Does OSHA's Clearances Apply to Backflows?

10/1/2024

Do OSHA safety regulations apply to RPZ and DCDA backflow preventers?

OSHA requires 30 inches to the face off a side wall for maintenance for horizontal installations.

My contention is that if the drain to the RPZ runs to that wall, you will have an obstruction and trip hazard, and it will not be accessible for maintenance.

I've also installed the RPZs 4 feet above the tight pump room floors for access. It's never been a problem.

Please advise. IBC says to install backflow preventers according to the manufacturer's instructions.

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4 Comments

Dan Wilder

10/1/2024 08:47:04 am

OSHA (generally) applies to about anything within the workplace or area where workers are present in respect to hazards. There is no specific regulation that I can find, more the general duty clauses and basic 29-1910 sections for working clearances (those electrical clearances are pretty broad strokes into general clearance requirements throughout).

The drain is a separate issue as this is a trip hazard so falls (IMO) into the "Walking/Working Surfaces" Section 29-1910.22

While OSHA has requirements for installation, it also addresses when those installation compliances cannot be met as to mitigation hazards (hazard recognition & assessment, training, and creation of steps to safely work around those hazards) so even is something does not comply with a specific section, it has the ability to be addressed and allowed when properly mitigated (you can't stop confined space issues, but you can provide means to work within them).

As to this specific issue, not having the full clearance may not be an issue if the available clearance can allow the safe ITM of the valve. Additional training & signage or use of items like an overhead support (to attach a chain hoist) are also options. Marking the drain and use of warning signage to address the drain (if it can't be relocated). Hardening of the area around the drain (install of a stair or raised floor), proper lighting...as long as the facility and/or your employer has properly addressed the issues and provided safe means to complete the task.

Jack G

10/1/2024 09:03:39 am

The 8 inches applies to the entry of the bfp. The 30 inches applies to the other end horizontally. Your bfp can be 8 inches or more off a sidewall as long as there is clearance to the test valves and clearance for mait.

Greg

10/1/2024 09:42:22 am

In reviewing OSHA's Walking Working Surfaces, the context is geared towards the management and maintenance of floor areas, etc. Design of the space would seemingly fall under the building code and possibly NFPA 101, Life Safety Code, if adopted.

https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.2

I have seen small ramps and other ascent / decent 'trip and fall' protections added, post installation.

NFPA 101, 2024 ed., Chapter 7 Means of Egress , has the following on change in elevation.

Note existing installations...

7.1.6.1.2
Approved existing walking surfaces shall be permitted.

7.1.6.2 Changes in Elevation.
Abrupt changes in elevation of walking surfaces shall not exceed 1∕ 4 in. (6.3 mm). Changes in elevation exceeding 1∕ 4 in. (6.3 mm), but not exceeding 1∕ 2 in. (13 mm), shall be beveled with a slope of 1 in 2. Changes in elevation exceeding 1∕ 2 in. (13 mm) shall be considered a change in level and shall be subject to the requirements of 7.1.7.

Greg

10/1/2024 09:55:06 am

2021 International Fire Code Chapter 10 Means of Egress
1003.3.3 Horizontal projections.
Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the finished floor shall not project horizontally more than 4 inches (102 mm) into the circulation path.

2024 International Building Code, Chapter 10 Means of Egress
1003.3 Protruding Objects
Link : https://codes.iccsafe.org/content/IBC2024P1/chapter-10-means-of-egress

The IBC goes into more detail on objects than the IFC....

Do ask the question, "Is the obstruction actually in the 'means of egress'? "

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Does OSHA's Clearances Apply to Backflows?

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