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August 2003
Full contents

Understand basic engineering codes

Here’s an overview of the nature, use and limitations of US industrial standards

H. W. COOPER, CodeLamp Corp., Jericho, New York

Comments? Write:
editorial@HydrocarbonProcessing.com

Process safety and risk management programs, safety audits and similar activities are being
increasingly used in the US within the industrial sector, and are leading to a safer workplace. The
incidence of workplace injuries and illnesses in the goods-producing sector of private industry
has dropped each year, from 9.9/100 full-time workers in 1997 to 7.9 in 2001.1

The benefits these programs bring are possibly even more significant considering industry's
increasingly severe processing conditions (temperatures, pressures, corrosivity) and increasingly
complex operations of new facilities, and the aging of existing ones.

Many serious safety-related problems can be avoided by fully complying with the provisions of
appropriate codes and standards that have been developed, made widely available and adopted
as requirements by private and governmental organizations. Full compliance is usually required
to obtain the necessary construction and operating permits as well as adequate insurance
coverage.

Unfortunately, design, construction and operational flaws continue to lead to fatalities, disabilities
and serious property losses every year. Annually, approximately 5,000 workplace fatalities occur
in the US, other than from homicides.1 Within the industrial and manufacturing sector, there are
approximately 17,000 fires/year, causing 20 fatalities, 550 serious injuries and a direct economic
loss (excluding those from the Sept. 11, 2001, World Trade Center attack) of approximately $7.8
billion in the US.2

In response to financial pressures, many companies are losing experienced engineering staff by
attrition or reduction-in-force, and are adjusting by increasing their outsourcing of critical
activities. Although the subcontractors may understand safety issues and indicate that they have
manuals, training programs and procedures, responsibility for plant safety remains with plant
management. In many cases, however, they unfortunately have not internalized the knowledge
necessary to effectively oversee safety aspects of subcontractors' performance. Quite possibly,
therefore, workplace safety might not continue to improve. It may even deteriorate, with
occasionally devastating consequences.

An overview of the nature, use and limitations of codes follows, intended to help orient new and
infrequent code users in the HPI.

Many serious safety-related problems can be avoided

by fully complying with provisions of appropriate
codes and standards that have been developed, made
widely available and adopted as requirements by
private and governmental organizations.

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Definition of terms. Succinctly put by the International Organization for Standardization (ISO):3

"Standards are documented agreements containing technical specifications or other precise

criteria to be used consistently as rules, guidelines, or definitions of characteristics, to ensure that
materials, products, processes and services are fit for their purposes."

Standards are documents whose requirements may be met on a voluntary basis unless and until
they are incorporated into a governmental regulation. Codes, as discussed below, are legal
requirements.

Related classes of documents are recommended practices and guidelines. These normally
present material that, while not codified and not quite a standard, has been found to be helpful
and may be used voluntarily - or may be ignored.

System and equipment design engineers servicing the process industries are most interested in
the codes, standards, recommended practices and guidelines that have been developed to
define the properties and testing of materials of construction, and the design, installation and
testing of complete equipment assemblies and facilities. Personnel in companies that produce or
process materials such as oil, chemicals, foods or metals are generally interested in additional
documents that cover lockout/tagout, entering confined spaces, product testing, emission testing,
and mandated reporting of emissions, discharges and accidents to appropriate governmental
agencies. Requirements for risk management programs and testing of mechanical integrity also
must be properly addressed. A particular document may cover one or more of these.

Code producers. At the federal level, Congress passes an act (law), whose text is a public
statute. Certain governmental agencies, such as the following, are authorized to create
regulations. These are the specific rules necessary to put the law into practice and define what is
legal and what is illegal. While each state and local municipality may promulgate regulations,
minimum technical requirements that have major impacts on the industrial sector generally arise
from three US agencies:

Environmental Protection Agency (EPA). It is a large agency with a $7.72 billion budget and
a staff of almost 18,000.4 It has passed a great many rules, many of which are very complex,
covering allowable compositions and quantities of gaseous emissions, liquid discharges and solid
wastes, test methods and reporting requirements. EPA regulations may be found in the Code of
Federal Regulations (CFR) Title 40 Protection of Environment. They include, as an example,
design and testing requirements for emission- and accidental release-control for storage tanks.

