Building Placement Considerations


19262 Hwy. 62 South, Orange, TX 77630

Building Placement Considerations

In the wake of the 2005 Texas City explosion, OSHA initiated the National Emphasis Program to increase compliance with Process Safety Management (PSM) and “facility siting.”  Under this program, OSHA has heightened its enforcement activity and conducts a comprehensive industry review of all refineries to compel immediate enforcement with PSM and facility siting requirements.
OSHA PSM 29 CFR 1910.119(e)(3)(v) provides general guidance for facility siding.  The non-mandatory guidance on PHAs in Appendix C addresses methodologies. It focuses on potential causes and consequences of fires, explosions, releases of toxic or flammable chemicals, and major spills of hazardous chemicals.
Blast-Rated Structures are only part of the equation, but other Facility Siting considerations are as follows:
  1. The proximity of occupied buildings to hazardous processes – Are occupied buildings rated for their designated locations per API RP 752 and API RP 753?
  2. Unit siting issues – Is spacing adequate for the ingress and egress locations of the buildings in the event of fire or explosion?
  3. Control room siting issues – Are there issues with the control room location concerning the unit it controls? Can it withstand a hazardous event? Does the control room meet Safe Haven standards, and is it noted as such?
  4. Trailer location concerns: Are all non-blast rated construction or “temporary” trailers situated outside the process area?  
  5. Fire protection design – Is the proximity of occupied structures susceptible to ongoing fire following a blast? Should fire barriers be considered? Can the hazardous process be accessed from at least one side with firefighting measures?
  6. Sewer systems – Would a fire or other abnormal situations ignite flammable material in the sewer system so that the sewer became a source for spreading the fire?
  7. Pipe rack location – Do pipelines carrying hazardous chemicals pass close by occupied buildings, where a leak would result in employee exposure?  
  8. Traffic concerns – Does automotive traffic in or around the hazardous process expose pipework or other equipment to impact and subsequent damage and release? 
  9. HVAC intake locations – Will the HVAC pull toxic or flammable vapors into an occupied space, exposing the building occupants?
  10. HVAC failure – Will the failure of the HVAC air handling in an occupied space limit the positive pressure necessary to keep toxic or flammable vapors out of the structure?
  11. Relief device discharge locations – Do emergency vents discharge to areas that place employees at risk of exposure?
  12. Atmospheric vent discharge locations – Do vents put employees at risk, especially in an emergency when the composition of the vented material is abnormally toxic or flammable? Does the vent discharge to points near HVAC intakes?


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