NFPA Journal - May/June 2017 - 46

BOSTON 2017

Conference & Expo

In November 2011, two contractors at the E. I. DuPont De
Nemours Co. located in Buffalo, New York, were performing
welding atop a 10,000-gallon slurry tank when hot sparks
ignited flammable vapors, causing an explosion that killed
one contractor and seriously injured another. The CSB's
final report and safety video, entitled "Hot Work: Hidden
Hazards," were released at an April 19, 2012, public meeting.
A primary cause of the blast was established by the CSB as
the failure of the company to require that the interior of
storage tanks-on which hot work was to be performed-be
monitored for flammable vapor. The CSB issued a recommendation urging DuPont to require monitoring inside and
around storage tanks prior to performing any hot work.

Hot work best practices
In February 2010, the CSB released "Seven Key Lessons to Prevent Worker Deaths during Hot Work in and Around Tanks,"
a safety bulletin that provided summaries and findings from
11 investigations. (It also notes that 60 fatalities occurred due
to hot work between 1990 and 2010.) In addition, the bulletin
provided seven key lessons aimed at preventing worker deaths
during hot work in and around storage tanks containing flammable materials. These include:
u Use Alternatives: Whenever possible, avoid hot work and
consider alternative methods.
u Analyze the Hazards: Prior to the initiation of hot work,
perform a hazard assessment that identifies the scope of the
work, potential hazards, and methods of hazard control.
u Monitor the Atmosphere: Conduct effective gas monitoring in the work area using a properly calibrated combustible
gas detector prior to and during hot work activities, even in
areas where a flammable atmosphere is not anticipated.
u Test the Area: In work areas where flammable liquids
and gases are stored or handled, drain and/or purge all
equipment and piping before hot work is conducted. When
welding on or in the vicinity of storage tanks and other containers, properly test and, if necessary, continuously monitor
all surrounding tanks or adjacent spaces-not just the tank
or container being worked on-for the presence of flammables and eliminate potential sources of flammables.
u Use Written Permits: Ensure that qualified personnel
familiar with the specific site hazards review and authorize
all hot work and issue permits specifically identifying the
work to be conducted and the required precautions.
u Train Thoroughly: Train personnel on hot work policies/
procedures, proper use and calibration of combustible gas
detectors, safety equipment, and job-specific hazards and
controls in a language understood by the workforce.
u Supervise Contractors: Provide safety supervision for
outside contractors conducting hot work. Inform contractors
about site-specific hazards, including the presence of flammable materials.
Between 2010 and 2013, the CSB reviewed 187 hot work incidents, 85 of which resulted in a fire or explosion while hot
work was being conducted on or near a tank or container.

46 | NFPA JOURNAL * M A Y / J U N E 2 0 1 7

These incidents resulted in 48 fatalities and 104 significant
injuries. Twenty-three percent of injuries and 42 percent of
fatalities involved contractor workers.
The CSB continues to see catastrophic incidents involving
hot work on tanks and containers containing flammable
vapors. Our past investigations into these incidents demonstrate a lack of awareness of the hazards of conducting hot
work on containers that in some cases had previously been
cleaned. The CSB recently deployed to two hot work incidents,
one at the Sunoco
Logistics LP terminal in
Nederland, Texas, and
CONFERENCE
SESSIONS
the other at the PCA
facility in DeRidder,
Dangers of Hot Work:
Louisiana. At Sunoco,
Key Lessons from
U.S. Chemical Safety
seven contractors were
Board Investigations
injured in a flash fire
Sunday, June 4,
10-11:30 a.m.
while conducting hot
Samuel Oyewole,
work on a pipeline on
U.S. Chemical
August 12, 2016. On
Safety and Hazard
Investigation Board
February 8, 2017, three
contractors were fatally
Hot Work Permit
Programs-
injured in an explosion
Mitigating Losses
at the PCA facility while
Sunday, June 4,
conducting hot work.
8:30-9:30 a.m.
Skip Donnell,
Due to the frequency
Liberty Mutual
and severity of hot
Insurance
work accidents, the CSB
has designated safe hot
work practices as one of the five elements of its newly developed Drivers of Critical Chemical Safety Change Program. The
CSB's Drivers of Critical Chemical Safety Change are based on
recommendations resulting from CSB investigations and studies. The goal of the program is to pursue implementation of
changes most likely to achieve important national-level safety
improvements.
The CSB has continued to advocate for best practices and
recommended improvements of consensus standards, specifications, recommended practices, technical reports, and
codes to address hot work activities. NFPA standards and
codes referenced by the CSB in its hot work investigations
include NFPA 51B, Fire Prevention During Welding, Cutting,
and Other Hot Work; NFPA 326, Safeguarding of Tanks and
Containers for Entry, Cleaning, or Repair; and NFPA 70E®,
Electrical Safety in the Workplace®. In addition, the CSB has
continued to push for the adoption of its recommendations
aimed at preventing hot work incidents by emphasizing the
need for increased hot work hazard awareness among workers and the need for stronger oversight and responsibility for
hot work activities.
SAMUEL A. OYEWOLE, PH.D., VIDISHA PARASRAM, MPH,
REEPA SHROFF, MS, AND JOHNNIE A. BANKS, CFEI, are chemical
incident investigators at the U.S. Chemical Safety and Hazard Investigation Board (CSB) in Washington, D.C. The CSB is an independent, scientific
federal agency whose mission is to independently investigate significant
chemical incidents and hazards and effectively advocate for implementation of the resulting recommendations to protect workers, the public, and
the environment.

Table of Contents for the Digital Edition of NFPA Journal - May/June 2017