Hazard ID & Risk Assessment - symbllc.com Assessment.pdf · Hazard ID & Risk Assessment (HIRA) Client Allen D. H. Blanchard 4 3.0 Process and Material Review The following represent

Prepared August 2010

On Behalf of CLIENT

Hazard ID & Risk Assessment Workplace Safety Evaluation & Analysis

Allen D. H. Blanchard

[email protected]

(713) 471-7273

www.symbllc.com

Hazard ID & Risk Assessment (HIRA) Client

Allen D. H. Blanchard 2

Table of Contents

1.0 Introduction ...........................................................................................................................3 2.0 Methodology ..........................................................................................................................3 3.0 Process and Material Review ...................................................................................................4

3.1 Materials ....................................................................................................................................... 4

3.2 Processes ....................................................................................................................................... 4

3.3 Hazardous Chemicals .................................................................................................................... 5

4.0 Site Inspection and Work Observations ...................................................................................6

4.1 Site Inspection ............................................................................................................................... 6

4.2 Work Observations ....................................................................................................................... 6

5.0 Exposure Monitoring (Industrial Hygiene and Hazards) ............................................................7

5.1 Parameters .................................................................................................................................... 7

5.2 Monitoring Results ........................................................................................................................ 7

6.0 Programs and Records Review ................................................................................................9

6.1 Program Review ............................................................................................................................ 9

6.2 Records Review ........................................................................................................................... 10

7.0 Injury and Incident Review .................................................................................................... 10 8.0 Safety Metrics & Industry Comparison ................................................................................... 11 9.0 Compliance Status ................................................................................................................ 12 10.0 PPE Assessment .................................................................................................................... 13

11.1 Primary Hazards .......................................................................................................................... 13

11.2 Radiation Exposures .................................................................................................................... 13

11.3 Assessment ................................................................................................................................. 13

11.0 Quantitative Risk Analysis ..................................................................................................... 14

11.1 Methodology ............................................................................................................................... 14

11.2 Numerical Assignments .............................................................................................................. 14

11.3 Quantitative Safety Risk Assessment .......................................................................................... 15

12.0 Summary & Findings ............................................................................................................. 16 13.0 Addendums .......................................................................................................................... 17

13.1 Site & Desktop Review Items ...................................................................................................... 17

13.2 Radiation Exposure Report Example ........................................................................................... 23



1.0 Introduction

This report documents the biennial hazard identification and risk assessment (HIRA) Client

conducts of its non-hazardous oil and gas waste disposal facility in USA. The HIRA is

performed in order to:

Identify worksite hazards and conditions;

Evaluate the adequacy of safety programs and practices;

Determine exposure levels for site physical, chemical and radioactive hazards;

Quantify risk factors for specific hazards; and

Provide insight for improvements.

2.0 Methodology

The HIRA incorporates various desktop reviews, site inspections, interviews, industrial

hygiene and hazard surveys, and analysis. More specifically, the HIRA includes:

Review of currently handled materials, chemicals and wastes;

Review and compilation of site processes, such as waste offloading, vehicle washout, hot work, etc;

Site monitoring of industrial hygiene and/or exposure hazards such as benzene, volatile organic compounds, noise, hydrogen sulfide, carbon monoxide, radiation, and explosive conditions;

Review of existing safety programs, procedures, policies, and records;

Site inspection and work observations

Analysis of safety metrics and comparison to industry averages;

Review of historical incidents and injuries;

Subjective evaluation of the safety compliance status;

Quantitative risk analysis of appropriate process, procedures and/or hazards;

Evaluation of PPE adequacy; and

Prioritized recommendations for safety improvements.



3.0 Process and Material Review

The following represent the theoretical materials, processes and hazardous chemicals

involved with site operations. See section 4.0, Site Inspection and Work Observations for

onsite processes and items specifically reviewed during this HIRA.

