Cryogenic liquids management

• Define safe storage and handling requirements. 

• Criteria for air monitoring. 

• Environmental Compliance reporting requirements 

• Define emergency response procedures to be followed for a cryogenic liquid release. 

• Identify training and exercise requirements. 

• Emergency Notifications. 

• Identify recommended modifications in technical systems and structures.

This plan is consistent with the requirements specified in Washington Administrative Code 296-24-567, 296-800-31070, 296-800-31075, and 296-800-31080.

This Plan applies to Puget Sound Microsoft facilities, to Microsoft employees and external staff who work with cryogenic liquids systems, and to all other employees and external staff who work in the affected buildings. 

This Plan does not anticipate or require that any employees will make efforts to control, contain, or repair the spill/release while it is occurring. Therefore, these facilities are not subject to the requirements of WAC 296-824-100. Qualified maintenance personnel may initiate repairs to the system(s) after the situation has been stabilized or resolved.

Cryogenic Liquids are used at three Puget Sound Microsoft facilities for lab research and development activities. A separate system provides gaseous nitrogen from small cylinders to create an inert atmosphere, as needed, in the experimental chambers.

Hazards of Cryogenic liquids (See Appendix 1 – Material Safety Data Sheet). 

• Cryogenic hazard – Liquid nitrogen (LN2) (boiling point -320.4°F) and Helium Liquid (LHe) (boiling point -452.7°F) are capable of causing instant frostbite on contact with living tissue. Direct skin contact with CRYOGENIC LIQUIDS causes severe frostbite (cryogenic burns) within seconds depending on the form of liquid nitrogen and/or Helium (liquid vs. mist) and surface area of the nitrogen / Helium-soaked material. It is important to know that soaked clothing or cotton can cause more rapid skin damage than a spill of direct CRYOGENIC LIQUIDS to the skin, which for a few seconds is protected by the Leidenfrost effect. The Leidenfrost effect is a phenomenon in which a liquid, in near contact with a mass significantly hotter than its boiling point, produces an insulating vapor layer which keeps that liquid from boiling rapidly.  

• Simple asphyxiant – CRYOGENIC LIQUIDS is not toxic, but it displaces oxygen that would otherwise be available for breathing. CRYOGENIC LIQUIDS is heavier than air when initially released from its container and vaporized (cold); and then as a gas it is slightly less dense than air. If released from its container, liquid nitrogen /Helium will collect in low-lying areas and then evaporate, posing an asphyxiant hazard to people in those spaces. Degrees of asphyxia will occur when the oxygen content of the working environment is less than 19.5% by volume. Effects from oxygen deficiency become noticeable at levels below 18% and sudden death may occur at 6% oxygen content by volume.  

• Heat flux – Heat flux into the CRYOGENIC LIQUIDS container from the environment will vaporize the liquid and potentially cause pressure buildup in containment vessels and transfer lines. 

4.1 Studio B 

Studio B is a 4-story building, with the laboratory spaces on either side of a hallway on the ground floor. The building has a central atrium that goes all the way to the top of the building. The LN2 tank is adjacent to the building in an unroofed concrete-block enclosure, supplying liquid nitrogen to the first-floor labs. The LN2 supply piping enters the building and runs above the suspended ceiling for 50-60 feet before entering the laboratory spaces. On the fourth floor, there is a lab that utilizes only liquid nitrogen and Helium portable dewars. The dewars range from 160L to 240L in volume each, and there are 10 LN2 and 10 LHe dewars used in the lab.

The laboratory spaces are configured with a number of oxygen-level sensors with a two-stage alarm that give both a visual strobe and audible alarm. The sensor/alarm system also closes the shut-off valve from the external tank when a low oxygen environment is detected; if the oxygen level returns to normal, the shut-off valve will re-open. The alarm system is connected to the Virtual Security Operations Center (VSOC). In the hallway outside the lab spaces, there is an Emergency Power-Off (EPO) switch that will close the shut-off valve. Laboratory personnel are advised to activate the EPO, if possible, when evacuating the laboratory spaces during a low oxygen alarm condition. 

4.2 Redmond-17760 / “Arcade”

Redmond-17760 (Arcade) is a 2-story commercial-warehouse type building with the laboratory spaces located in several enclosed bays on one side of a hallway on the first floor. Office spaces are located on the second floor. The LN2 tank is adjacent to the building in an unroofed metal-panel enclosure along with the chiller and air-handling equipment for the building. The LN2 supply piping enters through the exterior wall of the building directly into the laboratory spaces on the first floor. 

The laboratory spaces are configured with a number of oxygen-level sensors with a two-stage alarm that give both a visual strobe and audible alarm. The sensor/alarm system also closes the shut-off valve from the tank when a low oxygen environment is detected; if the oxygen level returns to normal, the shut-off valve will re-open. The alarm system is connected to the Virtual Security Operations Center (VSOC). In the hallway outside the lab spaces, there is an Emergency Power-Off (EPO) switch that will close the shut-off valve. Laboratory personnel are advised to activate the EPO, if possible, when evacuating the laboratory spaces during a low oxygen alarm condition. 