Occupational Safety and Health Administration (OSHA) of the Department of Labor. The
OSHA is a mid-sized government agency with an annual budget of approximately $445 million.5
It has focused largely on preventing and reporting accidents in the workplace, and conducts
about 36,000 inspections per year.5 OSHA regulations may be found in CFR Title 29 Labor.
Typical rules are related to signage, safety harnesses, safety guards, cages for ladders, lockout
of equipment being inspected, exposure to chemicals, respirator systems, accident reporting and
the like. Plant design engineers and operating staff are strongly affected by OSHA rules covering
exposure to noise and to hazardous materials.

In broad terms, where the EPA and OSHA cover the same situations, their technical
requirements are the same. The EPA, however, is generally concerned with a plant's impact
outside of its boundaries, while OSHA is generally concerned with activities within the plant's
boundaries.

The Department of Transportation (DOT). It is a very large government agency with a 2002
budget of approximately $58.4 billion dollars and 61,000 employees. It is responsible for the
safety of interstate transportation, including aviation, highway and pipelines. See CFR Title 49
Transportation for its regulations. The DOT regulates, among other items, the design, maximum
allowable filling densities, relief valves, loading and unloading of cylinders, portable tanks and

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tank cars.

Requirements for transporting hazardous materials are detailed in 49 CFR 179. These include
considerations of thermal protection, venting and safety relief, materials of construction and
insulation. The DOT's Office of Pipeline Safety has issued regulations pertaining to design,
testing and operating the pipelines that transport liquids and gases throughout the US. These
may be found in 49 CFR Parts 186-199. The US Coast Guard, which regulates various safety
aspects of water-borne shipping, has been transferred in November 2002, together with the
Transportation Security Administration, to the new Department of Homeland Security.

Standards producers. Nongovernmental agencies have historically had a major role in

developing standards. Many not-for-profit bodies have committees that focus on detailed design,
inspection, installation and operating requirements for rather narrow well-defined equipment,
processes or situations in their specific sector. These bodies' members frequently have
experience and expertise not present in governmental agencies.

Their standards are generally accepted since they follow the procedural requirements of the
American National Standards Institute (ANSI).6 All affected parties may provide input, and
decisions are arrived at transparently by consensus. The following sample includes
representative specialized major industrial standards-writing groups; there are hundreds of
others.

American Petroleum Institute (API)

American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc.
(ASHRAE)

American Society of Mechanical Engineers (ASME)

ASTM International (formerly American Society for Testing and Materials (ASTM)

The Chlorine Institute

Compressed Gas Association (CGA)

National Association of Corrosion Engineers (NACE)

National Fire Protection Association (NFPA)

Petroleum Equipment Institute (PEI)

Steel Tank Institute (STI)

Underwriters Laboratories Inc. (UL).

The standards produced by these nongovernmental agencies are not legal documents and have
no legal standing until and unless adopted by governmental bodies. Many industrial standards
are "incorporated by reference" in laws. They thus take on a legal status and become codes.

For example, use of NFPA 37 has become a legal requirement since 29 CFR 1910.110(b) (20)
[OSHA requirements for appliances] (iv)(c) states:

"All commercial, industrial and agricultural appliances or equipment shall be installed in

accordance with the requirements of . . . (c) Standard for the installation and use of Stationary
Combustion Engines and Gas Turbines-NFPA 37-1970."

As another example, an electrical system that does not conform to the NFPA 70 National Electric
Code is very likely not to meet the requirements of state and local ordinances and is thus illegal.

Components of standards and codes. Although there are legal differences, for brevity, the
terms "codes" and "standards" will be used interchangeably in what follows.