3.1 Materials

Non-hazardous oil and gas wastes o Oil base and water base drilling mud o Completion fluids o Production fluids – Saltwater, BS & W o Production solids – Sand. Tanks bottoms, soil, etc o Work over fluids

Naturally Occurring Radioactive Material

Recyclable iron, scrap and rock

Solid waste – trash, refuse

Compressed gases: oxygen, acetylene, propane, air

Fuels: gasoline, diesel

3.2 Processes

Truck receipt and standby

Container offloading: drums, cuttings boxes

Vehicle & Cargo offloading: tanker trucks, end dumps, roll off boxes, vacuum boxes

Container emptying: drums, cuttings boxes, frac tanks

Waste processing & disposal: mixing, slurrying, pumping, injection

Waste recycling: Transport, mixing, end dump loading

Container and vehicle washouts

Equipment maintenance: pumps, shaker, crane, forklift, backhoe, excavators

Welding, cutting, fabrication

NORM offloading, processing and injection

General tool use: grinding, drilling,

Electrical maintenance

Compressed gas storage and use

Fuel storage and use



3.3 Hazardous Chemicals



4.0 Site Inspection and Work Observations

4.1 Site Inspection

A site inspection was performed of the facility on July 27th. Items inspected include those

listed in Addendum 13.1, Site & Desktop Review Items.

4.2 Work Observations

As part of the biennial HIRA, observations were made of work processes such as those listed

in section 3.2 of this report. Over the two (2) days July 26 and 27, the following processes

were observed directly:

Waste receipt and standby;

Truck and cargo offloading;

Waste processing;

Welding and cutting;

General tool use; and

Vehicle and container washout.

Along with the other elements of this report, the site inspection and work observations are

used as input to determining the compliance status and to aid in attributing risk factors for

the quantitative risk analysis documented in section 11.1 of this report.



5.0 Exposure Monitoring (Industrial Hygiene and Hazards)

5.1 Parameters

Measurements were taken of the following parameters to determine the presence or

absence of actionable exposure hazards:

Benzene

Hydrogen Sulfide

Volatile Organic Compounds

Explosive Compounds

Gamma radiation

Noise

Carbon Monoxide

Oxygen

5.2 Monitoring Results

Exposure & Hazard Monitoring Results

Monitoring Points Result

Benzene

Condensate Tank Head Space 180 ppm

Frac Tank Head Space 125 ppm

V-Tank during saltwater offload 9.7 ppm within 1' of hose discharge

Injection Tank 4.9 ppm within 1' of discharge from V-Tank.

Welding area .3 ppm

Waist level on V=Tank .7 ppm during static no offloading conditions

Waist level on Injection Tank .6 ppm during static no offloading conditions

Laboratory .2 ppm

Saltwater storage pit .3 ppm

Noise

Air Compressor 102.5 db maximum. 82.4 to 99.0 for personnel. 15' radius

for 85 db.

Diaphragm pump 103.8 maximum

Diesel pump 105.3 maximum

Top of V-Tank 77.8 to 92.1 db

Top of Injection Tank 84.1 to 99.8 db

Containment Area around tanks 85.3 to 98.9 db

Between vertical tanks 83.8 to 87.8 db

Washout pit 77.4 to 81.6 db

Maintenance area 71.1 to 73.0 db

Backhoe cab 84.5 db



Cherry Picker Cab - 76.0 db; Front 76.1 db; Rear 77.6 db

Forklift Cab - 83.8 db; Front - 78.6 db; Rear - 87.8

Excavator Cab - 79.1 db; Engine - 91.1 db; Rear 74 db; 3' radius for

85 db

Semi Trucks 99.8 db at compressor

Trucks side by side 30' radius for 85 db. 83.0 db between trucks.

SW pit perimeter 70 to 72 db

Laboratory 56.3 db to 60.5 db

Sump pump diesel 94.2 db max. 8' radius for 85 db

Around Injection pumps 98.9 to 100.7 db

Ground level inside containment

area

87.7 db to 100.7 db generally

Truck standby and unloading areas 73.0 to 76.1 db

Volatile Organic Compounds (VOCs)

Condensate tank 400 ppm

Washout pit at shale shaker outlet 5 to 18 ppm

V - Tank 180 ppm during saltwater offload.

V - Tank 5 to 18 ppm in dead headed airspaces - no offloading

Injection Tank 15 to 30 ppm. Concentrated in dead air spaces.

