CORROSION RATES AND INSPECTION INTERVALS

PIPING INSPECTION CODE: IN-SERVICE INSPECTION, RATING, REPAIR, AND ALTERATION OF PIPING SYSTEMS

CORROSION RATES AND INSPECTION INTERVALS

Oleh : Bayu Nurwinanto

CMLS (Condition monitoring location)

General

CMLs are specific areas along the piping circuit where inspections are to be made. The nature of the CML varies according to its location in the piping system. The selection of CMLs shall consider the potential for localized corrosion and service-specific corrosion as described in API 574 and API 571. Examples of different types of CMLS include locations for thickness measurement, locations for stress cracking examinations, locations for CUI and locations for high temperature hydrogen attack examinations.

CML Monitoring

Each piping system shall be monitored at CMLs. Piping circuits with high potential consequences of failure should occur and those subject to higher corrosion rates or localized corrosion will normally have more CMLs and be monitored more frequently. CMLs should be distributed appropriately throughout each piping circuit. CMLs may be eliminated or the number reduced under certain circumstances, such as olefin plant cold side piping, anhydrous ammonia piping, clean noncorrosive hydrocarbon product, or high-alloy piping for product purity. In circumstances where CMLS will be substantially reduced or eliminated, persons knowledgeable in corrosion should be consulted.

The minimum thickness at each CML can be located by ultrasonic scanning or radiography. Electromagnetic techniques also can be used to identify thin areas that may then be measured by UT or radiography. When accomplished with UT, scanning consists of taking several thickness measurements at the CML searching for localized thinning. The thinnest reading or an average of several measurement readings taken within the area of a examination point shall be recorded and used to calculate corrosion rates, remaining life.

Where appropriate, thickness measurements should include measurements at each of the four quadrants on pipe and fittings, with special attention to the inside and outside radius of elbows and tees where corrosion/erosion could increase corrosion rates. As a minimum, the thinnest reading and its location shall be recorded. The rate of corrosion/ damage shall be determined from successive measurements and the next inspection interval appropriately established. Corrosion rates, the remaining life and next inspection intervals should be calculated to determine the limiting component of each piping circuit.

CMLS should be established for areas with continuing CUI (Corrosion under insulation, including stress corrosion cracking under insulation), corrosion at S/A interfaces, or other locations of potential localized corrosion as well as for general, uniform corrosion.

CMLS should be marked on inspection drawings and on the piping system to allow repetitive measurements at the same CMLS. This recording procedure provides data for more accurate corrosion rate determination. The rate of corrosion/damage shall be determined from successive measurements and the next inspection interval appropriately established based on the remaining life or RBI (risk-based inspection) analysis.

CML Selection

In selecting or adjusting the number and locations of CMLS, the inspector should take into account the patterns of corrosion that would be expected and have been experienced in the process unit. A decision on the type, number and location of the CMLS should consider results from previous inspections, the patterns of corrosion and damage that are expected and the potential consequence of loss of containment. CMLS should be distributed appropriately over the piping system to provide adequate monitoring coverage of major components and nozzles. Thickness measurements at CMLS are intended to establish general and localized corrosion rates in different sections of the piping circuits. A minimal number of CMLS are acceptable when the established corrosion rate is low and the corrosion is not localized.

A number of corrosion processes common to refining and petrochemical units are relatively uniform in nature, resulting in a fairly constant rate of pipe wall reduction independent of location within the piping circuit, either axially or circumferentially. Examples of such corrosion phenomena include high-temperature sulfur corrosion and sour water corrosion (provided velocities are not so high as to cause local corrosion/erosion of elbows, tees, and other similar items). In these situations, the number of CMLS required to monitor a circuit will be fewer than those required to monitor circuits subject to more localized metal loss. In theory, a circuit subject to perfectly uniform corrosion could be adequately monitored with a single CML. In reality, corrosion is never truly uniform and in fact may be quite localized, so additional CMLS may be required. Inspectors must use their knowledge (and that of others) of the process unit to optimize the CML selection for each circuit, balancing the effort of collecting the data with the benefits provided by the data.