They will contain the Effective Date and the Edition, presenting the date of adoption of the
promulgating body. Individual codes are revised periodically to reflect new technological
demands, newly available materials, systems or analytical capabilities, and changed consensus

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on appropriate requirements. Codes are now also being revised to reflect the preferred style of
ISO.

It is not unusual for the code-writing body to issue errata and/or clarifications. You must obtain
and review them to help assure the safety of your project.

Importantly, many jurisdictions, including OSHA and local building departments, require use of a
particular edition, even though it is not the latest one. This may lead to conflicts or omission of
provisions incorporated in the latest versions. For example, the OSHA regulations for installing a
stationary combustion engine or gas turbine discussed above require adherence to the
provisions of the 1970 edition of NFPA 37; the current edition is that of 1998.

All codes contain a Scope, which may be a few sentences or may be many paragraphs. For
example, NFPA 30 (Flammable and Combustible Liquids Code) contains:

1.1 Scope.

1.1.1* This code shall apply to the storage, handling, and use of flammable and combustible
liquids, including waste liquids, as herein defined and classified.

The Scope then continues with:

1.1.2 This code shall not apply to the following:

(1)* Any liquid that has a melting point equal to or greater than 100°F (37.7°C) . . .

(2) Any liquefied gas or cryogenic liquid as defined in . . ., etc.

Scope thus defines both what is covered and what is specifically excluded. (The "*" refers to
material included in explanatory material in an appendix that is not part of the requirements but is
included only for informational purposes.)

Officials (authorities having jurisdiction) must have discretion to approve systems, methods or
devices that are equivalent or superior to those prescribed in the code. They also need the
discretion to impose more stringent requirements to meet special situations where appropriate.
These are normally accommodated by an Equivalency provision found in many codes.

Definitions are important for avoiding ambiguity, confusion and misuse of requirements caused
by common usage and jargon that differs from one industrial sector to another, particularly where
common words are used.

For example, within NFPA 30, a container and a storage tank are precisely distinguished from
each other. A container is defined as, "Any vessel of 60 gal (227 l) or less capacity used for
transporting or storing liquids". A storage tank is defined as, "Any vessel having a liquid capacity
that exceeds 60 gal (227 l), is intended for fixed installation, and is not used for processing".
Atmospheric tanks and low-pressure tanks are, likewise, carefully defined in terms of the
maximum internal design pressure.

Process plant and utility power-plant designers and operators are likely to consider a boiler
generating 200-psig steam to be a low pressure boiler. In fact, a low pressure boiler is defined in
NFPA 31 (Standard for the Installation of Oil-Burning Equipment) as one for generating steam at
pressures not in excess of 15 psig or for furnishing water at a maximum temperature of 250°F at
a maximum gage pressure of 160 psi.

One potential pitfall is that the same word may be defined one way in one code and another way
in a different code. Definitions of two terms by OSHA and within NFPA 30 are shown in Table 1.

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TABLE 1. Comparison of definitions

Item OSHA - 29 CFR 1926.64 (b) NFPA 30 - 2000 Ed.

Atmospheric . . . designed to operate at pressures . . . designed to operate at

tank from atmospheric through 0.5 psig. pressures from atmospheric through
1.0 psig . . . measured at the top of
the tank.

Boiling point . . . the 10% point of a distillation . . . the 20% evaporated point of a
performed in accordance with. . . distillation performed in accordance
ASTM D86-62. with ASTM D86.

The numerical differences are not trivial. They lead, for example, to different technical
requirements for gasoline storage tanks. You absolutely must, therefore, always review the
Definition of terms that is included in virtually all codes.

The bulk of any code is its Requirements. These are most often prescriptive, having the form: If
the situation is "A", then you must do (or not do) "B".

Here's an example from 2.2.7.4.1 of NFPA 30: "Vent pipes that are provided for normal tank [in
an aboveground vault] venting shall terminate outside and at least 12 ft (3.6 m) above ground
level."

Less specific rules are occasionally encountered, often of the form: If the situation is "C", then
you must consider "D".