Saltwater pit 0 to 1.3 ppm

Frac Tank 250 ppm

Carbon Monoxide

Tanks, pumps , equipment, vehicles None detected

Oxygen

Tank head spaces, vehicle cabs, all

other

20.2 to 20.5 %

Hydrogen Sulfide

Condensate tank head space 3.0 ppm

All other areas None detectable

Explosive Compounds (LEL)

Condensate tank head space 22%

Frac tank head space 3%

Gamma Radiation

V-Tank 35 to 200 uR/hr

Between V-Tank and Injection Tank 8 to 18 uR/hr

Vertical storage tanks 20 to 75 uR/hr

Frac tanks Background

Saltwater pit Background to 40 uR/hr

Injection Tank Background to 15 uR/hr



6.0 Programs and Records Review

6.1 Program Review

A detailed review of the CLIENT ES & H program has been completed. The primary purpose

was to determine the required and/or appropriate programs, procedures, and policies. The

program review was derived from both regulatory requirements and client and industry

expectations and standards.



6.2 Records Review

The following records were reviewed in support of this HIRA and the overall

program review and improvements:

Historical OSHA 300 and 300 A logs

Injury and incident reports

Maintenance records

Radiation exposure records

Hazardous chemicals MSDS

Previous audits and inspections

Personnel orientation and training records

Employee Modification Rating (EMR) documents

7.0 Injury and Incident Review

The following incidents, including documents and any investigation reports, were reviewed:

Employee struck by Lightening (non-documented) – 6/13/1999

Mechanic Back Injury – 2003?

White Oak Waste Receipt Incident – 2/6/2010

Leonel Martines Eye Injury – 10/16/2007

H-10 Records Incident – 12/9/2008

Carrie Simon Waste Receipt Incident – 1/23/2009

Gloria Turner – Basic Trucking Waste Receipt Incident – 3/26/2010

Gallion Crane Roll Over Incident – 6/8/2010

Forklift incident – 6/28/2010

Non-documented spill incidents

The above incidents may be summarized as follows:

One (1) eye injury - Flying debris

One (1) back injury – Manual lifting

Two (2) equipment operation incidents

Spill incidents – Non safety

Four (4) waste receipt or administrative incidents – Non safety

One (1) act of god injury

Additional safety issues have arisen related to confined space, slips, housekeeping, gas

cylinders, and traffic.



8.0 Safety Metrics & Industry Comparison

A reliable indicator of CLIENT Safety status is comparison of safety metrics to industry

averages. Industry averages are obtained from the Bureau of Labor Statistics website.

Summary:

CLIENT has exceeded or met industry averages in safety metrics for every year since

operations began – 1998. Below is the analysis for the past three (3) years



9.0 Compliance Status

The following represents a snapshot evaluation of the general compliance status of specific

ES & H issues and programs. Comments are based on knowledge levels (Corporate, ES & H,

& Operations), quality of written programs, degree and quality of implementation, and

training levels.

Overall

Are site hazards known? Yes

Are safety regulatory requirements adequately understood? Yes

Are site hazards requirements and controls understood? Yes

Are written programs, policies, etc., in place? Yes

Are management systems sufficient to ensure compliance? Yes

Do written programs, policies, etc., address all areas of safety? Yes

Are all necessary elements of the written programs in place? No

Are corporate commitments in place to empower safety? Yes

Are onsite commitments in place to empower safety? Yes

What is the Corporate and ES & H level of knowledge? Sufficient

What is the ES & H level of knowledge? Sufficient

What is the onsite ES & H level of knowledge? Needs improving

What level of implementation exists for safety programs? Needs improving

What level of training exists for safety programs? Needs improving

Program Status Health & Safety Policy Satisfactory Respiratory Protection Satisfactory Confined Space Program Satisfactory Incident Investigation & Reporting Satisfactory Benzene Awareness Satisfactory Bloodborne Pathogens Satisfactory Responsibilities Needs Improving Stop Work Authority, Disciplinary Action, Waste Management Satisfactory Site (non-office) housekeeping – litter Needs improving Inspections and Audits Satisfactory Injury & Illness Reporting & Recordkeeping Satisfactory Hazard Communication Satisfactory Lock Out / Tag Out Satisfactory - Needs review NORM Management Procedure – Radiation Hazards Satisfactory Spill Prevention Control and Countermeasure Needs upgrading Training Program Needs improving Emergency Action Plan Needs training Electrical Safety Satisfactory-Needs improving Hurricane Action Plan Satisfactory Fire Prevention Needs improving First Aid Program Satisfactory



Flammable & Combustible Liquids Needs improving Material Handling & Lifting (Non Forklift) Satisfactory Equipment operations, safety & maintenance Needs improving Hand & Power Tools Satisfactory Welding, Cutting & Hot Work Needs improving Personal Protective Equipment (PPE) Satisfactory Slips, Trips & Falls Protection Needs Improving Noise Awareness, Exposure & Conservation Satisfactory

