Seal offs in Class 1, Div. 2 areas.

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bandylb18

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Currently working in Lea County, NM near Jal, NM
I'm inspecting electrical/instrumentation on eight crude oil truck unloading stations (Class 1, Div 2 areas). Station skids are all supplied with seal offs, properly installed. Commissioning is complete for two skids that are the first to be used in unloading product. Seals are not poured but owner is proceeding with unloading of 50 tanker trucks claiming it is part of the commissioning process. Is this in violation of Federal Regs? If so, which one(s)? I'm not certain where to begin in looking at CFRs.
 
bandylb18 said:
I'm inspecting electrical/instrumentation on eight crude oil truck unloading stations (Class 1, Div 2 areas). Station skids are all supplied with seal offs, properly installed. Commissioning is complete for two skids that are the first to be used in unloading product. Seals are not poured but owner is proceeding with unloading of 50 tanker trucks claiming it is part of the commissioning process. Is this in violation of Federal Regs? If so, which one(s)? I'm not certain where to begin in looking at CFRs.
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I don't see how being part of commissioning would make any difference. OSHA requires that the employer provide a safe work place. It might be possible for the employer to come up with an alternate means of providing an equivalent level of safety without pouring the seals. Or it might be that without the rest of the equipment in place there is no hazard. Seems to me this would require a hot work permit. What does the permit say?

What is the thinking on holding off on pouring the seals?
 
I believe this type of short term activity can be allowed with sniffing the area as a pre-requisite for the hot-work permit. Of course it is a spot check only, ask them to do it at least twice a shift (the hot work permit is only good for 6 hours). Otherwise defer to the AHJ. Or is that you?
 
We typically do the I/O check out and things like that before pouring the seals, but the check out would involve "water runs" and not any actual product.
 
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