Here's an example from 2.2.5.2.2 of NFPA 30 regarding emergency relief venting: "If unstable
liquids are stored, the effects of heat or gas resulting from polymerization, decomposition,
condensation, or self-reactivity shall be taken into account." There is, however, no indication of
how to take these effects into account.

Codes often contain Appendices (or Annexes) that present explanatory material and/or
recommended practices. An appendix may be part of the requirements, or may be included for
informational purposes only and its contents not required. Additionally, codes may include a
Referenced Publications section that lists all publications referred to in the requirements.

Using codes. Codes may be difficult to use for several reasons. Often the subject they cover is
inherently complex. For example, NFPA 31 (Standard for the Installation of Oil-Burning
Equipment - 2001 Ed.) is an example of an average code, consisting of 52 two-column pages of
text, 19 tables and 15 diagrams. It applies to industrial-, commercial- and residential-type steam,
hot water or warm air heating plants; domestic-type range burners and space heaters; and
portable oil-burning equipment, all accessory equipment and control systems, and all electrical
wiring connected to oil-fired equipment.

It also applies to installing oil storage and supply systems connected to oil-fired equipment and to
multifueled appliances in which fuel oil is one of the optional fuels. For this wide range of
equipment, it presents requirements and prohibitions for fuels, air for combustion and ventilation,
venting of flue gases, fuel oil tanks, piping systems and components, and installation.

The International Boiler and Pressure Vessel Code of the ASME is a prime example of an
extremely comprehensive and complex code, consisting of 11 sections in 30 volumes. The cost
is $7,900 for a printed copy of the complete set.7 It presents requirements for virtually all aspects
of the materials of construction, design, fabrication, testing and installation of boilers and
pressure vessels.

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A useful expert system is available that asks questions interactively, evaluates your answers and
immediately produces a report containing the verbatim text of only the sections of various code
documents that apply to your specific project.8

Sections of codes frequently refer to other sections of the same code or to a second code with or
without specific sections being indicated. The second code may then refer to various sections of
itself or additional codes. You may, therefore, spend hours, days, months or years reviewing all
mentioned requirements. This is, of course, impractical. At some point you must rely on your own
judgment or that of more experienced individuals or perhaps outsiders such as a governmental
agency's staff member, the Help Desk offered by professional societies or reputable equipment
vendors.

A large amount of data such as physical and chemical properties, plant and equipment
dimensions, and building characteristics may be required. Table 2 presents, as an example, a
complete list of all of the liquid properties required for evaluating all of the requirements of NFPA
30.

TABLE 2. Physical properties required by NFPA 30

? API gravity ? Melting point

? Boiling point ? Molecular weight
? Boil-over prone? (Yes/No) ? Rate of burning
? Fire point ? Reactivity degree hazard rating
? Flammability limit - lower ? Specific gravity
? Flammability limit - upper ? Stable or unstable?
? Flash point ? Vapor pressure at 100ºF
? Gel, thicken or solidify when heated? (Yes/No) ? Vapor pressure vs. temperature
? Health degree hazard rating ? Viscosity
? Heat of combustion ? Water-miscible? (Yes/No)
? Latent heat of vaporization (at boiling point) ? Water-reactive? (Yes/No)

Many collections of specialized data are available in addition to those contained in traditional
handbooks. For example, the NFPA publishes two documents9,10 containing properties related to
fire protection and a tabulation of hazardous chemical reactions.11 The AIChE publishes an
extensive collection of physical properties in hard copy and electronic format.12

Although values of all required properties can be obtained in advance of applying a code such as
NFPA 30 to a specific project, the effort would most likely be needlessly time-consuming and
costly, since not all of them are required in all cases. The pertinent ones depend on the situation
being investigated.

You may encounter errors and inconsistencies in tables and databases of physical properties.
These are encountered frequently enough for the NFPA to have established a Physical and
Chemical Data Consistency Advisory Committee to review published values of properties such
as flash points and flammability limits and recommend changes where appropriate.

