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So I wanted to come back a little bit to propane now.
If propane is being used as the fuel gas for welding and cutting then our oxy-fuel rules
apply.
However, where we oftentimes come across propane is not with oxy-fuel - it's powering a forklift,
or powering a heater on a construction site, a salamander.
So Oregon OSHA has a separate rule governing propane when used outside of oxy-fuel, but
there are some important points that you wanted to cover when it comes to propane and propane
cylinders.
It's important to know that propane is a product that's heavier than air, number one.
And leaks of propane can settle low.
It's important that they're doing leak checking on propane.
Propane has an odor, and by the way oxygen does not have an odor.
That's the one product oh I've had someone say to me "Oh I'll smell the product if it's
leaking."
No, not with oxygen you won't, I'm sorry.
Acetylene has an odor to it, propane has an odor to it, and you would notice an odor with
a with a fairly consistent leak in a cylinder.
But things to remember with propane that are in and out of the fuel gas rule, are amounts
of propane that can be stored inside a building: only 300 pounds of propane.
Whether the cylinders are full or empty it counts as a full cylinder.
So the cylinders that are not on forklifts, not in use, they need to make sure they're
not exceeding that amount of weight.
So if you have 33-pound propane cylinders you just got to do the math to know when you
exceed 300.
The next thing to mention is that propane cylinders, when they're refilled can only
be refilled if they're in current, what we call, test state.
A propane cylinder when it's manufactured is good for 12 years from date of manufacture
that's stamped on the collar.
Many times, a propane cylinder it'll have a collar above the cylinder whereas we have
markings stamped on the high pressure cylinders right on the shoulder of the cylinder.
The propane cylinder will have it up on the collar many times.
And those markings will depict the manufacturer the serial number, the DOT number of the cylinder,
and also the year of manufacture.
So 12 years it's good.
After 12 years, every five years that seller has to go through a visual (minimally a visual)
re-qualification process by an approved facility that is allowed to do that inspection.
And then they will put what's called a RIN number - RIN - identification number on the
cylinder which tells you it's been done.
If when you inspect that propane cylinder it's not there, that cylinder never should
have been refilled.
And there's some questions to ask: was it refilled?
how recently?
etc. to show that they refilled it, the owner of the cylinder had it refilled even if they
take it to a gas station and have it refilled there, sometimes they'll do it on their own
site refilling on site.
So that must be current that RIN number and that could be an alleged violation.
And by the way, those rules... ....you'll find that rule in the propane rule
Division 2 for liquefied petroleum gas also, if you are going to be addressing a propane
cylinder used on a forklift, we have a rule in the forklift rules that refers to NFPA,
Yeah, the NFPA 58 standard. 58 standard. And it's an older year on that rule, but it'll talk
about that. And that's where you draw your alleged violation from is the vertical
rules on the propane for forklifts. Right. Because it's outside of oxy-fuel. Right.
Of course, what we talked about so far, no smoking obviously! Propane is a heavy
gas it's flammable. No open flame, no source of ignition around propane. So when you
walk in the plant, you're walking around, you see that forklift go humming by you
and he's got that cigarette sticking out of his whatever, uh we don't worry about whether
Marlboro or not or a camel. What we're concerned about is it's an open flame
right in and around propane. The other thing that's very important in propane
and we'll talk about it in more detail over at a forklift here we have, but it is the mounting
and positioning of a forklift cylinder on a forklift and we'll show that here
shortly. Let's describe what Tom is talking about here. Please notice the pressure
relief valve on this cylinder, it's near the 12 or 1 pm position and has a blue rain cap
on it. And as you can see at the bottom, when the positioning pin is aligned with the hole
in the collar this ensures the relief valve is in the proper position and in direct communication
with the vapor space inside that cylinder. This situation was discovered during an Oregon
OSHA inspection. This cylinder was improperly positioned due to a shortened fuel hose. You'll
notice the positioning pin is not aligned with the hole in the collar resulting in the
pressure relief valve not being in the proper 12 or 1 pm position. This can be a dangerous
situation as the relief valve would not operate correctly if in communication with the liquid
and not the vapor space of the cylinder. This shows the cylinder not engaged with the positioning
pin. The purpose of the positioning pin is to ensure the pressure relief valve is in
direct communication with the vapor space. The relief valve should be near the 12 o'clock
position and equipped with a rain cap. We also, I want to make sure I share this with everyone
when I'm at a site doing inspection and they fill their own. they might have an on-site
500 gallon tank with propane.
