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K2 Plays With Fire!...

K2ConceptsK2Concepts Posts: 12,321Administrator El Jefe
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  • kasdorfkasdorf Posts: 45Member ✭✭
    edited September 28
    Good to know Jim.
    I have been wanting to build a exhaust fan system on my tank at work same as the one I have on my home tank but the boss wanted me to use an explosion proof fan so it never got done due to the cost of that fan.
    I was not concerned about it at home but work is a different story and the boss had the say so I will send him this video.

  • K2ConceptsK2Concepts Posts: 12,321Administrator El Jefe
    I knew I was going to get some "Stupid is as stupid does" feedback...thank you interweb...
  • smedlinsmedlin Posts: 1,116Member, Business Ninja ✭✭✭✭

    Is that what you mean when you say an activator is hot?

    Ok, that made me laugh
  • CluelessClueless Posts: 38Member
    Hi,
    As a Chief Fire Safety Officer and OSHA Specialist and Senior Incident Investigator this video is priceless as evidence. Why I say that is that this is the type of testing that I would do to determine if this chemical was the initiating element of the fire, fueling of the fire etc during an investigation into a building or location fire.

    Now should anyone suffer a fire where the insurance company refuses to pay up due to incorrect storage of a chemical (they will find any excuse not to pay you back any of the monies you've deposited with them) and lay the blame on you stating / claiming negligence this video can be used to counter their statement which will send them straight back to look for the cause of the fire. Remember to read the fine print of all insurance contracts as there is always a clause that will stop payment should the root cause be negligence on the clients behalf.

    Bear in mind that the insurance company send out an investigator, therefore he is on their payroll and it is not within his interest to establish a root cause on your behalf. The Fire Depts are all professionals and are of the best trained and highly skilled investigators available. However, due to the enormous workload and backlog they are only going to seriously investigate should there be a loss of life or serious threatening explosion. In a common location / house fire with no loss of life or threatening explosion they will go with the insurance company's investigators report and will often counter sign having simply read the HAZMAT info and not doing a thorough test of the chem.

    I worked on the Coal Mines as the OSHA Manager and senior incident investigator for far to many years where I was often called upon to re-investigate claims of negligence by insurance companies and nine times out of ten we would have to take the case to court to prove bias by the insurance company and their appointed investigator.

    Guys the mining companies have the funds to take on the insurance companies, I certainly don't and I'm sure there's a lot of guys on the forum don't either.

    Jim, thanks for the video, it was fun but is priceless evidence.
  • K2ConceptsK2Concepts Posts: 12,321Administrator El Jefe
    Thank you @Clueless appreciate the write up...very insightful...
  • CluelessClueless Posts: 38Member
    @K2Concepts
    You are most welcome, if any of the members ever need any OSHA assistance or advice I am always available at no cost.
  • K2ConceptsK2Concepts Posts: 12,321Administrator El Jefe
    Clueless said:

    @K2Concepts
    You are most welcome, if any of the members ever need any OSHA assistance or advice I am always available at no cost.

    @Clueless Be careful...most members on here don't have a clue as to what OSHA mandates are...add to it they are self-employed?...can of worms...
  • CluelessClueless Posts: 38Member
    @K2Concepts
    hahahaha .... yup I'm hearing you .... and most people tend to run the moment I say OSHA .... hahahaha .... fortunately I come from the other side of the coin where most OSHA inspectors are out to throw around their weight I actually go out of my way to assist the guys in getting it right so a finger can be flipped at the bureaucrats. My record is six years with no lost time injuries and no subpoenas. So if I can assist or advise the guys I'm willing to help. Same as all the free advice and assistance I've received from you and the forum , bit of payback ;)
  • WileECoyoteWileECoyote Posts: 5,545Member, Moderator, Business Ninja El Moderator
  • CluelessClueless Posts: 38Member
    @WileECoyote
    hahahaha..... yup ..... :s
  • LibertymanLibertyman Posts: 709Member ✭✭✭
    Clueless said:

