Nickie
I have never seen LOTO used to change a cylinder. Unless your system is controlled via a remote activation, the steps in cylinder change result in system isolation. The cylinder technician has complete control from the time they shut the cylinder valve and delivery valve (on the delivery side of the regulator) until they pressurize the system. However, work on the system piping, downstream from the regulator, should be covered by LOTO.
Neal
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From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Nickie Norton
Sent: Tuesday, May 9, 2017 4:58 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Lockout needed when changing gases?
I work in R&D for a small manufacturing company and was in a similar situation to yours. Our R&D group was initially left out of the processes that the plant was involved in, permitting, MOCs, etc. We now have a Laboratory Chemical Safety Plan that includes the SOPs for what you are describing. By having the plan in place, we can follow the SOPs. We only have to do MOCs when permanent renovation changes are involved. Changing the tubing in our hoods does not require an MOC, but running a permanent vacuum line from a pump to a hood would require an MOC, we would have to have someone from the maintenance department run such a line. Running a temporary line (such as rubber vacuum tubing from a portable vacuum pump) would not require an MOC. As for changing gas cylinders, they are covered by an SOP in our Lab Chemical Safety Plan, so no MOC is required.
Hope this helps.
Nickie Norton
Research Chemist
The Shepherd Chemical Company
4900 Beech Street
Norwood, OH 45212
nnorton**At_Symbol_Here**shepchem.com
513-842-9332
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I am a part of a group that is currently reviewing and updating the company’s safety standards. The company has mainly focused on the industrial process plant in the past, designating R&D along with all administrative areas as “unclassified”. This has allowed the lab to conduct research with minimal need for permits, MOCs, and other obstacles that are more pressing at the plant scale (kTon). It is quite obvious that R&D is more hazardous than an office area and thus should adhere to more stringent standards. My goal as the R&D representative is to make the laboratory as safe as possible without completely hindering progress.
My question lies within the Line/Vessel Opening safety standard. The current policy states “a permit is required before any line can be opened or removed.” At the laboratory scale this doesn’t seem practical. We build our vacuum/pressure/piping systems ourselves in most cases (using the appropriate glassware or stainless steel for the conditions) and often make modifications based on reaction observations and results. It is important to note that we do not modify vessels that are rated for pressurized reactions, only the piping that feeds the gas. Our piping systems are primarily 1/4” or 1/8” SS or copper tubing which we cut and bend ourselves. Is it necessary to write a permit for each modification? Are there certain exceptions I can site when writing this standard?
Also, technically changing gas cylinders involves a line opening as well. We have a lab SOP for this process. Should a permit be required?
I am the CHO for my lab and a researcher, so I’d like to find a compromise that puts safety first without impeding lab work entirely.
Does anyone have experience with this type of situation/policy?
Hannah Corcoran
R&D Facility Lead
Emerald Kalama Chemical, LLC
1296 Third St NW
Kalama, WA 98625
360-673-0319 (office)
hannah.corcoran**At_Symbol_Here**emeraldmaterials.com
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