10.0 PPE Assessment

11.1 Primary Hazards

Periodic assessment of PPE selection and adequacy are required by OSHA. At the CLIENT

facility in USA, the main materials or chemicals that PPE must protect against include:

Completion & work over fluids (corrosive or reactive in nature)

NORM – radiation exposure

Sharp and flying objects

Overhead and moving objects

Heavy items, equipment operations

Wet, windy or icy conditions

11.2 Radiation Exposures

CLIENT performed radiation exposure for approximately eight (8) years, during which no

worker approached the level at which annual monitoring is required. As a result, external

beta-gamma dosimetry monitoring was discontinued. As part of the NORM survey

described in section 5.0 of this report, gamma radiation levels were measured, to ensure

that levels are not significantly different than during the period of dosimetry monitoring.

They are not. Per Texas Department of State Health Services requirements, exposure

monitoring records have been maintained and are available for workers. Below is an

example of one exposure report.

11.3 Assessment

Based on the hazards present and the exposure scenarios, the M. B. Environmental Services

PPE policy and requirements is satisfactory.



11.0 Quantitative Risk Analysis

11.1 Methodology

The numerical risk ranking system incorporates the below factors.

Frequency of Occurrence or Exposure Severity of Incident Compliance Status Historical Occurrence (has previous incident occurred at CLIENT)

The following formula is used to compute the risk factor:

RF = Frequency x Severity + Compliance Status + Historical Occurrence

11.2 Numerical Assignments

Frequency Frequent = 5

Occasionally = 3

Seldom = 1.5

Severity Catastrophic = 4

(May cause death or complete facility loss)

Critical = 3

(Severe injury or illness or major property damage)

Marginal = 2

(Minor injury or illness or major property damage)

Negligible = 1

(< 1 lost work day but a violation of some kind)

Compliance Status Compliant = + 0

Minor improvements = + 2

Major improvements = + 4

Historical Occurrence Never = + 0

1 occurrence = + 2

> 1 occurrence = + 4



11.3 Quantitative Safety Risk Assessment



12.0 Summary & Findings

The purpose of the biennial hazard identification and risk assessment (HIRA) is to identify worksite hazards and conditions; evaluate the adequacy of safety programs and practices; determine exposure levels for site physical, chemical and radioactive hazards; quantify risk factors for specific hazards; and provide insight for improvements.

HIRA methods generally included desktop reviews of programs and records, site inspections and observations of work practices, monitoring of worker exposure parameters and hazards, and quantitative risk evaluation of hazards.

Materials of interest include non-hazardous oil and gas wastes, NORM, recyclable iron, scrap and rock, solid waste, compressed gases and fuels. Work over and completion fluids may pose the greatest skin hazard to workers. Produced saltwater, BS & W and condensate pose s significant flammability and explosion hazard.

Processes of direct interest include vehicle traffic, container offloading, dumping and washing, waste processing and vehicle washouts. Equipment maintenance and hot work, along with flammable source management are also of primary concern.

Exposure and hazard monitoring was performed onsite for benzene, volatile organic compounds, explosive compounds, noise, hydrogen sulfide, radiation, oxygen, carbon monoxide. Benzene and VOC measurements indicate significant hazards inside vertical tanks and frac tanks, in addition to posing worker exposures in process areas. Explosive conditions exist in vertical tank head spaces. Hydrogen sulfide is present in vertical tanks but below action levels. Noise levels warrant management in areas around injection pumps, processing and the air compressor. Noise levels in the vicinity of semi trucks can also be significant. Oxygen and carbon monoxide measurements do not indicate areas of concern. Radiation levels are negligible.

Historical injuries and incidents have included One (1) eye injury, one (1) back injury, two (2) equipment operations incidents, one (1) act of god, four (4) waste receipt or administrative incidents, and miscellaneous non documented spill, traffic, confined space, and slip incidents.

Safety Metrics indicate CLIENT has met or exceeded Industry averages since operations began in 1998.

The overall safety program compliance status is satisfactory with reservations. Management and resource commitments are satisfactory. Requirements are known and written programs and management systems are in place. Corporate and ES & H knowledge levels are satisfactory. Improvement is needed in program implementation and training, along with site knowledge levels. See section 9.0 for specific program evaluations.