More CMLs (Condition monitoring location) should be selected for piping systems with any of the following characteristics : 

1. higher potential for creating a safety or environmental emergency in the event of a leak.
2. higher expected or experienced corrosion rates.
3. higher potential for localized corrosion.
4. more complexity in terms of fittings, branches, deadlegs, injection points, and other similar items.
5. higher potential for CUI (corrosion under insulation, including stress corrosion cracking under insulation).

Fewer CMLS can be selected for piping systems with any of the following three characteristics : 

1. low potential for creating a safety or environmental emergency in the event of a leak.
2. relatively noncorrosive piping systems.
3. long, straight-run piping systems.

CMLS can be eliminated for piping systems with any of the following characteristics :

1. extremely low potential for creating a safety or environmental emergency in the event of a leak.
2. noncorrosive systems, as demonstrated by history or similar service; and
3. systems not subject to changes that could cause corrosion as demonstrated by history and/or periodic reviews.

Every CML should have at least one or more examination points identified. Examples include :

1. locations marked on un-insulated pipe using paint stencils, metal stencils, or stickers.
2. holes cut in the insulation and plugged with covers.
3. temporary insulation covers for fittings nozzles, etc.
4. isometrics or documents showing CMLS.
5. radio frequency identification devices (RFID). 

Careful identification of CMLS and examination points are necessary to enhance the accuracy and repeatability of the data.

Corrosion specialists should be consulted about the appropriate placement and number of CMLs for piping systemssusceptible to localized corrosion or cracking, or in circumstances where CMLs will be substantially reduced or eliminated.

Inspection Intervals 

If RBI ( risk-based inspection)  is not being used, the interval between piping inspections shall be established and maintained using the following criteria : 

1. corrosion rate and remaining life calculations.
2. piping service classification.
3. applicable jurisdictional requirements.
4. judgment of the inspector, the piping engineer, the piping engineer supervisor, or a materials specialist, based on operating conditions, previous inspection history, current inspection results, and conditions that may warrant supplemental inspections. 

The owner/user or the inspector shall establish inspection intervals for thickness measurements and external visual inspections and, where applicable, for internal and supplemental inspections.

Thickness measurements should be scheduled at intervals that do not exceed the lesser of one half the remaining life determined from corrosion rates or the maximum intervals recommended in Table. Shorter intervals may be appropriate under certain circumstances. Prior to using Table, corrosion rates shall be calculated.

Table contains recommended maximum inspection intervals for Classes 1, 2 and 3 of piping services, as well as recommended intervals for injection points and S/A interfaces. Maximum intervals for Class 4 piping are left to the determination of the owner/user depending upon reliability and business needs.

The inspection interval shall be reviewed and adjusted as necessary after each inspection or significant change in operating conditions. General corrosion, localized corrosion, pitting, environmental cracking, and other applicable forms of deterioration mentioned in Section 5 shall be considered when establishing the various inspection intervals.

CUI (corrosion under insulation, including stress corrosion cracking under insulation) Inspection.

Inspection for CUI shall be considered for externally-insulated piping in areas or temperature ranges that are susceptible to CUI. CUI inspections may be conducted as part of the external inspection. If CUI damage is found during spot checks, the inspector should inspect other susceptible areas on the equipment.

Although external insulation may appear to be in good condition, CUI damage may still be occurring. CUI inspection may require removal of some or all insulation. If external coverings are in good condition and there is no reason to suspect damage behind them, it is not necessary to remove them for inspection of the equipment. CUI damage is often quite insidious in that it can occur in areas where it seems unlikely.

Considerations for insulation removal are not limited to but include :

1. history of CUI for the specific piping system or comparable piping systems.
2. visual condition of the external covering and insulation.
3. evidence of fluid leakage (e.g. stains or vapors).
4. whether the piping systems are in intermittent service.
5. condition/age of the external coating, if known.
6. evidence of areas with wet insulation.
7. the type of insulation used and whether that insulation is known to absorb and hold water.