There is structural separation (concrete slab floor) between first floor and second floor in the Arcade Building, reducing the need for a full evacuation of the building in event of a release.

4.3 Building 127B (mQFab) 

Building 127 is a 2-story commercial type building that is divided by a barrier wall with the laboratory spaces located in the east of the building and has a separate entrance from the main building. This space is identified as Building 127B. There are office spaces located on the first and second floors inside and adjacent to the labs. The LN2 tank is adjacent to the east end of the building in an unroofed fenced enclosure. The LN2 supply piping enters the building and runs along the ceiling structure on the first floor for 25 feet and turn upstairs to supply the second floor. On the second floor it supplies a 1000L dewar that supplies LN2 to the lab on the first floor. In the lab on the second floor there is one portable dewar containing between 160 to 240 liters of LN2.

The laboratory and office spaces are configured with a number of oxygen-level sensors with a two-stage alarm that give both a visual strobe and audible alarm. The sensor/alarm system also closes the shut-off valve from the tank when a low oxygen environment is detected; if the oxygen level returns to normal, the shut-off valve will re-open. The alarm system is connected to the Virtual Security Operations Center (VSOC). In the hallway outside the lab spaces, there is an Emergency Power-Off (EPO) switch that will close the shut-off valve. Laboratory personnel are advised to activate the EPO, if possible, when evacuating the laboratory spaces during a low oxygen alarm condition.

There are three basic scenarios addressed in this Plan, increasing in severity and decreasing in likelihood.

• Small release (Facilities/Security Class 3 Event) – If a chamber is opened prior to all of the cryogenic liquids having been evacuated, a small “puff” of CRYOGENIC LIQUIDS may be released from chamber when door is opened. If the release is in the vicinity of an O2 monitor, the alarm may be actuated for a short period of time until the nitrogen dissipates and the O2 level returns to normal.
• Moderate Release (Facilities/Security Class 2 Event) – A moderate leak from pipe, joint, fitting, or from an experiment chamber. Due to the high expansion ratio of CRYOGENIC LIQUIDS, even a relatively small leak could release moderate quantities of CRYOGENIC LIQUIDS which would then off-gas due to the higher ambient temperatures. Fittings, joints, and experiment chambers could be displaced, loosened, or even broken in a large earthquake, or if impacted by a piece of moving machinery (e.g., a forklift).
• Large Release (Facilities/Security Class 1 Event) – A breach/failure of tank outside the building or a shearing of the piping as it transits the common areas of the building and enters the lab. A complete breach or failure of the tank is not likely unless the tank is impacted by a vehicle or other large object. The tanks are enclosed and not easily accessible by a vehicle. The piping leading into and through the building, though made of high-strength stainless steel, could be vulnerable to strong lateral forces from a large-scale earthquake.

Stakeholders for each Microsoft Facility or Business Group are responsible for implementing the requirements established by the Global OHS Program that are necessary for Microsoft to meet its regulatory requirements.

Actions in the event of a Cryogenic Liquid release are outlined below. Depending on the circumstances of the release, the problem may be confined only to the laboratory spaces, or it may affect the entire building. A large-scale release from the tank or the piping outside the building may affect a larger area around the building, including neighboring buildings. In that situation, the responding fire department may require that occupants of nearby buildings remain inside (shelter-in-place) to avoid exposure to the hazard.

Upon activation of a building wide O2 sensor/alarm, building occupants will follow the procedures in the Emergency Action Plan (EAP). Upon a lab O2 sensor/Alarm, lab personnel shall evacuate the laboratory.  Additionally, certain employees will conduct the following activities: 

7.1 Laboratory personnel

• All personnel in the laboratory space will evacuate the laboratory.  

• If it is safe to do so, employees may activate the EPO button while evacuating.  

• The laboratory manager or most senior laboratory employee will establish and maintain contact with VSOC (425-706-0000).

7.2 VSOC

VSCO will establish and maintain contact with local emergency responders, RE&F, and CBRE through the following actions:

• Receive notification that a O2 sensor/alarm has activated

• Notify the Lab Manager  

• Notify the City of Redmond Fire Department

• Initiate full-building fire alarm and evacuation

• Restrict entry of all doors to building to prevent access until building is cleared by Fire Department Responders

• Notify Microsoft OHS (GlobalOHS@microsoft.com) 

 7.3 Security 

• Receive notification that O2 sensor/alarm has activated.

• Support full-building fire alarm and evacuation as described in their procedures for incidents at Studio B, 127B, or Redmond-17760.

• Secure building access as directed by VSOC until building is cleared by Fire Department Responders

 7.4 Redmond Fire Department  

• Receive notification of release from Security.

• Respond to site per Fire Department procedure.

• Provide all clear to Security/advise when safe to reoccupy

 7.5 CBRE  

• The building automation system (BAS) will go into alarm, notifying Security, RE&F and CBRE.

• The Redmond Operations Center Technician on duty alerts On Duty Facility Manager (ODM) of the release.  