I want to make sure that they train everybody the same. I want to... we don't have a rule for
that per se, but it doesn't mean you don't have a hazard letter. And through asking the
right questions how are they filling the propane cylinders? Does everybody... when you do your
interviews, are they all doing... have them describe to you how they do it. From the point of shutdown
of the forklift, to hooking it up and everything, to see that everyone's consistent. I always
recommend they have a set of filling instructions, they laminate those instructions, they hang
them at the bulk tank. They're available there for the operator who might be trained by somebody
five years ago to refresh their themselves in the proper procedure in the filling process
of that propane cylinder. I also have my own suggestions when you go out to an AM/PM
a gas station kind of thing, (I'm not advertising for AM/PM by the way) where they fill propane
cylinders on site. You'll find many times there the propane tank was put in by a company
that now doesn't currently supply them because because that product pricing changes quite
frequently with it and they change suppliers of propane. But training - how are
those employees, which are many times high turnover rate employees, right that are they
all getting trained and all getting trained appropriately? That's very important to look
at. Also looking at PPE - are they protecting their eyes? Their hands? Because propane will
not cause the same burns of refrigerated liquid cylinder will, as severe. But it's still a burn.
And if it gets on the in the eye, that burn could be a serious burn compared to just an
ouch feeling that I would definitely get in redness from a burn from propane on my skin.
So it's important to be wearing the right personal protected equipment. And then also
at the fill stations you want to make sure again, there's fill instructions there, the
PPE is there, they don't let customers hang around the station, and keep smoking away to
at least 20 feet. And also the canopies I see are built around the the various fill
areas at these different facilities are low and they have very sharp edges and I had
an issue with a potential serious cut hazard to an employee because they would duck out
the side of the area and go under the canopy and could strike their head and get a serious
cut that would result in stitches. So those are things to look for. As we close let's review
a few other important factors relating to propane. Bulk propane tanks must have a legible
marking, usually a data plate like you see in the upper right, listing important information
about the tank. And depending on its size, it must be properly set back from buildings as
you see in table H-23. These distances from buildings do not apply to DOT cylinders. This
is an example of a bulk tank located too close to a building. One reason for the proper spacing
of tanks, is due to ensuring an adequate distance when removing the liquid propane. The chemical
safety board's investigation of a tragedy involving the process of removing liquid propane
can be viewed at their website please look for "Half an Hour to Tragedy" in their video
room. Propane cylinders must be secure and set on firm and dry foundations. The 2 pictures
you see at the top show the corrosion that formed on a cylinder that was sitting on bark dust.
Several years ago, the industry installed overfilling prevention devices, or OPDs, on
all 4 - 40-pound propane cylinders used for vapor service. A good example of this
is the 20-pound cylinder for propane barbecue grills. These must be equipped with OPDs, and
you'll know it by the triangular shaped hand wheel at the service valve. Carbon monoxide
can be a deadly byproduct of poorly running engines fueled by propane. Please be sure any
internal combustion engines fueled by propane are regularly inspected and serviced.
This fatality investigation report describes an Oregon OSHA investigation in Redmond, Oregon.
When an employee was overcome by carbon monoxide when running this propane-powered floor buffer.
And lastly, it was a prior version of the National Fire Protection Association's liquefied petroleum
gas code NFPA 58 Standard that OSHA based its current standard on. It is recommended to also follow
the most current NFPA 58 Standard for the safe handling and use of propane. Thank you.