From here to there: Topics in Transportation October 2015 SPRAY 23 Chapter 28, Section 2806.3.3 of the Oregon Fire Code, for example, states that “Level Two and Level Three aerosol display and merchandising areas shall be separated from each other by not less than 25 feet,” and that Level Two and Level Three aerosol display and merchandising areas shall be separated from flammable and combustible liquids storage and display areas by a minimum distance of 25 feet horizontally, or separated by a noncombustible partition that extends 18 inches above the merchandise. Unfortunately, however, these codes do not include detailed instructions on the separation required from oxidizers, acids or other incompatible dangerous goods. A facility might then look to the U.S. Dept. of Transportation’s (DOT) Hazardous Materials Regulations (HMR) for guidance. Although the HMR governs transportation, the term “transportation” is defined as including “storage incident to transportation.” Consequently, the wise safety manager should consider reviewing the segregation requirements outlined within this important reference. A quick review of the segregation table in 49 CFR §177.848 reveals that flammable gases of Class 2.1 (which includes most Level Two and Level Three aerosols) may not be loaded, transported or stored together in the same transport vehicle or storage facility during the course of transportation with high explosives of Divisions 1.1, 1.2 or 1.3; Blasting Agents of Division 1.5; and certain toxic gases of Class 2.3. Additionally, these materials may not be loaded, transported or stored together in the same transport vehicle or storage facility during the course of transportation unless separated in a manner that, in the event of leakage from packages under conditions normally incident to transportation, commingling of hazardous materials would not occur. Sounds easy enough. However, when you review the requirements of 49 CFR §176.83(b), the segregation requirements for ocean transport are a bit more restrictive. Class 2.1 flammable gases must be stowed “away from” or three meters (10 feet) from dangerous goods of Class 4.1 (flammable solids) and Class eight (corrosive liquids and solids). These articles must be stowed “separated from or six meters (20 feet) from dangerous goods of Classes 1.4, 1.6 (low explosives), 4.2 (spontaneously combustibles), 4.3 (water reactive materials), 5.2 (organic peroxides), and radioactive materials of Class seven. Flammable gases must be stowed 24 meters (80 feet) from incompatible dangerous goods in Classes 1.1, 1.2, 1.3 and 1.5 (high explosives and blasting agents), and 6.2 (infectious substances).” The use of the more restrictive segregation table in 49 CFR §176.83(b) may offer some good guidance on separating incompatible goods, thereby preventing dangerous interactions and possible catastrophes like the one that so unfortunately occurred in August. For questions regarding the segregation of dangerous goods in storage or transit, or to receive a copy of these segregation tables, contact the author by e-mail: steve@shipmate.com or by phone at (310) 370-3600. SPRAY
Spray October2015
To see the actual publication please follow the link above