Piping Service Classes 

General

All process piping systems shall be categorized into different piping classes. Such a classification system allows extra inspection efforts to be focused on piping systems that may have the highest potential consequences if failure or loss of containment should occur. In general, the higher classified systems require more extensive inspection at shorter intervals in order to affirm their integrity for continued safe operation. Classifications should be based on potential safety and environmental effects should a leak occur.

Owner/users shall maintain a record of process piping fluids handled, including their classifications. API 750 and NFPA 704 provide information that may be helpful in classifying piping systems according to the potential hazards of the process fluids they contain.

Class 1

Services with the highest potential of resulting in an immediate emergency if a leak were to occur are in Class 1. Such an emergency may be safety or environmental in nature. Examples of Class 1 piping include, but are not necessarily limited to those containing the following.

• Flammable services that can autorefrigerate and lead to brittle fracture.
• Pressurized services that can rapidly vaporize during release, creating vapors that can collect and form an explosive mixture, such as C2, C3, and C4 streams. Fluids that can rapidly vaporize are those with atmospheric boiling temperatures below 50 °F (10 °C) or where the atmospheric boiling point is below the operating temperature (typically a concern with high-temperature services)
• Hydrogen sulfide (greater than 3 % weight) in a gaseous stream.
• Anhydrous hydrogen chloride.
• Hydrofluoric acid.
• Piping over or adjacent to water and piping over public throughways (refer to Department of Transportation and U.S. Coast Guard regulations for inspection of over water piping).
• Flammable services operating above their auto-ignition temperature. 

Class 2

Services not included in other classes are in Class 2. This classification includes the majority of unit process piping  and selected off-site piping. Typical examples of these services include but are not necessarily limited to those containing the following :

• on-site hydrocarbons that will slowly vaporize during release such as those operating below the flash point.
• hydrogen, fuel gas, and natural gas.
• on-site strong acids and caustics. 

Class 3

Services that are flammable but do not significantly vaporize when they leak and are not located in high-activity areas are in Class 3. Services that are potentially harmful to human tissue but are located in remote areas may be included in this class. Examples of Class 3 service include but are not necessarily limited to those containing the following :

• on-site hydrocarbons that will not significantly vaporize during release such as those operating below the flash point.
• distillate and product lines to and from storage and loading.
• tank farm piping.
• off-site acids and caustics. 

Class 4

Services that are essentially nonflammable and nontoxic are in Class 4, as are most utility services. Inspection of Class 4 piping is optional and usually based on reliability needs and business impacts as opposed to safety or environmental impact. Examples of Class 4 service include, but are not necessarily limited to those containing the following :

• steam and steam condensate.
• air.
• nitrogen.
• water, including boiler feed water, stripped sour water.
• lube oil, seal oil.
• ASME B31.3, Category D services.
• plumbing and sewers.

Assessment of Inspection Findings 

Pressure containing components found to have degradation that could affect their load carrying capability [pressure loads and other applicable loads (e.g. weight, wind, etc., per API 579-1/ASME FFS-1)] shall be evaluated for continued service. Fitness-For-Service techniques, such as those documented in API 579-1/ASME FFS-1, Second Edition, may be used for this evaluation. The Fitness-For-Service techniques used shall be applicable to the specific degradation observed. The following techniques may be used as applicable.

To evaluate metal loss in excess of the corrosion allowance, a Fitness-For-Service assessment may be performed in accordance with one of the following sections of API 579-1/ASME FFS-1. This assessment requires the use of a future corrosion allowance, which shall be established.

• Assessment of General Metal Loss—API 579-1/ASME FFS-1.
• Assessment of Local Metal Loss—API 579-1/ASME FFS-1.
• Assessment of Pitting Corrosion—API 579-1/ASME FFS-1.

