OSHA Regulations: Steam and Hot Water Pipes

OSHA does consider exposed heated surfaces, if there is a potential for injury, to be a hazard and will issue citations if employees can come into contact with such surfaces. While there are not any OSHA standards, except those that are applicable only to specific industries, which address exposed heated surfaces, there are several OSHA general standards which address such hazards. Those standards are: 

1910.261(k)(11):

Steam and hot-water pipes. All exposed steam and hot-water pipes within 7 feet of the floor or working platform or within 15 inches measured horizontally from stairways, ramps, or fixed ladders shall be covered with an insulating material, or guarded in such manner as to prevent contact.

1910.262(c)(9):

Steam pipes. All pipes carrying steam or hot water for process or servicing machinery, when exposed to contact and located within seven feet of the floor or working platform shall be covered with a heat-insulating material, or otherwise properly guarded.

1910.147:

The control of hazardous energy (lockout/tagout) standard covers hazardous energy, including thermal, during the servicing and maintenance of machines or equipment. Thermal energy may be dissipated or controlled, and it is the result of mechanical work, radiation, or electrical resistance. This standard addresses practices and procedures that are necessary to disable machinery or equipment and to prevent the release of potentially hazardous energy while maintenance and servicing activities are performed. 

Section 5(a)(1) of the OSHAct:

Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.

Skin Burns

The topic of a safe touch temperature has been investigated thoroughly ever since the first damage function was created in 1947.  Since then, it has been an essential aspect in any design where a heated surface is exposed.  An inquiry into current standards and guidelines was an essential first step in my investigation.  It was also necessary for me to understand the physiological properties of skin and burns in order to investigate the effects of material type and thickness on the safe touch temperature.  I researched the origin of the damage function which yields how much injury occurs for a material at a specific material over time.

Current Regulations and Guidelines:

There are currently not many general safe touch temperature standards or codes. The US Department of Labor's Occupational Safety & Health Administration (OSHA) does consider exposed heated surfaces, if there is a potential for injury, to be a hazard.  There are not any OSHA standards, except those that are applicable to specific industries, which address exposed heated surfaces.  The American Society for Testing Materials (ASTM) has two standards that address the issue of a safe touch temperature.  ASTM C1055-99 and ASTM C1057-03 establishes a means by which the engineer can determine the acceptable surface temperature of an existing system where skin contact may be made with a heated surface.  It also details how personal injury resulting from contact with heat surfaces can be prevented by proper design of insulation systems or with the usage of other protective measures.  The National Insulation Manufacturers Association (NIMA) has guidelines dealing with the amount of insulation needed to ensure that the acceptable temperature is not exceeded.