OSHA Hazard Information Bulletins
October 7, 1996
| MEMORANDUM FOR: |
REGIONAL ADMINISTRATORS |
| FROM: |
STEPHEN MALLINGER
Acting Director
Directorate of Technical Support |
| SUBJECT: |
Hazard Information Bulletin(1) - Attaching an
Unguarded Blowtorch Regulator to a Portable
Propane Cylinder. |
________
FOOTNOTE(1) The Directorate of Technical support issues Hazard
Information Bulletins (HIBs) in accordance with OSHA Instruction CPL 2.65
to provide relevant information regarding unrecognized or misunderstood heath
hazards, inadequacies of materials, devices, techniques, and safety
engineering controls. HIBs are initiated based on information provided by
field staff, studies, reports, and concerns expressed by safety and health
professionals, employers, and the public. Information is compiled based on a
thorough evaluation of available facts and literature, in coordination with
appropriate parties. HIBs are used as an outreach tool for accident
prevention.
The Denver Regional Office brought to our attention a fatal accident
involving a 20-pound propane cylinder regulator that broke off when the
cylinder fell. The regulator was vulnerable to this kind of damage because
it protruded past the cylinder's protective collar. The use of unguarded
regulators on propane cylinders appears to be a common practice found on
construction sites.
A construction worker who did not receive job-related training entered a
manhole with a 20-pound Department of Transportation (DOT) approved propane
cylinder with a "Big Bertha" blowtorch assembly attached. While attempting to
melt ice in the manhole, the employee placed the cylinder on a step of a
portable ladder. The cylinder fell from the ladder and the regulator hit the
floor of the manhole. The regulator broke free from the cylinder's main
valve assembly, releasing gas and liquid propane into the manhole. The gas
in the manhole ignited, resulting in a fire that caused the worker's death.
A regulator that protrudes past a portable cylinder's protective collar (as
shown in the attached illustration) can create a hazardous condition. In
this instance, paragraph (h) of the Occupational Safety and Health
Administration (OSHA) standard 29 CFR 1926.153, which addresses liquefied
petroleum (LP) gas containers and equipment used inside of buildings and
structures, applies. The standard states that when operational requirements
make the use of cylinders outside of buildings and structures impractical
these cylinders maybe used inside of buildings and structures if paragraphs
(h)(2) through (11) of 29 CFR 1926.153 standards are followed. Title 29 CFR
1926.153(h)(4) states that when regulators are used the regulator must be
connected directly to the container valve and paragraph (h)(5) states that
valve on containers having a water capacity greater than 50-pounds (normal
20-pounds LP-gas capacity) shall be protected from damage while in use or
storage. It should be noted that the pertinent provision for using this
equipment installed outside (29 CFR 1926.153(g)) requires that
"Containers shall be upright upon firm foundations or otherwise firmly
secured". In this instance, the cylinder was not secured nor on a firm
foundation, although it was used "inside" (within a confined space). It is
recognized that the incident described above happened at a construction site.
If a similar incident had occurred at a general industry worksite, 29 CFR
1910.110(c)(5)(a) through (l) would be applicable. Title 29 CFR
1910.110(c)(5)(d) specifically requires that valves on such containers shall
be protected.
Recommendations for use by employees and employers involved in similar
operations should include the following:
a. The employee and supervisor should be given training on the
recognized and associated hazards for the work that is to be
performed.
b. Training on what equipment is needed for the job and how to use
this equipment.
c. Supervisors should determine that employees are using properly
assigned equipment.
d. Critical parts of equipment shall be protected from
danger.
In addition, 20-pound LP-gas cylinders like the one illustrated on
attachment one, are addressed under the National Fire Protection
Association's (NFPA's) "Standard for the Storage and Handling of Liquefied
Petroleum Gases," 58-1995 section 2-2.4.1 "Portable Containers Appurtenance
Physical Damage Protection". NFPA recommends that such cylinders incorporate
protection against physical damage to appurtenances and immediate connections
to those while in transit, storage, while being moved into position for use
and when in use, except in permanent residential and commercial
installations. Section 2-3.7(b) states that valves, regulators, gauges, and
other container appurtenances shall be protected against physical damage.
NFPA 58-1995 recommendations for the safe use of cylinders of this type
include:
a. Recessing connections into the container so that valves will
not be struck if the container is dropped on a flat surface.
b. Providing a ventilation cap or collar designed to permit
adequate pressure relief valve discharge and capable of withstanding a blow
from any direction equivalent to that of a 30-lb.(14-kg) weight dropped 4
ft.(1.2 m). The standard also requires that the construction of the cap
collar must be such that the force of a blow will not be transmitted to the
valve. In addition, collars must be designed so they do not interfere with
the free operation of the cylinder valve.
c. All persons employed in handling LP-gas shall be trained in
proper handling and operating procedures. Such training shall be documented
(paragraph 1.5 of NFPA 58-1995).
d. DOT cylinder specification containers be installed only above
ground, and shall be set upon a firm foundation, or otherwise firmly secured
(paragraph 3-2.4.1).
OSHA compliance officers and consultation personnel, as well as employers,
should be aware that the hazardous condition described above is likely to be
found at construction sites. Additionally, they should be aware of the
recommended procedures for eliminating this hazard.
Please distribute this bulletin to all Area Offices, State Plan States,
Consultation Projects, and appropriate local labor and industrial
associations. Copies of this HIB may be used for outreach purposes.
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