    @K2Concepts
    hahahaha .... yup I'm hearing you .... and most people tend to run the moment I say OSHA .... hahahaha .... fortunately I come from the other side of the coin where most OSHA inspectors are out to throw around their weight I actually go out of my way to assist the guys in getting it right so a finger can be flipped at the bureaucrats. My record is six years with no lost time injuries and no subpoenas. So if I can assist or advise the guys I'm willing to help. Same as all the free advice and assistance I've received from you and the forum , bit of payback ;)

    @Clueless what is the osha and fire code for paint booth clearance. is it 3 feet on all sides? What about a concrete wall? do you still have to keep that 3 feet minimum distance?
  • DeviousDipsDeviousDips Posts: 1,078Member ✭✭✭✭
    Does osha differ from country to country? I'm sure all countries have their own laws. It's probably different state to state. 
  • CluelessClueless Posts: 38Member
    @Libertyman @DeviousDips
    Yes the laws differ but mainly in the Section, i.e. the similar or same law in different countries or states will have a different chapter, paragraph and sub paragraph reference. The codes will also be similar or the same with the different references.

    Most countries have now aligned and fall under the I.S.O. (International Safety Organization) or the S.F.P.E. (Society of Fire Protection Engineers). All new fire protection systems and methods are shared between each member out SFPE and all new legislation and regulations are also shared. Not only is this a way of standardizing fire protection it also projects best practices in different types of fire or workplace safety situations.

    Yes the 3 foot requirement is still in place with a fire break wall required, however, this is not practical when working with chemicals, as heavier than air vapors are able to creep around corners and cover entire floor spaces which results in a continued At Risk Situation.

    It is also not practical for a small business to lay out huge amounts of monies on building concrete walls for a spray booth 6'x6' as in my case I am not able to do large or long parts yet so spending the monies on concrete walls etc would take away money that could be spent on purchasing better equipment and more stock. However we still carry the responsibility to practice Due Diligence, As in my case I have a really small tool shed that is constructed of a concrete floor and corrugated iron walls and roof next to one of the cottages on my property. I have lined the inside roof and walls with plastic sheets and added an extraction fan. the chemicals are stored in a vented cabinet outside protected from the weather. This is my fire and explosion best practice. It is in-expensive and practical.

    As long as you can prove Due Diligence and Best Practice the OSHA and Fire Inspectors will not be able to find fault with what is done. Remember all legislation states "Reasonably Practicable" in other words it has to be within reason and practical.

    Unfortunately most OSHA Inspectors run by The Book because they have no practical experience in all of the different tasks and it is often convenient to forget Due Diligence and Reasonably Practicable simply Because the Book Says So!

    One needs to asses the risk and take preventative measures that are Reasonably Practicable.

    Should you not be in a position to place a spray booth or chem store outside then separate the chems from other stored items preferably away from anything combustible and any possible ignition sorce like electric plug points etc. Any non combustible material can be used as a wall i.e. metal sheeting with metal frame etc. The required concrete wall is simply to contain a fire and prevent it from being able to spread. Again it is not reasonably practicable if you store as few chems as I do. As in my case a vented steel cabinet will suffice.

    Remember, Due Diligence, Reasonably Practicable, Asses the Risk and Mitigate.

    I know it's long winded, however I hope it helps.
  • WileECoyoteWileECoyote Posts: 5,545Member, Moderator, Business Ninja El Moderator
    @Libertyman the 3' requirement is for electrical only. NFPA is different. Our requirements said any "heat generating source must be 20' from any flammable storage or point of use"
  • CluelessClueless Posts: 38Member
    @WileECoyote @Libertyman
    Yes the 20' distance is mainly for flame work, cutting, grinding, welding etc. I'm pretty certain that there is no flame work taking place anywhere near the dipping / painting due to ruining the job. In a paint shop the greatest danger is electrical connections and supply points. As long as any small business practices Due Diligence within the boundaries of Reasonably Practicable you are in good standing.