To evaluate blisters and laminations, a Fitness-For-Service assessment should be performed in accordance with API 579-1/ASME FFS-1. In some cases, this evaluation will require the use of a future corrosion allowance, which shall be established.

To evaluate weld misalignment and shell distortions, a Fitness-For-Service assessment should be performed in accordance with API 579-1/ASME FFS-1.

To evaluate crack-like flaws, a Fitness-For-Service assessment should be performed in accordance with API 5791/ASME FFS-1.

To evaluate the effects of fire damage, a Fitness-For-Service assessment should be performed in accordance with API 579-1/ASME FFS-1.

Piping Stress Analysis (Analisis Piping Stres)

Piping shall be supported and guided so that : 

• its weight is carried safely.
• it has sufficient flexibility for thermal expansion or contraction, and.
• it does not vibrate excessively.

Piping flexibility is of increasing concern the larger the diameter of the piping and the greater the difference between ambient and operating temperature conditions. 

Piping stress analysis to assess system flexibility and support adequacy is not normally performed as part of a piping inspection. However, many existing piping systems were analyzed as part of their original design or as part of a rerating or modification, and the results of these analyses can be useful in developing inspection plans. When unexpected movement of a piping system is observed, such as during an external visual inspection the inspector should discuss these observations with the piping engineer and evaluate the need for conducting a piping stress analysis.

See API 574 for more information on pressure design, minimum required and structural minimum thicknesses, including formulas, example problems and default tables of suggested. 

Piping stress analysis can identify the most highly stressed components in a piping system and predict the thermal movement of the system when it is placed in operation. This information can be used to concentrate inspection efforts at the locations most prone to fatigue damage from thermal expansion (heat-up and cooldown) cycles and/or creep damage in high-temperature piping. Comparing predicted thermal movements with observed movements can help identify the occurrence of unexpected operating conditions and deterioration of guides and supports. Consultation with the piping engineer may be necessary to explain observed deviations from the analysis predictions, particularly for complicated systems involving multiple supports and guides between end points.

Piping stress analysis also can be employed to help solve observed piping vibration problems. The natural frequencies in which a piping system will vibrate can be predicted by analysis. The effects of additional guiding can be evaluated to assess its ability to control vibration by increasing the system’s natural frequencies beyond the frequency of exciting forces, such as machine rotational speed. It is important to determine that guides added to control vibration do not adversely restrict thermal expansion.

CONSTRUCTION SAFETY & HEALTH MANAGEMENT SYSTEM

                      CONSTRUCTION SAFETY & HEALTH MANAGEMENT SYSTEM                       ACCIDENT PREVENTION PROGRAM
Oleh : Bayu Nurwinanto

Worksite Analysis

We will conduct a worksite analysis, through systematic actions that provide information as needed to recognize and understand the hazards and potential hazards of our workplace. Listed below are types of worksite analysis actions that can assist with making an inventory of potential hazards in our workplace :

1. Job safety analysis.
2. Comprehensive hazard surveys.
3.  Hazard analysis of changes in the workplace.
4. Regular site safety and health inspections.
5. Employee report of hazards or potential hazards.
6. Accident and incident investigations with corrective actions and follow-up.
7. Injury and illness trend analysis.
8. Personal protective equipment assessment.
9. Ergonomic analysis.
10. Specific identification of confined spaces.
11. Identification of energy sources for specific machines.
12. Copies of written inspections and surveys by: fire department, in-house as required by safety and health standards (e.g., overhead crane inspections, powered industrial truck daily inspection, etc.).

Job Safety Anaylsis

(Company Name) will utilize job safety analysis to determine potential hazards and identify methods to reduce exposure to the hazards.

Job Safety Analysis (JSA) is a method of planning for safety and health.  There are three parts to the JSA.

