Propane and PSM

June 9th, 2015 | ,

Propane

Question: I am considering installing a propane tank at my facility, will it be subject to the requirements of RMP and PSM?

Answer: Assuming that the propane tank will be used for forklift fuel, you are not required to comply with the requirements of RMP, PSM, or CalARP because of the following exemptions/exclusions:


Title 40 CFR §68.126 A flammable substance listed in Tables 3 and 4 of §68.130 is nevertheless excluded from all provisions of this
part when the substance is used as a fuel or held for sale as a fuel at a retail facility.

Title 29 CFR §1910.119(a)(ii)(A) Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part of a process containing another highly hazardous chemical covered by this standard;


Although exempt from the requirements of RMP, PSM, and CalARP, the propane must be included on all hazardous material inventory reports (e.g. Hazardous Materials Business Plan in California) and employees will be required to be trained for safe handling in accordance with HazCom requirements. Furthermore, the propane tank will be subject to OSHA and EPA’s general duty clause which requires that “each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees”

So what are some of the recognized hazards that you should be aware of? Here is a quick overview of select requirements in the 2015 International Fire Code:

1. Impact Protection – The tank will need to be protected from accidental impact. Bollards are the most common type of engineering control used in this regard. Here are the 2015 IFC requirements for Impact Protection:

2015 IFC §312 Vehicle Impact Protection
2015 IFC §312.1 General. Vehicle impact protection required by this code shall be provided by posts that comply with Section 312.2 or by other approved physical barriers that comply with Section 312.3.
2015 IFC §312.2
Guard posts shall comply with all of the following requirements:
  1. Constructed of steel not less than 4 inches (102 mm) in diameter and concrete filled.
  2. Spaced not more than 4 feet (1219 mm) between posts on center.
  3. Set not less than 3 feet (914 mm) deep in a concrete footing of not less than a 15-inch (381 mm) diameter.
  4. Set with the top of the posts not less than 3 feet (914 mm) above ground.
  5. Located not less than 3 feet (914 mm) from the protected object.

2015 IFC §312.3 Other barriers. Barriers, other than posts specified in Section 312.2, that are designed to resist, deflect or visually deter vehicular impact commensurate with an anticipated impact scenario shall be permitted where approved.

If you are interested in learning more about impact protection, we’ve written about it here.

2. Tank Location and Placement – Regarding tank location and placement, here is a useful code snippet and table to refer to.
2015 IFC §6104.3 Container location. LP-gas containers shall be located with respect to buildings, public ways and lot lines of adjoining property that can be built upon, in accordance with Table 6104.3.

Table 6104.3

3. Safety Precautions and Devices –  The following safety precautions must be considered and implemented as applicable:
2015 IFC §6107.1 Safety devices. Safety devices on LP-gas containers, equipment and systems shall not be tampered with or made ineffective.
 
2015 IFC §6107.2 Smoking and other sources of ignition. “No Smoking” signs complying with Section 310 shall be posted where required by the fire code official. Smoking within 25 feet (7620 mm) of a point of transfer, while filling operations are in progress at LP-gas containers or vehicles, shall be prohibited. Control of other sources of ignition shall comply with Chapter 3 of this code and Section 6.22 of NFPA 58.
No smoking
2015 IFC §6107.3 Clearance to combustibles. Weeds, grass, brush, trash and other combustible materials shall be kept not less than 10 feet (3048 mm) from LP-gas tanks or containers.

2 responses to “Propane and PSM”

  1. Melanie Foster says:

    500 gallon propane tank placed by AmeriGas at a commercial building location. What are the requirements for bollards and what are the fines and fees for non compliance? Plumas county in CA

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