Subject: Re: [DCHAS-L] Cylinder question
Date: January 17, 2012 4:28:07 PM EST
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
The "in-use" provision applies to all research labs, not just academic labs. It is not an "exception" just for "academic" labs. However, the interpretation of "in-use" is that the cylinder of oxidizing or fuel gas is physically connected to an analytical device (e.g., a gas chromatograph or flame photometer), a manifold, or the like. When not "in-use" (e.g., the single standby cylinder of flammable gas kept available to allow a quick change out) the protective cap must be on the standby cylinder (thus necessitating removal of the pressure/flow regulator); and the cylinder properly secured to prevent tip over.
This "standby" provision is NOT consistent with use of a research laboratory as a "storage" area for many capped cylinders. The 20-ft rule and or non-combustible barrier would apply if a reasonable person perceives that the lab is used for "storage," - a function that should generally be limited to one or a few specially designed/equipped rooms in a building. I will attempt to find more specific information other than simply firm recollections based on numerous Q&A over many years.
NFPA 45 (approx title: fire safety for laboratories) is probably a good source. However, I do not have direct access to the document.
David Haugen (retired)
Argonne National Laboratory
"Don Abramowitz" <dabramow**At_Symbol_Here**BRYNMAWR.EDU>To:
Tuesday, January 17, 2012 12:42:30 PMSubject:
Re: [DCHAS-L] Cylinder question
If you are referring to the following standard:1910.253(b)(4)(iii)
cylinders in storage shall be separated from fuel-gas cylinders or
combustible materials (especially oil or grease), a minimum distance of
20 feet (6.1 m) or by a noncombustible barrier at least 5 feet (1.5 m)
high having a fire-resistance rating of at least one-half hour.
Note that this standard appears in Subpart Q of 1910, entitled "Welding, Cutting and Brazing." The use of gas cylinders to support laboratory instruments is outside the scope of this standard. There are also letters of interpretation on the OSHA website that talk about "in-use" vs "storage" and you may find a favorable interpretation there.
Environmental Health & Safety Officer
Bryn Mawr College
101 N. Merion Avenue
Bryn Mawr, PA 19010-2899
I have a question regarding the use of gas cylinders on instrumentation within an academic research lab. I am familiar with the regulations regarding storage of flammable and oxidizing gas cylinders, in particular the 20 foot rule, gas cabinet, or concrete barrier requirements. That being said, I seem to remember learning at a training session that cylinders "in use" were exempt from these requirements. I can not find the regulation stating this, but if I remember correctly, it was written almost specifically for research labs at academic institutions and added by the regulatory authority as an "exemption" to the standard. Can anyone point me in the right direction for this regulation?
Brandon Chance, M.S.
Safety and Environmental Compliance Manager
Office of Building Operations & HSSE
Texas A&M University at Qatar
PO Box 23874 | Doha, Qatar
TAMUQ Building Room 225E | Education City
(o) +974.4423.0495 | (m) +974.6668.3552 | SkypeIn USA 001.281.764.1776
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