    There is much I have not mentioned in my writing as I attempted to answer the question concerning the 3'.
  • WileECoyoteWileECoyote Posts: 5,545Member, Moderator, Business Ninja El Moderator
    @Clueless wouldn't a heating element for a small oven be considered a heat source? MANY of the shops around here are using them to bake parts and even powdercoating ovens are sources. We also used "Dehydrating ovens" for waterslide decals that were considered heat generating. On top of that, many of the shops in the US are sharing garage space, flame cutting, welding and grinding are VERY common in alot of these small shops. Flame treating is part of our process on most of the plastics we coat.

    The point is, the members of the forum need to be aware that these rules exist, and they exist for a reason. your average dipper may not think there is anything dangerous about open flame in his shop, or running a torpedo heater near the paintbooth to be able to paint in the cold weather... but if your inspector shows up... you WILL be shut down.
  • CluelessClueless Posts: 38Member
    @WileECoyote
    Yup, You are quite right, however a hot air source is not a heat source, Electric ovens unless they can reach a sudden / immediate flashpoint temp of the chem vapors is not a heat source, as creeping vapor will evaporate or dissipate before it reaches flashpoint on the way to the heat source. Check out the BP Texas Oil Refinery Explosion (https://en.wikipedia.org/wiki/Texas_City_Refinery_explosion) the fuel vapor had to traveled a long distance to find a flashpoint which was the alternator / generator on a small truck standing idling. To initiate a vapor fire a spark or open flame is required.

    I'm pretty sure the guys that are sharing a shop with other business concerns have a separation between them, Any form of barrier that will prevent a spark or flame getting directly onto any chem will not initiate a fire. Also all chemical storage needs to be vented, as each enterprise is individual the Risk needs to be assessed for each business, again reasonably practicable. Is it reasonable and practical to build a concrete wall when a separation wall or barrier already exists? Is the chem area vented? Is the heat source close to the stored chem? can a barrier between the two be placed to separate the heat source from the chem storage? Can the chems be moved to a better location within the business area? etc,etc.

    Yes everyone needs to be aware of the dangers and at risk situation, yet we also need to think as Jim says Outside of the Box. If it is reasonable and practical it will suffice. Yes the inspector will come around and inspect the area, however if you have taken practical measures to remove the risk and you are not in an at risk situation then the inspector has no reason to shut you down.

    Part of my duties was to do inspections on high risk areas and no matter what anyone did I would've been able to find a non compliance and shut the area down until compliance is met. In many cases I found non compliance to The Book, however once Reasonably Practicable had been proved and Due Diligence in place I was unable to fault this.

    The best practice is to remove the risk, if this cannot be done the risk needs to be mitigated. The easiest thing to do would be to invite someone from the Fire Dept down to visit and advise. In most countries this is a free service even here in Latin America, it'll prolly cost you a coffee and a snack of sorts.
  • LibertymanLibertyman Posts: 709Member ✭✭✭

    @Libertyman the 3' requirement is for electrical only. NFPA is different. Our requirements said any "heat generating source must be 20' from any flammable storage or point of use"

    Trevor so what you are saying, is to keep our yellow paint cabinets 20' or more away from a heat source, say like a bar joist gas heater (for heating the shop) is that correct. Does that also mean that any outlet must be 20' away from storage cabinets as well?

  • LibertymanLibertyman Posts: 709Member ✭✭✭
    @WileECoyote , @Clueless what is the requirement for fire suppression, (in general) for your paint booth (commercial grade booths)
    What happens in the event that our building doesn't have a sprinkler system. Can you get by with out one, or would you have to possibly go to a dry system, or something of that nature
  • CluelessClueless Posts: 38Member
    @Libertyman @WileECoyote

    @Libertyman the 3' requirement is for electrical only. NFPA is different. Our requirements said any "heat generating source must be 20' from any flammable storage or point of use"

    Trevor so what you are saying, is to keep our yellow paint cabinets 20' or more away from a heat source, say like a bar joist gas heater (for heating the shop) is that correct. Does that also mean that any outlet must be 20' away from storage cabinets as well?

