Increased regulatory scrutiny and the growing emphasis on process safety management have spurred a steady relocation of equipment from production room floors, freezers and coolers to facility rooftops. The reasons for the transition have been practical. Moving equipment to a roof allows a facility to expand by taking advantage of the “free real estate” offered by a building’s rooftop footprint. And safety benefits – like eliminating the potential for pipes to be struck by handling equipment or minimizing exposure – limit liability in an era marked by federal oversight initiatives like OSHA’s national emphasis program.

While facilities may be doing everything right when it comes to moving equipment to the roof, they may be overlooking a seemingly innocuous detail that OSHA has begun to focus on: the methods of egress.

When equipment on a roof requires any kind of routine maintenance, fixed industrial ladders, which have commonly been used by the industry to provide access to the roof, are no longer sufficient.

And in most cases, relocation of equipment to a rooftop has created the need for routine maintenance, leaving facilities that have only fixed ladders vulnerable to OSHA citations.

“We’ve always had equipment on the roof, but in the past, it hasn’t been equipment that requires routine maintenance,” said Bryan Haywood, PSM consultant and president of the Safety Engineering Network. “Now that equipment on the roof has grown in volume and complexity, the situation is different. IIAR and every RAGAGAP out there require that routine maintenance be performed, so the question becomes: how do you configure stairs and ladders to accommodate that maintenance?”

OSHA’s answer, it appears, is simple: where routine maintenance is required, so are fixed industrial stairs.

“Most people know that fixed industrial stairs are a good idea, but not many people know that there is an OSHA standard that actually requires them,” said Peter Jordan, president of MBD Risk Management Services. “If you have personnel on that roof once a day, you’d have a hard time reading the OSHA standard and saying you don’t need fixed stairs.”

“The bottom line is that if you have equipment on the roof that requires routine maintenance, OSHA is paying attention to this issue. They’re going to see it.”

The issue of egress is most likely to come up with OSHA during a routine PSM inspection, and, ironically, the relocation of equipment to the rooftop – which in turn creates a requirement for fixed stairs – is most often driven by a desire to meet a PSM program. However, the OSHA standard that requires fixed industrial stairs is not a PSM requirement.

“The citations we’re seeing from OSHA are not being made under PSM, they are made under 1910.24(b), the agency’s standard for industrial stairs,” said Haywood.

To better understand what this may mean to a facility, Haywood suggested a thorough study of standard 1910.24 “Fixed Industrial Stairs,” and its requirements, as follows: 1910.24(b) states…

“Where fixed stairs are required.” Fixed stairs shall be provided for access from one structure level to another where operations necessitate regular travel between levels, and for access to operating platforms at any equipment which requires attention routinely during operations.

“As you can see, it is pretty clear that a process that places its piping and other components that require attention routinely during operations on a roof will be required to have fi xed industrial stairs for access to their roof areas,” said Haywood, adding that if the fi rst portion of the section is not convincing enough, the second part provides more examples of when fixed industrial stairs are required…

Fixed stairs shall also be provided where access to elevations is daily or at each shift for such purposes as gauging, inspection, regular maintenance, etc., where such work may expose employees to acids, caustics, gases, or other harmful substances, or for which purposes the carrying of tools or equipment by hand is normally required. (It is not the intent of this section to preclude the use of fixed ladders for access to elevated tanks, towers, and similar structures, overhead traveling cranes, etc., where the use of fixed ladders is common practice.)

“I am sure someone could argue at some point that their processes do not meet any of these requirements,” said Haywood. “However, if your facility has daily or shift rounds to be made (normal practice in PSM/RMP processes) we need industrial stairs to access the roof. Even if we do not make daily or shift rounds, but workers have to go up on the roof to operate valves or perform maintenance on a regular basis, then we are required to have fixed industrial stairs.”

Haywood also pointed out that 1910.37 requirements come into play . . .

1910.37(a)(3) Exit routes must be free and unobstructed. No materials or equipment may be placed, either permanently or temporarily, within the exit route. The exit access must not go through a room that can be locked, such as a bathroom, to reach an exit or exit discharge, nor may it lead into a dead-end corridor. Stairs or a ramp must be provided where the exit route is not substantially level.

