Pipe Marking Program
for
[Company Name/Location]
I. OBJECTIVE AND SCOPE
This program is intended to establish a consistent system to assist in identification of materials conveyed in piping systems and their hazards when released in the environment. [Company Name/Location] employees must be aware and informed of the contents in chemical pipes. This can best be accomplished by labeling all piping systems. This program does not apply to pipes buried in the ground.
The procedures described in this Program are intended to facilitate compliance with applicable governmental regulations. If there is a conflict between this Plan and a governmental regulation, the governmental regulation will apply and this Plan will be modified. However, all other requirements in this Plan apply even if more stringent than governmental regulations.
II. DEFINITIONS
Piping Systems. Piping systems include pipes of any kind and, in addition, fittings, valves, and pipe coverings. Supports, brackets, or other accessories are specifically excluded from this program.
Pipes. Are conduits for the transport of gases, liquids, semi-liquids, or fine particulate dust.
III. RESPONSIBILITIES
A. Program Manager
[Responsible Person] shall manage the Pipe Marking Program for [Company Name/Location]. The Program Manager will ensure that the program is accurate and up to date. Training records pertaining to this program shall be maintained in accordance with the facility Training Plan.
B. Management
[Company Name/Location]will provide adequate controls, tools, and equipment to implement the pipe labeling program. [Facility Manager Name] or his/her designee will ensure proper adherence to this Plan through regular inspections.
C. Supervisors
Supervisors shall themselves support the implementation of this Program by routinely observing any pipe labeling within their area of responsibility and reporting and exceptions to the requirements of the Program. They will also insure that their employees are trained to understand pipe labeling required by the Program and that they comply with all labeling.
D. Employees
Employees are responsible for complying with all labeling located in their work area as required by this Program. Employees shall report to their supervisor any exceptions to Program requirements.
E. Third Party Contractors
Third Party Contractors are responsible for complying with labeling required by this Program, and shall insure that their employees have the necessary training to comply with labeling required by this program.
IV. PROCEDURE
[Existing Pipe Marking Programs shall be considered acceptable if such programs are described in writing and implemented so that management can demonstrate that the basic requirements of this program and any governmental requirements are being met.]
A. General Pipe Marking Requirements
Pipe markings are the primary and explicit means for identification of pipe contents. Positive identification of the contents of a piping system shall be by lettered marking giving the name of the contents in full or abbreviated form (See examples in Appendix A). Pipe contents shall be identified by name and sufficient additional details such as temperature or pressure as are necessary to identify the hazard. In any situation, the number and location of identification markers shall be based on the particular piping system.
1. All pipes will be marked.
2. All markings will be consistent with the legend in Appendix B.
3. Color will be used to identify the characteristic hazards of the pipe contents.
4. Contrast shall be provided between color field of the marking and lettering for readability.
5. All markings will include directional arrows, indicating the direction of flow, at each end of the label. Directional arrows will go around the entire circumference of the pipe (or pipe covering).
6. Lettering must be sized appropriately for readability (See Appendix B).
7. Pipes containing material which when released from the piping would have a potential for inflicting injury or property damage by burns, impingement, or flashing to vapor state must be marked with the appropriate warning.
B. Placement of Markings
1. Pipe markings will be positioned so that they can be easily seen from the normal angle of approach. For example: If the pipe is overhead all markings will be placed below the centerline of the pipe.
2. Pipes will be marked at the following locations:
a. Adjacent to all changes in direction.
b. Adjacent to all valves and flanges.
c. At both sides of floor and wall penetrations.
d. At any point of entry into the pipe.
e. At maximum of 50 intervals on straight runs. Closer spacing intervals will be used when necessary for visibility.
3. All valves, cleanout fittings or other fittings providing access to pipe contents will be tagged with a permanently legible tag.
C. Regular Inspection
1. Regular inspection of pipe marking at [Facility Name/Location] will be accomplished in the following manner:
a. Pipe marking inspections will be conducted monthly using the checklist contained in Appendix C. (Inspections may be conducted as a part of monthly safety inspections.)
b. Inspections will be documented.
c. Any illegible markings or missing markings will be replaced immediately following the inspection.
d. If the need for additional marking is determined during the inspection it will be installed as soon as practical following the inspection. Temporary marking will be used until permanent marking can be installed.
V. TRAINING
A. Employee Training
Each employee who works in, or may be required to pass through, areas in which pipes and piping exist must be trained to recognize pipe markings and understand potential hazards of the materials and conditions identified by pipe markings. Training will include familiarization with the Marking Legend contained in Appendix B. The training will be in the form of classroom and/or on-the-job instruction. Training will be conducted and documented according to the requirements of the [Company Name/Location] Training Plan. [Responsible Person] is responsible for ensuring employees receive the training required by the Pipe Marking Program.
Employees must also receive training as required by the Chemical Hazard Communication Program of [Company Name/Location].
B. Training Records
Training records will be maintained in accordance with the Training Plan and the Records Retention Plan.
VI. REFERENCES
A. Regulatory References
US Occupational Safety and Health Administration (OSHA):
1. 29 CFR 1926.1200 Hazard Communication
B. Industry Standard References
1. ANSI/ASME A13.1-2007
2. ANSI A13.1-1996
3. ANSI Z53.1-1979
C. Site Policy References
[Facility Name/Location]Chemical Hazard Communication Program.
VII. APPENDICES
A. Marking Examples
B. Marking Legend
C. Pipe Marking Inspection Checklist
VIII. DOCUMENT CONTROL
This Pipe Marking Program shall be reviewed annually, or as needed if changes to the worksite are made, by [Responsible Person].
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