1. The first component of a JSA is breaking down a job or task into the specific steps it takes to complete the job.  Although this can be done in small detail, typically only the major steps are listed. This often results in five to ten steps.  The steps are listed in chronological order, listing the first thing that must be done, then what comes next, and so on.
2. The second component of a JSA is to list all the hazards that are involved in each step. There may be many hazards that get listed next to some steps and may not be any associated with some steps.
3. The third step is to write down how each hazard will be eliminated or controlled. In other words, describe what needs to be done in order to perform that task safely.

Sample JSA Form

Employee Report Of Hazards

Our employees play a key role in identifying, controlling, and reporting hazards that may occur or already exist in the workplace. Employee reports of potential hazards can be an effective tool to trigger a closer look at a piece of equipment, operation, or how work is being performed. Reports of potential hazards can also provide suggestions to eliminate a hazard.

Accident/Incident Investigation

We will conduct an investigation for all accidents/incidents and near misses. Our primary goal of conducting an investigation is to determine the “root cause” to prevent the risk of a future occurrence. Investigation reports can help determine injury and illness trends over time, so that patterns with common causes can be identified and prevented. Investigations are not intended to place blame.

Accidents and “near-miss” incidents will be investigated by (Name/Title). The reports will be reviewed by (Name/Safety Committee) within (Days/Hours) of an accident/incident.

Hazard Prevention And Control

Our management will develop systems to prevent and control hazards. These include: the establishment of controls through engineering, work practice, personal protective equipment, and/or administrative actions; systems to track hazard correction; preventive maintenance systems; emergency preparation; and medical program.

Our written system will be implemented to assure guards, housekeeping, and personal protective equipment are provided and being used.

Job Site Inspections

(Company Name) will conduct daily job site inspections.  Hazards will be documented, reviewed, and corrections will be made in a timely manner.  More detailed, written inspections will be conducted by (Name/Title) on a (Weekly/Monthly) basis.  The Safety Coordinator or other designated safety person will tour each job site and observe potential safety/health hazards, and develop a plan for safeguarding this company's workers which may include the following :

1. Removing the hazard.
2. Guarding against the hazard as required by MIOSHA.
3. Providing personal protective equipment and enforcing its use.
4. Training workers in safe work practices.
5. Coordinating protection of workers through other contractors.

A record of all safety inspections and correctional steps will be kept.

Accident Investigation

All accidents resulting in injury or property damage will be investigated.  The purpose of the investigation is NOT to find fault, but to find the cause of the accident so similar incidents can be prevented in the future.

1. All accidents, no matter how minor must be reported to the Foreman immediately.
2. Foremen must report all accidents to the Safety Coordinator as soon as possible.
3. Foremen must complete an initial written accident investigation the day of the accident, if possible.
4. All workers involved in the accident or who witnessed the accident must complete a written statement describing the incident.
5. The Safety Coordinator will complete a thorough accident investigation to determine root causes and corrective actions.
6. Near misses (situations where an accident almost happened) should be reported. Corrective action must be taken to prevent the same situation from occurring again with the potential for serious injury. Foremen should make a note of near misses and the corrective actions taken and report them to the Safety Coordinator, so that the same corrections may be made on all the company’s job sites.

Personal Protective Equipment

1. Hard hats will be worn on job sites at all times.
2. Eye protection will be worn when there are potentials of hazards from flying objects or particles, chemicals, arcing, glare, or dust.
3. Leather work boots shall be worn to protect from falling objects, chemicals, or stepping on sharp objects.  Safety toe footwear may be necessary in some instances. Athletic or canvas-type shoes shall not be worn.
4. Protective gloves or clothing shall be worn when required to protect against a hazard.
5. Harnesses and lanyards shall be utilized for fall protection as required.

Policies, Procedures, Safety And Health Rules

Our management is responsible for implementing major decisions, policies and safety and health procedures. Specific safety and health procedures that are required by MIOSHA will be put in writing such as: lockout, right to know, fall protection, confined space, respiratory program, etc.  A copy of our written safety program will be available on every jobsite, either in the jobsite trailer, the gang box, or with the foremen.  The required MIOSHA posters will be posted (Location).