Which safety-related codes are used in the HPI? Although code applicability is project-
specific, Table 3 lists codes (and recommended practices) that are commonly encountered. The
hundreds of documents that specify chemical composition and physical properties of materials of
construction, while obviously also important, have not been included. Similarly, neither building
codes nor equipment testing standards nor standards of other countries have been included.

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TABLE 3. Frequently used codes

Organization Number Code title

ASHRAE 15 Safety Standard for Refrigeration Systems - 2001

ANSI B31.1 Power Piping - 2001
ANSI B31.3 Process Piping - 2002
ANSI B31.4 Pipeline Transportation Systems for Liquid Hydrocarbons and
Other Liquids - 2001
ANSI B31.5 Refrigeration Piping and Heat Transfer Components - 2001
ANSI B31.8 Gas Transmission and Distribution Piping Systems - 2000
API API 620 Recommended Rules for the Design and Construction of Large
Welded, Low Pressure Storage Tanks - 2002
API API 650 Welded Steel Tanks for Oil Storage - 1998
API API 653 Tank Inspection, Repair, alteration and Reconstruction - 2003
API RP-520 Sizing, Selection and Installation of Pressure Relieving Devices
in Refineries - 2000
ASME International Boiler and Pressure Vessel Code - 2001
Section VIII - Pressure Vessels
Section X - FRP Pressure Vessels
NACE RP 0169 Recommended Practice, Control of External Corrosion on
Underground or Submerged Metallic Piping Systems - 2002
NACE RP 0285 Recommended Practice, Corrosion Control of Underground
Storage Tank Systems by Cathodic Protection - 2002
NFPA NFPA 30 Flammable and Combustible Liquids Code - 2002
NFPA NFPA 31 Standard for the Installation of Oil-Burning Equipment - 2001
NFPA NFPA 37 Standard for the Installation and Use of Stationary Combustion
Engines and Gas Turbines - 1998
NFPA NFPA 54 National Fuel Gas Code - 1999
NFPA NFPA 58 LP-Gas Code - 1998
NFPA NFPA 68 Guide for Venting of Deflagrations - 1998
NFPA NFPA 69 Standard on Explosion Prevention Systems - 1997
NFPA NFPA 70 National Electric Code - 2002
NFPA NFPA 85 Boiler and Combustion Systems Hazards Code - 2001
PEI RP100 Recommended Practices for Installation of Underground Liquid
Storage Systems - 2000
STI F841.01 Standard for Dual Wall Underground Steel Storage Tanks -
2001
UL UL 58 Standard for Steel Underground Tanks for Flammable and
Combustible Liquids - 1996
UL UL 142 Standard for Steel Aboveground Tanks for Flammable and
Combustible Liquids - 2002
UL UL 2080 Standard for Fire Resistant Tanks for Flammable and
Combustible Liquids - 2000
UL UL 2085 Standard for Protected Aboveground Tanks for Flammable and
Combustible Liquids - 1997
UL UL 2244 Standard for Aboveground Flammable Liquid Tank Systems -
1999

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UL UL 2245 Standard for Below-Grade Vaults for Flammable and

Combustible Liquids - 1999

The text of federal and many state codes is very often available on their Websites. Copies of
documents produced by nongovernmental bodies are available from them either in print or
electronic formats. Although the latter can usually be searched for key words or phrases using
the popular word processing programs, nonexperts may miss requirements since they often do
not know what to search for. The expert system, previously mentioned, avoids this problem by
asking questions and evaluating your responses so that only relevant questions are asked, and
all sections of the particular code that pertain to your project have been considered.8

Many associations such as the ASME and the NFPA offer seminars on using their codes. The
best way to master a code is to join and actively participate in the committee responsible for its
development and support. The association's Website or membership office will provide the
appropriate contact information.

Which codes apply to my project? Since there are usually many ways to carry out any
process, a process flowsheet should always be developed as the first step. This should show all
process equipment and piping, with materials of construction, operating pressures, temperatures,
flowrates, and amounts of materials stored in tanks or bins. Relief valves, vents and drains must
also be included.

