Training: A Code Requirement AND Key to Safety

A TRENDING PROBLEM

Are you experiencing extended downtimes due to the inability of your personnel to troubleshoot combustion systems? Are new technologies resulting in increased outsourced service calls because your people are not aware of how to address it? You are not alone; this is a common trend among many industries, manufacturers and facilities. So, how are these issues to be remedied? The answer is simple and stated directly within the national and international standards: training. Training is a regular component of any business; you are trained in how to do your job, to operate equipment, on processes and more. It is how we learn to function within our working lives. For industrial settings, training is imperative to safety, success and daily efficiency. It’s so imperative that U.S. and International Codes and Standards such as NFPA 86 (Standard for Ovens and Furnaces) and EN 746 (European Standard for Industrial Thermoprocessing Equipment), actually list requirements to be met on an annual basis regarding employee education. As codes are developed to outline the minimum standards required by law, it’s obvious that authorities recognize training is not just fundamental for knowing how to do your job; it’s an ongoing effort that must be enforced to ensure that you are performing your job duties safely.

NFPA 86 applies to ovens, dryers, furnaces, thermal oxidizers and any other heated enclosure used for processing materials. This includes equipment utilizing fuel gases such as natural gas or petroleum, liquid fuels, oxy-fuel and many others. NFPA 86 specifically states [Figure 1] that personnel who operate, maintain or supervise the oven or furnace shall be thoroughly instructed and trained in their job functions, demonstrate an understanding of safe operation procedures, be kept current with changes in the equipment and operating procedures, and shall receive regular refresher training. EN 746-1, Section 6.4.9 also states that “personnel operating the equipment shall be trained and competent in the operation of the equipment and in the hazards associated with the process, and their prevention.” Based on these legal requirements, the question now remains: Are you receiving and/or conducting the proper training?

Figure 2: Training Requirements as outlined by EN 746-1.

Figure 2: Training Requirements as outlined by EN 746-1.

Figure 1: Training Requirements as outlined by NFPA 86: Standard for Ovens and Furnaces, 2011.

Figure 1: Training Requirements as outlined by NFPA 86: Standard for Ovens and Furnaces, 2011.

It’s quite common within corporations and at individual facilities to overlook something like training. Do you remember the last time you or your colleagues received instruction related to combustion or the equipment?Production and daily responsibilities take priority, budgets are limited and new hire on-boarding is often thought to be sufficient. Since it’s required for your OEM’s to provide training on the new oven, furnace or boiler when installed, that information is also thought to be adequate preparation for its operation and it is usually dispersed to other operators as transitions are made. This information may not be accurate, though, as it can be diluted during employee training if not preserved in a formal program or document. As OEM’s don’t return to installation sites to educate on any changes in the National Codes and Standards or equipment either, the initial training may not meet current standards or address recent changes in national and international regulations. As stated by the National Board of Boiler and Pressure Vessel Inspectors in the 2002 Bulletin, Volume 57, Number 2, “of the 23,338 accidents recorded over the past ten years, 83 percent were a direct result of human oversight or lack of knowledge.” So the majority of tragic and costly industrial accidents include human error as part of the root cause, when most of these occurrences could have been prevented if hazards were recognized and proper safety measures were known and taken.

 

WHAT WE FIND

Some of the most common overlooked hidden hazards that CEC Combustion Safety’s Auditors have found after conducting thousands of inspections a year on all different types of fuel-fired equipment are:

Figure 3: Hidden hazards found most commonly during CEC Combustion Safety’s site(s) audits.

Figure 3: Hidden hazards found most commonly during CEC Combustion Safety’s site(s) audits.

  • Lubricated plug valves that are not being maintained
  • Jumper wires
  • Incorrect venting
  • Lack of safety interlock and valve tightness testing
  • Emergency shut off valves that are not labeled
  • Bent or broken safety relief handles
  • Disconnected or crimped sensing lines for safety devices

These hazards present an immediate risk. They are usually found on more than one piece of equipment within a facility, but are frequently ignored even though they have a direct correlation to the operation and safety of equipment and staff. As shown in [Figure 3]:

  • Jumper wires can bypass safety devices or system requirements for efficient operation, allowing for unburned fuel to accumulate, which could result in a fire or explosion.
  • Lubricated plug valves seal by virtue of the sealant that is within them, if they aren’t being maintained or lubricated with the correct sealant, gas may leak past the valve seat downstream into the fuel train piping or through the stem into the atmosphere, just waiting or an ignition source.
  • Incorrectly vented gas train components including vent valves, regulators, pressure switches, and relief devices also may allow for a release of gas into the workplace atmosphere.

These are a sampling of hidden dangers that go unnoticed on a daily basis because maintenance personnel, managers and other employees do not know what to look for.

