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OSHA Hazard Information Bulletins

May 20, 1988

MEMORANDUM FOR REGIONAL ADMINISTRATORS


THRU:LEO CAREY
Director
Office of Field Programs
 
FROM:EDWARD BAIER
Director
Directorate of Technical Support
 
SUBJECT:Safety Hazard Information Bulletin on
the Use of Polyvinyl Chloride (PVC) Pipe
in Above ground Installations

The Dallas Regional Office has brought to our attention a potential serious hazard existing with the use of polyvinyl chloride (PVC) plastic pipes for transporting compressed gases in above ground installations. An employee in a Texas plant was injured recently by a rupture in a PVC compressed air line. Plastic projectiles from the point of rupture caused lacerations of the employee's hand. This is noteworthy because the Plastic Pipe Institute, in its Recommendation B dated January 19, 1972, recommends against the use of thermoplastic pipe to transport compressed air or other compressed gases in exposed plant piping. (See attachment.)

Furthermore, sections 842.32, 842.43 and 849.52(b) of the American National Standards Institute/American Society of Mechanical Engineers (ANSI/ASME) B31.8-1986, Gas Transmission and Distribution Piping Systems Standard, limit the operating pressure of plastic piping distribution systems to 100 pounds per inch (psi) and prohibit the installation of such systems above ground except where ". . . the above ground portion of the plastic service line is completely enclosed in a conduit or casing of sufficient strength to provide protection from external damage and deterioration." (Excerpts attached.)

Additional consensus standards applicable to PVC compressed gas systems include American Society for Testing Materials (ASTM) D1785-86, Standard Specification for Polyvinyl Chloride Plastic Pipe, Schedules 40, 80, and 120, and ASTM D2513-86a, Standard Specification for Thermoplastic Gas Pressure Piping Systems.

Please disseminate this bulletin to all Area Offices, State Plan States and Consultation Projects.

Attachments



February 14, 1989

Mr. Jack Cannova Tempe
Industrial
412 W. Dryon Street
Tempe, Arizona 85283

Dear Mr. Cannova:

In response to your recent inquiry concerning our regulatory position on the use of plastic pipe for compressed air systems, I trust this letter will clear up any confusion over the issue.

It is our position that PVC pipe shall not be used as a means of transporting compressed air. This position follows the manufacturer's own statements that PVC is unsuitable for compressed air systems. We do allow the use of certain ABS materials that are specifically designed for compressed air systems. One such product is "Duraplus" air line piping system ABS pipe. However, as in any such system, the manufacturer's specifications on acceptable pressure and temperature considerations must be followed.

In closing, misapplication of a product, such as using PVC for compressed air systems, may result in citations and penalties being issued dependent upon the specific conditions.

I appreciate your concern and inquiry into this potential safety hazard.

Sincerely,

SAM A. ROGERS
Bureau Chief



October 5, 1988

Mr. Tim Arbogast
Arizona OSHA
800 W. Washington
Phoenix, Arizona 85007-2922

Dear Mr. Arbogast:

It has recently come to my attention that there is a severe safety regarding the improper usage of plastic polyvinyl chloride (PVC) pipe. This pipe is designed for the transmittal of liquids, and is dangerous when used for transmitting compressed air or gas. Unfortunately, PVC has been frequently used with compressed air in construction projects across the country.

The state of Washington has notified the public that PVC pipe is not to be used in compressed air systems. I have also learned that the state of Nevada is in the process of making a similar determination and announcement. Additionally manufacturers of this product advise against its use with compressed air in their catalogue publications.

I believe that it is in the best interests of the citizens of our state if your office would expeditiously make such an announcement. A notice to users of the hazards of PVC pipe - when used improperly - would have the effect of preventing possible severe injury to people who work with or near this product.

By way of this letter, I am contacting the Department of Labor, OSHA, in Washington, D.C. and asking their officials to report to me on actions taken on the Federal level to restrict the use of this pipe and to notify users of the potential hazards involved in improper use of PVC pipe.

Your timely consideration of this request is appreciated.