As you prepare your process flowsheet, several aspects of facility design and operation are
particularly noteworthy. Although not an absolute limitation, OSHA indicates (29 CFR 1910.119
App A) the threshold quantities for highly hazardous chemicals, toxics and reactives - above
which there is a potential for a catastrophic event. Many chemicals commonly used in the
process industries are included, such as acetaldehyde, chlorine, ethylene oxide and methyl
chloride.

There are, moreover, absolute limits to the amounts of many chemicals that may be stored in
buildings. For example, 29 CFR 1910.103 Subpart H (Hazardous Material - Hydrogen) presents
the requirements for storing hydrogen, including maximum quantities in various types of
buildings. Section 7.5.13 of NFPA 31, as another example, limits the amount of fuel oil in
buildings to 1,375, 10,000, 15,000 or 50,000 gallons depending on the building design. Section 7
of ASHRAE 15 restricts the quantity of refrigerants that may be kept in occupied spaces. There
are many additional examples of quantity limitations.

OSHA also defines legally permissible exposure levels to many chemicals. Those for benzene,
for example, are detailed in 29 CFR 1910.1028. Exposure limits recommended for numerous
chemicals by other groups are also available.13, 14, 15, 16

Certain safety design parameters are determined within codes. The minimum emergency relief
venting flowrate from aboveground storage tanks subject to fires, for example, depends on tank
dimensions, insulation, spray systems, drainage and dike arrangements and the stored liquid's
properties. The minimum venting rate for stable liquids can be calculated from section 2.2.5.2 of
NFPA 30. More complex methods, required for liquids that are reactive, are available from the
AIChE's Design Institute for Emergency Relief Systems.

Although you generally can select materials of construction based on convenience and economic
considerations, there are limits. As examples: NFPA 30 prohibits use of certain metals on tanks
storing Class IIIB liquids in diked areas; NFPA 37 requires that fuel piping to engines and gas
turbines to be steel or other metal; ASME B31.3 (323.4.2) enumerates various metallurgy that is
specifically unacceptable in process piping; ASHRAE 15 (9.1.2&9.1.3) enumerates various
metallurgy that is specifically unacceptable for contact with specific refrigerants. There are many
additional examples of materials limitations.

Valuable information about proper design and operation of many specific types of facilities is

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available from the not-for-profit trade groups. For example, the Compressed Gas Institute17
publishes guides for handling widely used gases such as acetylene, anhydrous ammonia,
hydrogen and oxygen. Information about safely handling chlorine, hydrogen chloride, sodium-
and potassium hydroxides and related compounds is available from The Chlorine Institute.18

In order to assess safety requirements, you will need to know, among other items:

How various physical areas of your installation have been classified; these are defined in
NFPA 70.

The fire classification of each flammable or combustible liquid in your project. These may
possibly be found in references 9 or 10, or may be calculated by the method presented in
NFPA 30 or by technique cited in reference 8.

Importantly, materials listed in 29 CFR 1910.119 App. A are, by OSHA definition, "Highly
Hazardous Chemicals." If you handle one of these materials, although the Applicability section
lists exemptions, you may be required to develop a Process Safety Management Plan and review
it every five years. This plan must include the electrical classification, and design codes and
standards employed (as well as provisions for confirming the mechanical integrity of equipment
such as vessels, pumps, piping systems, relief and vent systems, and emergency shutdown
systems). Similarly, the EPA's concern about chemical accident prevention has led to its General
Duty Clause of §112(r)(1) of the Clean Air Act. A Risk Management Plan is required under 40
CFR 68 Subpart G for facilities that process regulated toxic or flammable substances (listed in 40
CFR 68.130) or, even if not listed, other extremely hazardous substances.

Getting started. Although code applicability is quite project-specific, the following starting points
have been helpful. It will be useful and usually cost-effective to utilize the services of a
professional reference librarian. They have been educated to use a wide range of sources to find
information quickly and efficiently. Many have the background to assess the timeliness,
relevance, completeness and accuracy of their findings.