Moreover, it’s often discovered that many organizations don’t have regular training programs. The programs that are in place may not be executed by qualified instructors and the material may not be accurate or targeted to be relevant. Additionally, with high turnover rates, new hires are being expedited through processes and are commonly not provided with information considered to be comprehensive according to the Codes and Standards. A major component required by the Codes and Standards regarding training programs is that they must be documented, and it has also been found that the majority of organizations with a program in place have little to no documentation for the program itself or those that complete it.

Documentation is not just considered a basic outline of the program either. Program records must be detailed, as the regulation to verify all standard training procedures is an NFPA requirement. This requirement is enforced by any authorities having jurisdiction (AHJ), ISO 14001, the standard for environmental management systems, and OHSAS 18001. OHSAS 18001 is a safety assessment series above the OSHA standard developed to establish criteria against which to be certified and assessed in order to control occupational safety and health risks. On a more personal level, certifications must also be upheld throughout the years, and 80% of the requirements to retain them are based on training. This means that program proof must be supplied and must specify the processes involved, annual frequency, course instructor identification, method of material delivery, documentation processes and the continuation of a program for a 5 year minimum to sustain compliance.

 

CORRECTIVE ACTION

The task to meet NFPA 86 and other standards’ requirements can seem overwhelming, but it is necessary, and quick corrective action can be taken to become compliant. There are many avenues that can be approached for providing combustion system training. These different methods for training include:

Figure 4: Combustion Training Workshop Open Course at Eclipse, Inc. in Rockford, IL, March 2013.

Figure 4: Combustion Workshop Open Course at Eclipse, Inc. in Rockford, IL, March 2013.

  • Attendance to professional programs like open courses or combustion workshops can start you on the path towards compliance and provide you and your staff with the documentation needed to supply proof of completion. There are a variety of organizations that conduct equipment specific operator training. Others can come to your site to provide customized training for your facility and its fuel fired equipment.
  • Online programs are available that are accessible 24/7 and all personnel can engage at their convenience from any computer with an internet connection.
  • Ensure that your OEMs are providing the required training upon installation of a new ovens, furnaces and boilers as well. The key isto find a credible vendor that has in depth knowledge on the codes, standards, combustion equipment and its operation.
  • Develop your own program, consult the experts before assuming it meetsNFPA 86 or EN 746 requirements and be certain that the curriculum encompasses general safety knowledge, equipment operation, Code protocols and that all personnel are on a schedule to participate on a yearly basis.

Along with that, reinforcement is a necessity and should be incorporated into preventative maintenance programs, within startup systems or through shorter refresher courses that are carried out annually.

Beyond the lawful requirement, the benefits of a strong training program are long lasting and invaluable. Thorough training dramatically reduces the risk of experiencing a combustion related accident, it enhances safety efforts overall and can help to cut costs and save energy. Rather than hiring outside contractors, in-house personnel who are already familiar with the equipment can be trusted with identifying hazards and performing regular maintenance so problems can be diagnosed and repaired faster. Reduced maintenance time and recognized defects lead to better fuel efficiency and operations. As more personnel receive training, sites experience reductions in interruptions, outages and downtime. And more than that, they remain compliant with the National Codes and Standards while people and equipment are better protected.

Training isn’t a responsibility to be taken lightly; it’s a legal fulfillment required in any industrial setting. An effective and compliant program requires time, research, continuous improvement and participation by dedicated team members as well as the participants. The importance of proper training can’t be discounted, as it’s not just knowledge that is at risk; it’s the safety of the facility and personnel that work within it that really drive why the National Codes and Standards such as NFPA 86 mandate a formal training program, completed on an annual basis. Not just one minor equipment issue can cause a disastrous event, its multiple hidden issues that have a domino effect and human error is usually the final additive to bring about a tragedy, production disruption, or other business and life threatening events. Verify your organization’s training platform, investigate the curriculum and research what outside vendors may offer courses to help you satisfy your annual responsibility. Allocate time and money for a training program and you will receive a much greater return on your investment, paybacks that are immediately evident.

 

Honeywell Combustion Safety has been in business since 1984. With engineers and staff members that sit on Code committees such as NFPA 56, NFPA 85, NFPA 86, and NFPA 87, our inside expertise is integrated within all of our practices and our global reach ensures that customers around the world are kept safe. Honeywell Combustion Safety offers Testing and Inspections, Engineering & Upgrades/Retrofits, Gas Hazards Management, Training, and Field Services for all industrial facilities and different types of fuel fired equipment. Contact Honeywell Combustion Safety at +1 216.749.2992 or visit www.combustionsafety.com for additional information.

 

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*This article was featured in Process-Heating Magazine

Published on August 21, 2013