    Hi Guys,
    The USA OSHA Regulation (below) states "Unless Separated by a Partition", as I said the 20' separation is the minimum requirement unless there is a partition in place. Therefore the 20' requirement only applies if there is no partition separating the two and the space is open between the two.

    This includes the exhaust as you do not want to create or promote vapour by warming the containers with flowing heated air in the area as this would create a risk of explosion.

    Best Practice if reasonable and practical would be to place a partition to separate work areas generating, spark, flame cutting or other heat source.

    Note that the regulation states partition and not partitioning wall, i.e. not necessarily a concrete or brick wall. therefore any non combustible material will suffice, thin metal sheeting etc. (corrugated iron roofing material would be more than sufficient)

    United States of America
    Occupational Safety and Health Administration
    1910.107(c)(2)

    Minimum separation. There shall be no open flame or spark producing equipment in any spraying area nor within 20 feet thereof, unless separated by a partition.

    Sprinckler System

    The USA OSHA Regulation (below) states "When Sprinklers are provided" therefore for the storage of your chems in a cabinet or storeroom a sprinkler system is not a regulation requirement. A fire extinguisher however is required at a minimum of ten feet away from and outside of the cabinet or store. (bear in mind certain chems combust or become combustible when they come into contact with water, burning chemical floating on water would also cause the fire to spread)

    Best practice would be to mount a CO2 or DCP (Dry Chemical Powder) extinguisher 10 feet (or as close a 10 feet as possible) away from the cabinet. (within line of sight and unobstructed)

    There is no mention of the Chemical Storage Cabinet fire protection minimum requirement, therefore I referred to the chemical storage room minimum requirement of a fire extinguisher at 10 feet even though the storage in a cabinet contains far less than the store. This will put you in good standing as you comply to fire protection for a greater capacity.

    United States of America
    Occupational Safety and Health Administration
    1926.152(d)
    "Fire control for flammable liquid storage."


    1926.152(d)(1)
    At least one portable fire extinguisher, having a rating of not less than 20-B units, shall be located outside of, but not more than 10 feet from, the door opening into any room used for storage of more than 60 gallons of flammable liquids.



  • CluelessClueless Posts: 38Member
    @Libertyman @WileECoyote

    Spray Booth Fire Protection
    There is no Regulation that I am aware of or could find concerning Sprinkler System inside of a Spray Booth, there are however regulations concerning electrical fittings, lighting and venting for a spray booth concerning fire protection.

    Best practice would be to have an extinguisher easily accessible and within easy reach of the spray booth, again I would go with a CO2 or DCP extinguisher.


  • WileECoyoteWileECoyote Posts: 5,545Member, Moderator, Business Ninja El Moderator
    @Libertyman the 20 foot rule does not apply to outlets, but yeah... I would keep that heater FAR away. Now your paint booth can be dry chem, or sprinklered, but that is going to depend on your local ordinance... But water based paint isn't flammable... Hint hint.
  • K2ConceptsK2Concepts Posts: 12,321Administrator El Jefe

    Clueless said:

    @K2Concepts
    hahahaha .... yup I'm hearing you .... and most people tend to run the moment I say OSHA .... hahahaha .... fortunately I come from the other side of the coin where most OSHA inspectors are out to throw around their weight I actually go out of my way to assist the guys in getting it right so a finger can be flipped at the bureaucrats. My record is six years with no lost time injuries and no subpoenas. So if I can assist or advise the guys I'm willing to help. Same as all the free advice and assistance I've received from you and the forum , bit of payback ;)

    @Clueless what is the osha and fire code for paint booth clearance. is it 3 feet on all sides? What about a concrete wall? do you still have to keep that 3 feet minimum distance?
    @Libertyman The IS an exception to the 3' clearance and that is a 1 hr fire rated wall...you can be as close to that as you need to be...but the fire inspector would like a couple of inches so you can clean out the space because of the chance of the dust igniting in the event of an earthquake...(weird but I guess it happens)...my son in law is the fire inspector for the county so he showed me these things before we went for inspection...so both my booths are tight to the walls at the rear of the booth...and on MY booth we had to add a layer of drywall to the bathroom to gain the 1 hour fire rating...that's why you have to know your codes...

