Are SCBA’s Required for Controlled Ammonia Releases?

Does your mechanics have to wear an SCBA to response to a controlled ammonia release? HAZMAT / HAZWOPER we think a full team from incident command to decontamination.  Emergency response teams are just that, but is ruling of a mechanic responding to a controlled ammonia release? This week, the United States Court of Appeals for the Eleventh Circuit issued a decision limiting the reach of the HAZMAT standard 29CFR§ 1910.120.

In May 2017, one of the underground pipes became over pressurized, and, as it was designed to do, the system automatically diverted ammonia from that pipe to the sump. A short while later, ammonia saturated the sump water, and excess ammonia began venting to the outside. The ammonia in the air triggered a sensor at the skid set to alarm if the ambient ammonia reached 50 parts per million. About 45 minutes after the ammonia began to vent, a security guard heard the alarm sounding at the skid and smelled ammonia. He began having trouble breathing and reported the leak. Once notified, control-room personnel dispatched “rovers”—specially trained response employees to manage the ammonia release. Upon arriving at the skid, the rovers called the control room and instructed those there to “isolate” one of the valves regulating the flow of ammonia. Meanwhile, the rovers continued working on other parts of the skid and added water to the sump. Working together, plant personnel stopped the ammonia release, but because the rovers arrived at the skid without “self-contained breathing apparatus[es],” OSHA fined Tampa Electric $9,054 under 29 C.F.R. § 1910.120(q)(3)(iv).

29 C.F.R. § 1910.120(q)(3)(iv)
Emergency response or responding to emergencies means a response effort by employees from outside
the immediate release area or by other designated responders (i.e., mutual aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard. Responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure) are not considered to be emergency responses.