• ODM follows standard escalation protocols.

• CBRE personnel may respond to the release location and assist local emergency responders as necessary.

• Fire Systems/HVAC Technician will respond to the site and support Security with configuration of alarm panel as needed.

• Maintain liaison with Security, Microsoft OHS, and RE&F throughout the incident

 The decision to re-occupy the building and the laboratory spaces will be based solely on an all-clear given by the responding fire department, the verified status of the laboratory spaces and equipment, and management decision.

An After-Action Review will be conducted after each annual exercise or any actual activation of the Plan. The Review will include all involved stakeholders: Lab Personnel/Owner, VSOC, Security, Microsoft OHS, RE&F, and CBRE. The Review will evaluate the circumstances/scenario of the event; identify any discrepancies or problems with the implementation of the Plan or procedures; recommend changes or corrective actions necessary.  Changes may include modifications of this Plan, technical systems, work procedures, physical structures, or other factors that affect Microsoft’s response. The Review will be documented in an After-Action Report, and the Report will serve as a work plan to determine that corrective actions are addressed.

Training in the implementation of this Plan will be provided to all laboratory personnel, to other workers (or contractors) in and near the laboratory spaces, and to the employees working throughout the building. Initial training will be conducted for lab personnel upon hiring, and at least annually thereafter, unless changing conditions dictate a more frequent schedule.

Training for other occupants of the building will be conducted annually as part of general safety and fire evacuation drill.

The training for laboratory staff and Microsoft or CBRE response personnel will include:

• The physical, chemical and physiological hazards associated with cryogenic liquids in general

• The possible scenarios of cryogenic liquid spill/release

• Alarm and safety systems; indications of a release;

• The emergency procedures required in case of a release and Escalation Protocols

• Incident reporting and management procedures

Emergency response agencies (e.g., City of Redmond Fire Department) may be invited to attend training sessions in order to familiarize themselves with the procedures provided in this Plan. Visitors to the laboratory spaces will be briefed on all safety hazards, alarm systems, and evacuation procedures prior to entering the lab.

A full-scale exercise of the Plan will be conducted annually, including a full evacuation of the building. Specific timing of these exercises will be at the discretion of RE&F.

RE&F, with support from OHS will be responsible for the currency and implementation of this Plan, including reviewing and updating this Plan annually or whenever a change in operating configuration or circumstances dictates. Triggers for revision include:

• Significant changes in laboratory configuration, equipment, or experimental design;

• Significant structural changes in laboratory spaces

• Changes or upgrades in monitoring and alarm systems;

• Significant structural changes to the building;

• Significant turnover in laboratory personnel;

• Significant changes in building occupancy. 

OHS will establish periodic training and exercise requirements, schedule, and content and will monitor the implementation and coverage of training for all building occupants. RE&F will coordinate with, and assist OHS regarding the scheduling of training sessions and periodic exercises.

12.1 Microsoft Internal References

• MS Policy 37019-2, Regulatory Compliance  

• MS Policy 37019-5, Regulatory Investigations, Inspections, and Inquiries  

• Microsoft, Accident Prevention Program

• Microsoft Chemical Hygiene Plan    

• Microsoft Personal Protective Equipment Program

12.2 External References

• Emergency Plans WAC 296-24-567:

• Emergency Alarm Systems WAC 296-800-31070:

• Emergency Alarm Systems WAC 296-800-31075:

• Emergency Alarm Systems WAC 296-800-31080:

• Hazardous Substances Release WAC 296-824-100: 

All information collected by the Employee Incident Report Form will be used by Microsoft Corporation and its affiliates and subsidiaries (“Microsoft”) for documenting an accidental incident and other appropriate business purposes.  Microsoft will transfer this information to and store this information in the United States, to the extent permitted by law.  Microsoft will continue to comply with local data protection requirements for data transferred to the U.S., and is registered as Privacy Shield compliant for the purposes of the collection and transfer of EU data.  The information will be retained according to the Corporate Retention Schedule.  When necessary, Microsoft may transfer to or share this information with its affiliates and subsidiaries for appropriate business purposes; third-party agents acting on Microsoft’s behalf to provide products and services to employees (e.g., Worker’s Compensation Third Party Administrator); third parties as Microsoft determines is necessary to protect or defend its rights or property or the safety of property of its personnel; in the course of litigation; and as required by law, regulation, or court order.  Microsoft will not disclose your information outside Microsoft for purposes not identified in this notice without your consent, except as provided above.  By submitting this form that contains your information to Microsoft, you acknowledge you are providing the information voluntarily; that it is a true and accurate description of a work-related incident; and that you have read and agreed to Microsoft’s data collection practices described above.

LN2.pdf 

Liquid Helium.PDF

• Emergency Plans WAC 296-24-567

• Emergency Plans WAC 296-24-56701

• Emergency Alarm Systems WAC 296-800-31070

• Emergency Alarm Systems WAC 296-800-31075 

• Emergency Alarm Systems WAC 296-800-31080