(Company Name) will inform and enforce the following safety rules :

All of our safety rules must be obeyed.  Failure to do so will result in strict disciplinary action.

1. Wear appropriate clothing and use sun block to prevent sunburn.
2. Watch where you are walking.  Do not run.  Keep your mind on your work at all times.
3. The use of illegal drugs or alcohol or being under the influence during working hours shall be cause for termination.  Inform your supervisor if taking strong prescription drugs that warn against driving or using machinery.
4. Do not distract the attention of fellow workers or engage in horseplay.  Do not engage in any act which would endanger another employee.
5. Keep your working area free from rubbish and debris. A clean job is the start of a safe job.
6. Do not use a compressor to blow dust or dirt from your clothes, hair, or hands.
7. Report any fear of walking at heights to your supervisor.
8. Know where fire extinguishers are located and how to use them.
9. Lift correctly - with legs, not the back.  If the load is too heavy GET HELP.  Do stretching exercises prior to work activities.  Approximately twenty percent of all construction related injuries result from lifting materials.
10. Keep back at least 10’ from all power lines, further if high voltage.
11. Nobody but the operator shall be allowed to ride on equipment unless the equipment is designed to carry a passenger.
12. Do not use power tools and equipment until you have been properly instructed in the safe work methods and become authorized to use them.
13. Do not remove, displace, damage, or destroy any safety device or safeguard on equipment or machinery.
14. Barricade danger areas.  Guard rails or perimeter cables may be required.  Do not enter an area which has been barricaded.
15. If you must work around power shovels, trucks, rough-terrain fork-lifts, dozers, or other heavy equipment, make sure operators can always see you.
16. Never oil, lubricate, or fuel equipment while it is running or in motion.
17. Before servicing, repairing, or adjusting any powered tool or piece of equipment, disconnect it, lock out the source of power, and tag it out.
18. Excavations over five feet deep must be shored or sloped as required.  Keep out of trenches or cuts that are not properly shored or sloped.  Excavated material or other debris shall not be stored nearer than two feet from the edge of the excavation.  Excavations less than 5 feet will require cave in protection where conditions indicate possible side failure.
19. Practice the following safety procedures when using ladders : 1. Use the "four to one" rule when using a ladder.  One foot of base for every four feet of height. 2. Portable ladders in use shall be equipped with safety feet unless the ladders are tied, blocked or otherwise secured.  Step ladders shall not be used as a straight ladder. 3. Ladders must extend three feet above landing on roof for proper use. 4. Defective ladders must be properly tagged and removed from service. 5. Keep ladder bases free of debris, hoses, wires, materials, etc.
20. Build scaffolds according to manufacturers' recommendations and MIOSHA Construction Safety Standard, Part 12, Scaffolding. 1. Scaffolds over 10’ must have guardrails on all open sides. 2. Scaffold planks shall be properly lapped, cleated or otherwise secured to prevent shifting.
21. Use ground fault circuit interrupters at all times with any temporary power supply. Use only extension cords of the three-prong type.
22. Fall protection is required at 6 feet or higher. 100% tie-off means the harness and lanyard are always connected to anchorage.
23. Never throw anything "overboard."  Someone passing below may be seriously injured.
24. Open fires are prohibited.
25. Know what emergency procedures have been established for your job site.  (Location of emergency phone, first aid kit, stretcher location, fire extinguisher locations, evacuation plan, etc.).
26. Never enter a manhole, well, shaft, tunnel or other confined space which could possibly have a hazardous atmosphere because of lack of oxygen, or presence of toxic or flammable gas, or has a possibility of engulfment by solids or liquids. 1. Only a qualified person will test the confined area with an appropriate detector before entry. 2. Wear the necessary personal protective equipment. 3. Provide ventilation by blowing fresh air into the confined space. 4. An attendant (hole-watch) may be required to be stationed at the entrance.