Sincerely,

DENNIS DeCONCINI
United States Senator





STATE OF WASHINGTON
Department of
Labor & Industries
Hazard Alert


For more information, call:1-800-423-7233
 
FOR IMMEDIATE RELEASEMay 26, 1988


PVC pipe not to be used in compressed air systems

OLYMPIA -- The Department of Labor and Industries warned today that plastic polyvinyl chloride (PVC) pipe cannot be used in compressed air piping systems without the risk of explosion.

When PVC piping explodes, plastic shrapnel pieces are thrown in all directions.

"We're seeing more incidents of explosive failure, and we're citing more employers for using PVC air system piping," said Paul Merrill, senior safety inspector in L&I's Spokane office.

"It's probably just a matter of time before someone gets seriously injured in one of these explosions unless everyone pays more attention to the manufacturer's warnings," Merrill said.
Last year, a section of PVC pipe being used for compressed air exploded 27 feet above a warehouse floor. A fragment of the pipe flew 60 feet and embedded itself in a roll of paper. Fortunately, nobody was in the area at the time.
A PVC pipe explosion in a new plant in Selah broke an employee's nose and cut his face.

PVC piping buried 3 feet underground at a Yakima manufacturing plant exploded, opening up a crater approximately 4 feet deep by 3 feet across.

Only one type of plastic pipe has been approved for use with compressed air. That pipe, Acrylonitrile-Butadiene-Styrene (ABS), is marked on the pipe as approved for compressed air supply.

By law, employers must protect their workers by avoiding the use of unapproved PVC pipe in such systems. Existing compressed air systems which use PVC piping must be completely enclosed, buried or adequately guarded according to specifications approved by a professional consulting engineer.

NOTICE TO EMPLOYERS: If you have questions about the suitability of a material for air system piping, call Labor and Industries at the number listed above for a free consultation.

NOTICE TO EMPLOYEES: If you suspect that a pressurized PVC piping hazard exists, bring it to the attention of your employer. If you do not obtain satisfactory results, you may file a confidential complaint with the Department of Labor and Industries. Complaints are investigated promptly.


THE INDUSTRIAL COMMISSION OF ARIZONA
DIVISION OF OCCUPATIONAL SAFETY & HEALTH
P.O. BOX 19070
PHOENIX, ARIZONA 80005-9070


HAZARD ALERT

We have recently been made aware of a potentially serious hazard involving the prohibited use of unprotected plastic (PVC( piping to transport compressed air and other compressed gases in above ground installations.

While in Arizona we are not aware of any incidents of ruptured or exploding plastic pipes, States such as Washington and Texas have experienced incidents and injuries. Despite the lack of incidents in Arizona, we full recognize the potential for similar occurrences in this State and thereby request that you review your facilities and replace any such unsafe installations.

The Arizona Division of Occupational Safety and Health will be providing a program of awareness, assistance, and enforcement. This notice will be going to representatives of industry associations, labor organizations, print and electronic media.

Through our consultation and training program we will be providing assistance based upon requests received from employers. Through our compliance programs, we will be conducting unannounced inspections to ensure compliance with manufacturers' specifications and American National Standards Institute and American Society of Mechanical Engineers' Standard B 31.8-1986, which limits the operating pressure of plastic piping distribution systems to 100 pounds per square inch (psi) and prohibits the installation of such systems above ground except where the above ground portion of the plastic service line is enclosed in a conduit or casing of sufficient strength to provide protection from external damage and deterioration.

If you need assistance, please don't hesitate to call the Industrial Commission's Arizona Division of Occupational Safety and Health at 255-5795.