Locate any specific federal requirements related to the material you are processing or
storing. Search the US Code of Federal Regulations at www.CFR.gov using key words or
phrases that correspond to your product, process or device. Certainly include the OSHA
List of Highly Hazardous Chemicals (29 CFR 1910.119 Appendix A.) and the EPA list of
regulated toxic and flammable substances (40 CFR 68.130). Three other useful
governmental websites are www.DOT.gov, www.OSHA.gov and www.EPA.gov.

Search the Website of logical trade groups. For example, if your project involves handling
flammable petroleum products, it would be sensible to visit www.API.org for codes and
standards related to petroleum equipment and processing, www.STEELTANK.com for
information about requirements for steel tanks and www.NFPA.org for information about
fire protection.

If your project includes handling and storing flammable materials, always search the
Website of the National Fire Protection Association (www.NFPA.org).

Contact appropriate trade groups. Many of them have help-desks supported by
knowledgeable staffs.

Contact appropriate state and local regulatory agencies such as those with responsibility
for environmental protection, utility services such as water and electricity, and local
building and fire departments. In many cases, the codes of states and local agencies
contain requirements beyond those required by national codes. Local authorities-having-
jurisdiction often will also insist that you incorporate various devices or practices they have
found to be helpful, even though they are not specifically required by any code.

Discuss your project with your insurance carrier. Larger companies that provide coverage
for industrial facilities have knowledgeable staffs.

Discuss your project with equipment and raw material suppliers. They are likely to be
familiar with codes that apply to their products. You may, however, want them to first
execute a confidentiality agreement.

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After you have developed a list of project-specific applicable codes, it is critical to have qualified
competent engineers review it for completeness. Experience and judgment are required.

Your responsibilities. When you review a situation for safety or, more narrowly, for compliance
with a particular code, you have both legal and ethical responsibilities to fulfill.

We work in a litigious society, so if you have been involved, even remotely, in a project that has
experienced a loss of life, disabilities or economic losses, you should not be surprised to find
yourself subpoenaed as a witness or even as a defendant. You will serve your employer and
yourself best by bringing any design, testing, installation or operating deficiencies to the attention
of your supervisor, and/or the project manager.

If you are not satisfied with their response, you must go further. In fact, the National Society of
Professional Engineers makes this explicit in its Code of Ethics for Engineers. Part II (Rules of
Practice) 1.a states unambiguously:

"If engineers' judgment is overruled under circumstances that endanger life or property, they shall
notify their employer or client and such other authority as may be appropriate."

As unpleasant as they are, resignation and/or contacting governmental officials are options that
may be justified by the possibility that catastrophic situations will arise. Remember that, although
you may be ostracized within your company, "whistle blower" statutes legally protect you.

Once a deficiency is detected, it is important to carefully and clearly document it together with the
course of action you proposed, to whom you proposed it and on what date. If you foresee a life-
threatening or major property-loss situation arising, think defensively and develop an "audit trail,"
particularly if your advice is rejected. This may help with a proper resolution of the danger, or
may be critical for establishing that you did everything you reasonably could to avoid a
dangerous situation.

Probably most corporations and managers will act in a responsible way with respect to clear-cut
safety issues, as has been demonstrated by their having undertaken voluntary product recalls
and implementing Responsible Care programs for vetting and tracking the use of their products.

The country's reaction to the behavior of some in the energy and communications fields who may
have willingly wiped out their employees' and shareholders' lifetime savings for their own benefits
is having some positive effects. Many managers who are under strong pressure to produce
profits have absorbed lessons about importance of their personal and corporate reputations,
about an open two-way street communication policy, and about dealing straightforwardly with
bad news.