The periodically required PPE assessment indicates that, based on current hazards, ppe requirements and policies are satisfactory.

A Quantitative safety risk analysis was performed of 28 safety programs or elements, incorporating frequency of occurrence or exposure, severity of incident, compliance status, and historical occurrence into the following formula: RF = FO x SI + CS + HO

The highest risk programs, in descending order, included: Material Handling – Forklift/Backhoe operations; Fall Protection – Process Tank; Fire Hazards/Prevention; Traffic; Welding & Cutting; Material Handling – Heavy Equipment Operations; Electrical Safety – Hazardous Areas; Electrical Safety – Maintenance Areas; Confined Spaces; and Slips & Trips.



13.0 Addendums

13.1 Site & Desktop Review Items

Program Site & Desktop Review Items

All Programs

Initial and Annual Training

Annual Reviews

Benzene Awareness

Quantitative Monitoring every two (2) years

Bloodborne Pathogens

Review, maintain, update Exposure Control Plan at least annually

Review to reflect technological changes

Ensure BP supplies are available (ppe, labels, red bags)

Annual program review

Engineering controls examined on a regular basis

Hand washing facilities. Antiseptic with clean cloth or paper towels.

Containers that prevent leakage. 'Biohazard' labels.

Gloves, lab coats, face shields or masks and eye protection (goggles)

Gown, apron, lab coat, clinic jacket or similar

Fluorescent orange or orange red labels. Red bags may be substituted.

Records of occupational exposure.

Record of medical evaluation following exposure.

Electrical Safety

Separate training - Qualified & Un-qualified workers

Shiftly inspections of portable equipment

Inspect plugs and receptacles

Safety Signs to warn employees of electrical hazards

Emergency Action Plan

Ready list of emergency contact numbers

Ready list of employees for emergency accounting

Hand held blow sirens @ key Locations. Tested every two months.

Document siren tests every two months

Environmental & Waste Management Policy

Steel trash bins with covers.

Onsite litter & spillage.

Review waste streams, storage, recycling, etc. practices

Disposal documentation. Authorized wastes only.

Environmental Program



Waste Acceptance documentation

Waste recycling documentation

Periodic review of waste streams, recycling potential, current practices

Facility Environmental Inspections

Equipment Safety, Operations, Maintenance

Qualified operators must be specified

Manufacturer's Manuals available

Inspection records. Certification records as appropriate

Unattended equipment at night - light reflectors or barricades with lights

All cab glass is safety glass

Parked equipment must have parking brake engaged. If on incline, must have wheel chocks.

Seat belt on backhoe and forklifts

BH/FL Earth moving equipment must have service brake system

Forklift and BH must have horns AND reverse signal alarms

Reverse signal if have obstructed rear view

BH & Forklift must have rollover protective structures. 52" from deck to top

ROPS must have affixed label - manufacturer, model of ROPS, Model/SN designed to fit

Crane Load rating chart securely fixed in the cab

Frequent inspections performed daily to monthly

Periodic inspections at 1 to 12 month intervals or per manufacturer

Monthly running rope inspections. Certification record must be maintained

Monthly certifications of brakes, crane hooks and ropes

Fire extinguisher in cab or vicinity of the crane

FL Label must be attached showing certification by testing organization

Sufficient clearance must be maintained for passage and handling

Regular workplace safety inspections

Road and travel surfaces should be smooth and secure

Fire Prevention Plan

Periodic inspections to assess combustible material risk - ES & H

Periodic program review

Signage: Tanks (waste, diesel, sw, gas), breaker panels, trash

Electrical equipment and circuitry will be numbered/identified.

Designated smoking areas - signage

Secured storage of cylinders; valve protectors/caps/guards

Good housekeeping

Fire extinguishers inspected monthly. Annual maintenance. With records

First Aid Program

First aid provider onsite during waste operations



FA providers qualified by Red Cross or equivalent

First aid supply kit

Assess supply kit annually

Eye and body flush facilities

Flammable & Combustible Liquids

No onsite fiberglass or polyethylene tanks for flammable-combustible liquids

Tanks must be at least 3' apart

Tanks must be apart at least 1/6 th of the sum of their diameters. When one tank is < ½ the diameter of another, the two tanks shall not be closer than ½ the diameter of the smaller.

When unstable flammable/combustible liquids are stored, spacing shall not be < ½ the sum of the tank diameters.