    For flammable storage? A vented and self-closing cabinet solved all our storage issues...

    Sprinklers? Yes you will need a self-contained sprinkler system on each booth AND adequate fire extinguishers within the space. All electrical switches or lighting must be explosion proof and NEMA rated.

    Lastly? You may want to consider going with a heat pump instead of a gas fired furnace for heat...you will eliminate that possibility of open source flame...
  • LibertymanLibertyman Posts: 709Member ✭✭✭
    @Clueless , @K2Concepts, and @WileECoyote thanks for your input, greatly appreciated, having a shop on your property, verses jumping into a commercial leased building the rules change drastically . Iam trying to get loaded up with info the best I can, to do battle with the city. I do have a block wall that exceeds the 1hr rating, so yes I know I can be closer, but with the lights mounted on that side of the booth, I probably should keep enough room in case I have to service the fixtures. So Trevor, are you saying it would be up to the local code, whether they would require some sort of fire suppression with in the booth, correct?
    Iam confused, @Clueless said he couldn't find any requirements for sprinkled booths, anyone care to elaborate? A question for you Jim, did you have to file a form with the EPA for handling and disposing used toxic chemicals? My cabin neighbor runs a body shop and suggested I look into it, to see if we would be required to do so, like they have to. Oh what fun....
  • WileECoyoteWileECoyote Posts: 5,545Member, Moderator, Business Ninja El Moderator
    Some municipalities require ANY painting done by a business to be a fire hazard, so it needs to be done in an approved booth (that includes some sort of fire suppression). Some say there is a reasonable amount you can paint before you hit that point. 
  • MidOhioHydrographicsMidOhioHydrographics Posts: 8,607Member, Moderator, Business Ninja El Moderator
    Correct @Libertyman it was my City/County codes that required the most for the booth. Fire suppression, make up air, electrical near the opening, etc.
  • K2ConceptsK2Concepts Posts: 12,321Administrator El Jefe
    See, we were not required to have a makeup air...that expense would have been a nail in the coffin to be honest...even if I could have done most of it myself...
    Fire suppression can be hit and miss...some require and some do not if you are using less than a minimum amount of VOC products or your parts are less than a minimum size?
    Also, doors on a booth can play a part...seems that once you have doors on your booth then you are almost certainly going to need fire suppression...
    @Libertyman there are no hazardous chemicals in large amounts. The LAST thing you want is the EPA involved...your local Air Quality Management is trouble enough...the EPA is the absolute worse so if you can avoid them? Do so...
  • MidOhioHydrographicsMidOhioHydrographics Posts: 8,607Member, Moderator, Business Ninja El Moderator

    See, we were not required to have a makeup air...that expense would have been a nail in the coffin to be honest...even if I could have done most of it myself...

    So you are allowed to have your booths on exhausting a ton of air with no openings to allow inflow to make up for it? This is surprising to me, but don't start asking questions! LOL. I know it's difficult to open my shop door when we have the booth on and everything closed up. It seriously affects the efficiency of the booth and the amount of airflow over the user. May be an OSHA issue. Our manometer gauge goes sky high when the AMU isn't on. Looks like we have severely dirty filters in.

    We weren't required to have a make-up air furnace, but at minimum some way to let air into the building while the booth was on. I was told "Something like automatic louvers in the wall" would suffice. But then I'm drawing below-zero air into my shop, and that's no good either.
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