Missouri propane marketers must conduct a Written Fire Safety Analysis to comply with the provisions of NFPA 58 (2001 edition). In order to conduct the analysis, MPGA is providing this checklist approved by the Missouri Propane Gas Commission. It facilitates your compliance with NFPA 58 and also serves as a step-by-step guide as you walk through the analysis with your local fire department at each plant.
The WFSA process must include fire service personnel who provide information relevant to their ability to respond. A fire service representative should walk through the plant with you as you describe the various attributes described on the checklist. Jurisdiction on plant safety falls with the MPGC, not local firefighters. Their responsibility is to understand how they would respond to the plant as is in the event of an emergency.
BACKGROUND
The National Fire Protection Association’s LP Gas Code (NFPA 58), 2001 edition, has been adopted by the State of Missouri as the official state propane code. Within NFPA 58, Section 3.10.2.2 requires that a Written Fire Safety Analysis (WFSA) be completed for all LP gas installations that use ASME containers with an aggregate capacity of more than 4000 gallons (water capacity). Manifolded tanks meet this threshold if the aggregate volume exceeds 4000 gallons.
The section also requires planning with local emergency agencies, such as fire and police departments, for the effective control of inadvertent product release or fire. This planning should consider the safety of emergency personnel, workers and the public.
The WFSA provides owners and operators of affected facilities with a self‐audit tool that they can use to determine facility safety and enhance the effectiveness of local emergency responders. If serious hazards are identified during the assessment, special protection as allowed by NFPA 58 may be needed
CONDUCTING THE WFSA
Your assessment must be prepared by a person approved by the Missouri Propane Gas Commission who has relevant experience and knowledge of industry practices. As a general rule, the Commission authorizes the owner or operator to prepare the WFSA. The exception is for an engineered facility, such as one that incorporates refrigerated storage, automated fuel standby (either industrial or utility) or pipeline terminals. These assessments must be prepared, stamped and signed by a professional engineer. Also, note that all storage tanks utilized by public utility companies as defined in RSMo 323 are regulated by the Missouri Public Service Commission.
There are five elements addressed in the WFSA:
1. Evaluation of the total product control system and its effectiveness;
2. Analysis of hazards within the facility, including congestion or other local conditions;
3. Assessment of exposure to and from other properties, population and activities;
4. Determination of the probable effectiveness of local fire departments based on water supply, response time and training; and
5. Evaluation of the application of water by hose streams or other methods of effective control of leakage, fire or other exposures.
This handbook will serve as a checklist for most Missouri LP gas facilities which fall under the WFSA requirement. In conducting your assessment, it might also be helpful to also consult NFPA’s Pamphlets 58 (2001) and 54 (1999) and the Missouri Propane Gas Commission “blue book” which contains applicable state law and regulations. To assist you in completing the assessment, citations are provided which reference these source documents.
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