Safety Discipline 

(Company Name) has implemented the following four step disciplinary system when safety rules are not followed or other unsafe actions endanger workers.

First violation       : Oral warning; notation for personnel file.

Second violation : Written warning; copy for file or Personnel Office.

Third violation     : Written warning; one day suspension without pay.

Fourth violation   : Written warning and one-week suspension, or termination if warranted

Zero-tolerance Violations:Some safety violations are of such serious nature that there will be no warnings and termination may result. Examples include.

• Entering hazardous confined spaces without following proper procedures.
• Failing to use fall protection equipment.
• Entering unsafe excavations.

Both the employee and the supervisor allowing these unsafe acts may be terminated. 

A record will be maintained of all disciplinary actions.

Emergency Procedures

In case of an emergency on site the following procedures will be instituted at each site.

1. Method of communication will be determined at each site: telephone, radio, etc.
2. Post the following emergency telephone numbers (Police, Fire & Medical Response Team)
3. Post the job site address near the communication station.
4. Post names of first aid responders on site.  First responders should obtain all required First Aid/CPR and Bloodborne Exposure training.
5. Designate person to direct emergency crews to site of emergency.
6. Instruct each employee if known harmful plants, reptiles, animals, insects, or other environmental hazards are present, including : 1. The potential hazards, 2. How to avoid injury, 3. Applicable first aid procedures to be used in the event of injury.

Lockout / Tagout

Lockout / Tagout assures that employees are protected from unintended machine motion or unintended release of energy which could cause injury.  This includes electricity, water, steam, hydraulic, gravity, and many other sources of stored energy.

All sources of energy must be shut off, de-energized at the source, and locked-out prior to any employee beginning work around or on the potential hazard.

Confined Space Entry

No employee shall enter confined spaces without authorization. A confined space is defined as the following :

1. A space that is Not Designed For Continuous Employee Occupancy, and.
2. Is large enough and so configured that a person can bodily enter into and perform assigned work, and.
3. Has LIMITED or RESTRICTED means for ENTRY or EXIT.

Confined spaces that may have a HAZARDOUS ATMOSPHERE require special precautions.  Hazardous atmospheres are those that may expose employees to the risk of death, incapacitation, impairment of ability to self rescue caused by :

1. Flammable gas.
2. Airborne combustible dust.
3. Atmospheric oxygen concentration below 19.5 or above 23.5%
4. A toxic atmosphere or substance.
5. Danger of engulfment.

Written Hazard Communication Program

Hazard communication means ensuring that all workers know about the chemicals that they work with and work around.  Often called “Right to Know,” the hazard communication program involves the following elements :

1. Written hazard communication program.
2. Training on the chemicals this company uses.
3. Labeling: using properly labeled containers.
4. Safety Data Sheets (SDS):  SDS (formerly known as Material Safety Data Sheets or MSDS) must be readily available onsite. Workers must know where to find SDS and be able to read and properly utilize an SDS.
5. Posting signs to inform employees of the location of SDS and when new chemicals are brought on the job site.
6. Informing other contractors:  If we use chemicals around other contractors, it is our responsibility to inform other contractors of the hazards involved. We will make every effort to keep other contractors safe from the chemicals we use.  Typically, the general contractor onsite will need to coordinate all chemical use of all contractors to maintain a safe workplace.

Fall Protection Program

Fall protection is required whenever working at six feet or above.

Fall protection will be provided by one or more of the following :

1. Guardrails.
2. Hole covers.
3. Safety nets.
4. Personal fall arrest system (harness and lanyard).

Electrical Safety

Electrical safety involves two primary issues :

• Powerlines.
• Temporary and permanent electrical wiring and equipment.