As long as you have a basic understanding of codes that apply to your facility and operations,
you will probably not be placed in a compromising position, and can have the satisfaction of
contributing to the safety of your coworkers, your community and society-at-large. HP

HELPFUL ABBREVIATIONS
AIChE American Institute of Chemical Engineers, New York, NY
ANSI American National Standards Institute, Washington, D.C.
API American Petroleum Institute, Washington, D.C.
App Appendix
ASHRAE American Society of Heating, Refrigerating and Air-Conditioning Engineers,
Atlanta, Georgia
ASME American Society of Mechanical Engineers, New York, NY
ASTM ASTM International (formerly the American Society for Testing and Materials),
Conshohocken, Pennsylvania

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CFR Code of Federal Regulations

CGA Compressed Gas Association, Chantilly, Virginia
DOT [US] Department of Transportation
EPA [US] Environmental Protection Agency
Gal US gallon
ISO International Organization for Standardization, Geneva, Switzerland
L Liter
NACE National Association of Corrosion Engineers, Houston, Texas
NFPA National Fire Protection Association, Quincy, Massachusetts
OSHA [US] Occupational Safety and Health Administration (part of the US Department
of Labor)
PEI Petroleum Equipment Institute, Tulsa, Oklahoma
psi Pounds per square inch
psig Pounds per square inch gauge
STI Steel Tank Institute, Lake Zurich, Illinois
UL Underwriters Laboratories Inc., Northbrook, Illinois

LITERATURE CITED

1 OSHA, Workplace Injuries and Illnesses in 2001, USDL 02-687.

2National Fire Protection Association, The U.S. Fire Problem Overview Report,
Quincy, Massachusetts, 2001, p. 156.

3SInternational Organization for Standardization, Website www.ISO.org, March

2003.

4 EPA, Website home page www.epa.gov, March 2003.

5 OSHA Website www.OSHA.gov, March 2002.

6 ANSI, Paper IC N2382, January 2002.

7 ASME Website, www.asme.org, March 2003.

8CodeLamp Corp., The Code Counselor, Website www.codelamp.com, March

2003.

9 National Fire Protection Association, NFPA 49, Hazardous Chemicals Data,

Quincy, Massachusetts, 1994.

10 National Fire Protection Association, NFPA 325, Fire Hazard Properties of

Flammable Liquids, Gases, and Volatile Solids, Quincy, Massachusetts, 1994.

11National Fire Protection Association, NFPA 491, Hazardous Chemical Reactions,

Quincy, Massachusetts, 1997

12AIChE project at the Thermodynamics Research Center of Texas A&M

University, ongoing project with several products available.

13 American Conference of Government Industrial Hygienists, A Manual of

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Recommended Practice, 19th Ed., Cincinnati, Ohio, 1986.

14American Industrial Hygiene Association, OSH-DB Occupational Safety and

Health Database, continually updated, Fairfax, Virginia.

15National Institute of Occupational Safety and Health, A Manual of Recommended

Practice, 19th Ed., Cincinnati, Ohio, 1986.

16NRC (National Research Council), Emergency and Continuous Exposure

Guidance Levels for Selected Airborne Contaminants, National Academy Press,
Washington, D.C., 1991.

17The Compressed Gas Association, Chantilly, Virginia (Website:

www.cganet.com).

18 The Chlorine Institute, Rosslyn, Virginia (Website: www.cl2.org).

Herbert W. Cooper has over forty years of experience with environmental,

economic and technological aspects of power production, hydrogen production,
steel mills, petrochemical production, oil refining and similar industrial facilities.
He has been the president of Dynalytics Corp. since 1969; a company whose
clients have included major engineering firms, equipment vendors, oil and
chemical, and aerospace companies. Currently, he is the chairman of
CodeLamp Corp., a spin-off of Dynalytics that has successfully integrated plant
design experience and expert systems technology with the communications
capabilities of the Internet to provide project-specific information about fire
codes. He received his bachelor and masters degrees in chemical engineering
from the City College of New York, and a doctorate in engineering science
(chemical engineering) from Columbia University. Dr. Cooper is a member of the
American Institute of Chemical Engineers and the National Fire Protection
Association; he is chair of its Physical and Chemical Data Consistency Advisory
Committee. He may be reached via e-mail: info@codelamp.com.

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