York, and a Doctorate in Engineering Science (Chemical Engineering) from Columbia University. Dr. Cooper is a member of the American Institute of Chemical Engineers and the National Fire Protection Association; he is Chair of its Physical and Chemical Data Consistency Advisory Committee. Dr. Cooper may be reached at: Telephone (631 755 2112) ; E-mail info@codelamp.com.

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