At least 10 feet must exist between storage tanks and any building.

Tank areas must be diked with volume at least that of largest capacity tank

Earthen walls must be at least 3' high and include at least 3' on the top

Combustible material may not be present inside diked areas

Flammable storage cabinet rooms must have ventilation, at least 10' from entrances (if upgrade) or 20' from entrances (if downgrade)

Unloading areas must be 25' (class 1) and 15' Class 2 from ASTs

FE within 10 to 25' of ASTs and Unloading areas

General Waste Management

Periodic site inspections

Evaluate hazards with waste practices --- with Hazard ID

Hand & Power Tools

Safety glasses being used

Power cords away from heat, oil, sharp edges

Tools disconnected when not in use

Cords and electrical outlets in good condition.

No excessive dust on motors. Stored in clean area.

Safety guards for equipment with hazardous moving parts: Saws, grinders

Momentary contact on-off switches on: drills, grinders, sanders, saws, similar

Constant pressure switches on saws > 2"

Electrical - 3 prong ground, double insulated or powered by low voltage isolation transformer

Tools stored in dry place. Not used in wet place. Work areas well lighted.

Wheels shall be free from cracks or defects. Well fitted.

Portable grinding tools must have safety guards,

Hazard Communication

MSDS onsite



Chemical hazard list current

HazCom Poster - Both trailers

Hazcom signage on vertical tanks

Non-managed hazardous chemicals?

Hazard Identification & Risk Assessment

Qualitative & Quantitative Hazard ID every 2 years

Industrial hygiene monitoring every 2 years

Periodic site hazard inspections

Job Safety Analysis or Job Hazard Analysis

Review of written plans, regulatory status, incidents, accidents, injuries

Health & Safety Policy

Written procedures; Annual reviews; Hazard ID & Risk Assessments;

Inspections; Audits; PPE, Resources

Hurricane Action Plan

Internet access

Incident Investigation & Reporting;

NA

Injury & Illness Recordkeeping

OSHA 301 completed within 7 days

OSHA 300 log signed

OSHA 300 Log posted in conspicuous place by February 1st

Inspection, Measurement & Test Equipment

List of IMTE. Calibration dates.

Lock Out / Tag Out

Supplies: Tags, locks/keys, cable ties

Material Handling & Lifting

Rigging material inspection

Documents, tags or labels specifying lift limits

Rigging material stored in safe place

Hooks only of closable, lockable type

Motor Vehicle Safety & Defensive Driving

Periodic assessment of drivers licenses

Vehicles < 10 mph must have seat belts

Noise Awareness, Exposure & Conservation

Noise exposure assessment every 2 years

Change in process require updated assessment?

Signage: Air compressor, injection pumps

Ear plugs

Procedures in both trailers

NORM Laboratory Procedures



NA

NORM Management Procedure

NA

Personal Protective Equipment (PPE) Program

Personnel wearing boots, hard hats, gloves, eye wear?

Hazard assessment every 2 years. Documented

Respiratory Protection Policy

IH Monitoring every 2 years

Short Service Employee

List of SSEs. Assigned mentor.

Visual means to differentiate

Slips, Trips & Falls Protection Procedures

Site assessments - every 2 years

Clean and orderly facility.

Conditions maintained dry as possible.

Protection in wet areas to the extent practical and effective.

Safe clearances for material handling. Clear aisles, no obstructions, even ground.

Open pits must have guard rails or covers.

Standard Rails, Toe Boards

Spill Prevention Control and Countermeasure

System hoses capped or flanged when not in use

Drain valves that could result in spill must be locked shut unless frequently cycled operationally

Pumps that could cause spill must be starter's deactivated if they are used only infrequently

Lighting must be sufficient to identify spills

Accumulated water must be removed

Warning signs at unloading area to prevent vehicle departure before transfer complete

Program review every 3 years

Monthly SPCC inspections

Internal inspections of tanks annually - performed & documented when open

Stop Work Authority

Document stop work interventions

Training Program Documentation

Waste Acceptance Policy

NA

Welding, Cutting & Hot Work Procedures

Written permits for Hot Work

Cylinders legibly marked with stencils, stamps or label



Must have valve protection cap or collar

Stored away from heat

Oxygen not store near combustible material, near fuel gas or likely to cause fire

Welding blankets or shields if combustible material within 35'



13.2 Radiation Exposure Report Example