Fixed ladders that meet 1910.27 may be used for “emergency egress” in some situations, said Haywood, who added that he refers to OSHA’s Standard Directive “STD 01-01-012 – Application of 29 CFR 1910.27, Fixed Ladders Used in Emergency Situations (6/20/1983)” to help explain when fixed ladders can be used as a means for emergency egress. In that directive, OSHA states…

This instruction provides performance criteria for fixed ladders used only as a means of access for firefighters and other emergency personnel, or escape for employees in fire and other emergency situations.

1. Employers must establish and implement adequate administrative controls such as barricades and signs to prevent nonemergency use of fixed ladders which are meant for firefighter use and emergency escape only.
2. In the event the employer does not provide adequate administrative controls such as barricades or signs and employees use an emergency ladder for other than its intended purpose, the employer may be appropriately cited under 29 CFR 1910.27.
3. Fixed ladders not equipped with cages, landing platforms, ladder safety devices, or other forms of employee protection, in some situations may be allowed as a means of access for firefighters and other emergency personnel, or escape for employees in fire and other emergency situations. These guidelines are provided because it may be more hazardous to comply with 29 CFR 1910.27 than not to comply.

Regardless of where and how specific OSHA regulations surrounding stairs apply to an individual facility, the bottom line is that fixed stairs are almost always required when a large volume of equipment is on the roof, said Haywood.

“Moving equipment to the rooftop is safer for our equipment, but it also increases the risks to the workers who have to routinely access the equipment and perform high-risk activities with limited means of egress. Emergency egress is nothing to sneeze at, and it becomes doubly important when we have workers on a rooftop with highly hazardous chemicals.”

And that, he said, should be the biggest consideration for a business that is considering moving equipment to a roof, or already has equipment in place. “If they’ve made this change, or if they’re thinking about making this change, they may need to revisit their project in light of the OSHA requirement to ensure they have not created an egress issue,” he said.

Agency Issues Clarification on Hydrostatic Relief

The International Institute of Ammonia Refrigeration recently received clarification from the Occupational Safety and Health Administration on an ongoing question surrounding OSHA’s requirement for hydrostatic relief for various pieces of equipment, especially evaporative condensers.

The issue was originally represented in an OSHA statement known as “the Palmer letter” which stated OSHA’s position that hydrostatic relief is required when equipment containing liquid refrigerant can be isolated.

However, a few years ago, the agency unofficially noted that administrative controls, i.e. the use of trained operators, are acceptable when isolating equipment as outlined in IIAR-2. Nevertheless, OSHA did not officially revise its position and the interpretation remained on the agency’s website.

The inconsistency created confusion about OSHA’s requirement, and IIAR pursued OSHA to encourage the agency to make an official decision on the issue.

As a result of IIAR’s communication on the subject, OSHA issued a notification that it will remove its requirement for hydrostatic relief, provided that administrative controls are used for isolation, as outlined in IIAR-2.

OSHA’s decision to remove the requirement was an important recognition of the relevance of IIAR standards to the industry and the agency, said IIAR’s Government Relations Director, Lowell Randel.

“This is a great example of how IIAR has been working with OSHA to inform them of IIAR standards and influence policy where standards are addressed by the agency,” said Randel. “OSHA’s response to IIAR highlights what the change means as far as how it applies to our standards, and showcases the proactive work that IIAR is doing with the agency.”

Randel added that the collaboration represents an effort by IIAR to work with OSHA to inform the agency of IIAR standards and influence policy where those standards are addressed.

“This is a success story for both OSHA and IIAR where IIAR was able to go directly to OSHA and explain issues the industry had with an official interpretation. Now we’ve seen direct changes as a result of that back and forth communication,” he said. “Because we’ve been able to develop good relationships with OSHA, we can discuss these kinds of issues and come to a resolution.”

The technical details behind OSHA’s notification on this issue are discussed in greater length in the “Technical Department” column in this issue of the Condenser. OSHA’s notification and its current interpretation of requirements can be found on the IIAR website at www.iiar.org.