Tim Arbogast, Director



PLASTICS PIPE INSTITUTE
355 LEXINGTON AVENUE, NEW YORK, N.Y.10017
212-370-7341


RECOMMENDATION B
THERMOPLASTIC PIPING
FOR THE TRANSPORT OF COMPRESSED AIR
OR OTHER COMPRESSED GASES


Adopted January 19, 1972

The Plastics Pipe Institute recommends against the use of thermoplastic pipe to transport compressed air or other compressed gases or the testing of such piping with compressed air or other compressed gases in exposed above ground locations, e.g. in exposed plant piping. It is recommended that all thermoplastic piping used to transport compressed air or other compressed gases be buried underground or encased in shatter-resistant materials. In designing thermoplastic piping to transport compressed air or other compressed gases, the strength at the operating temperature, the pressure, the energetics, and specific failure mechanism need to be evaluated.



Colonial Engineering Inc.
Thermoplastic Piping Systems



To Whom It May Concern:

From time to time, I receive inquiries as to the suitability of using PVC pipe land fittings in compressed gas piping systems. While the benefits of use may be enticing, it is a very dangerous and, in some states, illegal thing to do. For example, MIOSHA (Michigan's branch of OSHA) prohibits the use of PVC plastic in compressed gas systems unless properly encased in steel, cement, or some other approved material. Please check your local and state regulations.

The main problem with using PVC pipe and fittings for compressed gas is not that it spontaneously explodes but that PVC is a brittle material that can be broken or shattered with external force unless properly protected. Compressed gasses can be best described as being analogous to a coiled spring. When a PVC pipe or fitting fails when under stress from compressed gas it literally explodes like a bomb, sending shards of plastic flying several feet in all directions. Liquids, on the other hand, being compressed by only 1/10th of 1% contain very little stored energy. When pressurized systems with liquids fail, the energy is dissipated very quickly, thereby creating a much lower potential for hazard.

Colonial Engineering does not recommend the use of PVC plastic pipe fittings in compressed gas service.

If you have further questions regarding this matter please feel free to contact me directly.

Sincerely,

Jack Roach



ESLON THERMOPLASTICS, INC.
P.O. BOX 15894, CHARLOTTE, NC 28210
DATE: July 11, 1988
704-889-2431  800-438-7881


INTEROFFICE MEMO

TOEslon Sales Force
 
FROMTerry McPherson
 
SUBJECT:COMPRESSED AIR AND PLASTIC PIPE

The dangers involved in using rigid vinyl piping products for compressed air transport are well known in our industry. Numerous disclaimer bulletins and letters have been circulated for almost three decades. It will not surprise you to learn that our government has just recently recognized the problem.

Attached you will find a copy of a memorandum that was issued by the "U.S. Dept. of Labor, Occupation Safety & Health Administration" (OSHA). You may wish to give copies to your customers and any other interested party. The government has finally made this danger "official."



PETER A. SCHUSTER
210 E. Grove Street Kawkawlin, MI 48631
(517)684-6135

October 4, 1989

Dear Regulator:

RE: Testing Product Lines of Underground Storage Tanks

I am alerting you that there is a device on the market for pressure testing product lines, used in conjunction with tank testing, which is not safe. This device, manufactured by Horner Creative Products, 413 State Park Drive, Bay City, Michigan 48706, utilizes a plastic (PVC) cylinder which is attached to the pipeline, filled with gasoline, and then up to 100 PSI air pressure applied to the cylinder.

Not only have the manufacturers of PVC indicated for years that "extreme dangers" are involved because of its potential to explode, but they have notified Mr. Horner via their distributors, that they do not want him using their material (PVC) to make his line tester. He has thumbed his nose at the manufacturers of PVC, and continues to market this product. The use of PVC for compressed air or gas systems has been prohibited by several states - copies of their hazard alerts enclosed.

As a responsible regulator it is only proper that you be aware of this device being utilized nationwide by hundreds of unsuspecting operators. I have documented three failures of this product line tester to date. Fortunately no injuries have yet occurred, but there is obviously an imminent danger to the operator and to the public. There have been documented cases of similar misuse of PVC in compressed air or gas systems where injuries have occurred.

Please, before someone gets killed, or seriously hurt, help remove this product from the marketplace. Obviously Mr. Horner will not remove it without pressure being applied from you.

Should you have further questions, or I can be of further service, please feel free to call on me.

Warm regards,

Peter A. Schuster

 
 
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