To avoid electrical incidents, several basic safety rules must be followed :

sloping of trench sides

1. Stay at least 10 feet back from powerlines, in ALL directions. Stay further back if voltages are greater than 50,000 volts.
2. Do not store materials under powerlines.
3. Mark powerlines on the job site with warning signs below.
4. Use ground fault circuit interrupters (GFCI) whenever plugging into temporary power or using an extension cord.
5. Extension cords and trailing cords with missing ground prongs must be removed from service.
6. Extension cords and trailing cords with cuts must be removed from service.
7. Do not operate wet power tools.
8. Keep extension cords from being damaged in doorways or being run over.
9. Keep extension cords out of wet areas.
10. Never wire anything yourself or attempt to make electrical repairs. Leave that for an electrician.
11. Assume all wires and electrical boxes are live, unless you are certain they are not.
12. Do not store any materials within 3 feet of electrical boxes.

Excavation Safety

Pre-job planning is vital to accident-free excavations and trenching; safety cannot be improvised as work progresses.

The following concerns must be addressed by a qualified person.

1. Evaluate soil conditions and select and construct appropriate protective systems in accordance with MIOSHA Part 9, Excavation, Trenching and Shoring.
2. If the trench is 5’ or deeper, you must use one of the following (sloping of trench sides, benching of trench sides, trench boxes and shoring)
3. If the trench is less than 5’ but is hazardous due to soil or the nature of the trench, then you must use protective systems.
4. Appropriate protective systems to prevent a cave-in may include.
5. Inspect the site daily at the start of each shift, following a rainstorm, or after any other hazard-increasing event.
6. Contact MISS DIG to locate underground lines at least 3 days prior to excavating.
7. Plan for traffic control when necessary. Refer to the Michigan Manual on Uniform Traffic Control (MMUTC) Part 6 (available from the Michigan Department of Transportation) for traffic control.
8. Determine proximity to structures that could affect choice of protective systems.  For example, ensure roads, sidewalks, or buildings are not too close to allow the use of a trenchbox or adequate sloping.
9. Test for low oxygen, and hazardous gases and vapors, especially when gasoline engine-driven equipment is running, or the dirt has been contaminated by leaking lines or storage tanks. Fuel-powered equipment produces carbon monoxide in the exhaust and must not be used without adequate ventilation. Provide appropriate respiratory protection when necessary.
10. Provide safe access into and out of the excavation. If the excavation is 4’ or greater, ensure a ladder is within 25’ of workers in the excavation.
11. Provide appropriate protections if water accumulation is a problem. Water flow and accumulation must be inspected and must be controlled.
12. Keep excavations open the minimum amount of time needed to complete operations.

Safety And Health Training

(Company Name) will provide training to assure the requirements of MIOSHA standards are met and continuously evaluate employee training needs to keep workers safe and healthy on the job.

1. New Employee Orientation:  New employees will receive training on the company safety and health management system, safe work practices and expectations, and specific safety and health training for the tasks that they will perform.
2. After inspecting a job site, (Name/Title) will identify and evaluate all potential hazards for potential of serious injuries and probability of an accident.  Actions will be taken to minimize the hazards and protect the workers.
3. The Safety Coordinator or other designated site person will appraise the skill and knowledge level of exposed workers, and provide any needed training.
4. Where safety and health training is needed, appropriate training will be provided.
5. Records will be maintained for all training sessions with descriptions of topics covered and names of workers trained.
6. Toolbox Talks:  Toolbox talks will be conducted regularly (weekly/daily).  Topics covered will include : 1. The safe work practices necessary for that day’s work. 2. Any safety concerns workers may have. 3. Brief refresher training on relevant safety topics (topics to be provided by the Safety Coordinator).

Safety And Health  Work Observations

Safety and health work observations will be performed periodically by supervisors or designated observers.

Safety and health work observations ensure: 1) an employee has the knowledge to perform the work as trained, and 2) is actually performing their work task safely. Specific observations or audits are especially critical for lockout/tagout, confined space, or where the risk of exposure is high. Results will be documented and follow-up training will be provided as needed.  This process helps assure safety and health training is effective.