Tagged: Alberta and British Columbia
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Does the transfer of flammable fluids with trucks constitute hot work’ The flammable substance is either being loaded or unloaded. In either case the internal combustion engine (introducing a combustion engine to a work process) which is in close proximity to the trucks tanks is required to run the pump. What regulations would define this or is there an exemption for trucks’ Reading a number of different articles it seems that there may be some legal exemption if the engine is on wheels. Under section 9.4 of the OHSInsider’s Model Hot Work Policy section 9.4 it states “where the internal combustion engine is not a vehicle powered by an internal combustion engine” Why is this specified this way’ Do vehicles have an exemption and if so where does it state this?
Long story short: Hot Work requirements apply but not the special precautions in Section 9.4. In other words, comply with Section 11 rather than Sec. 9.4 of Model Policy.
Here’s the breakdown and explanation that I hope answers your Qs.
Section 9.4 of the Model Policy refers to the additional precautions required, i.e., combustion air intake or exhaust discharge with flame arresting device or located outside “hazardous location” (I’ve pasted in the definition of “hazardous location” below) under Sec. 166 of the Alberta OHS Code when internal combustion engines are located in or near a hazardous location. But those precautions DON’T apply to a vehicle powered by an internal combustion engine. (Sec. 166(3)). That would be the case in the situation you describe.
What you would have to do is ensure that such vehicle is not located or operated in a hazardous location except in accordance with the Hot Work requirements contained in section 169 of the OHS Code–Section 11 of the Model Policy.
And here’s the key definition you need to apply the above, which is also contained in the Model Policy.
“Hazardous location” means a place where fire or explosion hazards may exist due to flammable gases
or vapours, flammable or combustible liquids, combustible dust or ignitable fibres, or flyings, as
described in the Canadian Electrical Code;
Hope that helps. GlennI think I might have misread your Q. To the extent you’re talking about ANOTHER internal combustion engine external to the trucks located near the tanks, the answer is YES, the combustion air intake or exhaust discharge with flame arresting device or located outside “hazardous location” would be required in accordance with Section 166 of the OHS Code and Sec. 9.4 of the Model Policy. My previous response was based on my understanding–which may have been wrong–that the engine you were referring to was the truck’s engine. Sorry for the confusion.
Hi Glenn. Sorry if my question was hard to follow. My specific question is when a trucks motor (internal combustion) is in the hazard area and running to transfer the fluids – is that hot work’ Or is there an exemption for truck loading. Hope that helps more.
Okay, I read you. Yes, that WOULD BE hot work. Here’s the definition from the OHS Code–check out subsection (c):
“hot work” means work in which a flame is used or sparks or other sources of
ignition may be produced, including
(a) cutting, welding, burning, air gouging, riveting, drilling, grinding and chipping,
(b) using electrical equipment not classified for use in a hazardous location, and
(c) introducing a combustion engine to a work process; -
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