Occupational Safety and Health Administration
and the
Chemical Reactivity Hazards Management Alliance

I. Alliance Background

Date Signed

March 30, 2004

Overview

Signatories of the Alliance:

• Environmental Protection Agency (EPA)
• American Chemistry Council (ACC)
• Center for Chemical Process Safety (CCPS) of the American Institute of Chemical Engineers (AIChE)
• Chlorine Institute (CI)
• Mary Kay O'Connor Process Safety Center
• National Association of Chemical Distributors (NACD)
• Synthetic Organic Chemical Manufactures Association (SOCMA)

Through the Alliance, OSHA and signatories of the Chemical Reactivity Hazards Management Alliance are working together to provide their members, customers, contacts and others involved in the manufacture, distribution, use and storage of chemicals with information, guidance, and access to training resources that will help them protect communities and employees' health and safety through better identification and management of chemical reactivity hazards.

Implementation Team Members
 

Chemical Reactivity Hazards Management Non Governmental Organizations:
 

* Paul Murphy was a contributor from July 2004, to April 30, 2005

Evaluation Period

March 30, 2004 - March 29, 2005

II. Implementation Team Meetings
 

III. Results

1. Events and Products
   
   Training and Education Goal
    
   • Provide input and expertise to OSHA to deliver training addressing chemical reactivity hazards, to be delivered in conferences, meetings, OSHA Training Institute (OTI) Education Centers, or through distance learning.
   Products
   
   Reactives Chemical Workshop
   
   The OSHA and Chemical Reactivity Hazards Management Alliance is developing a Reactive Chemicals Workshop, "Chemical Reactivity Hazard Management Tutorial for Chemical Handlers," for presentation throughout the chemical industry. The workshop is designed to help smaller businesses identify the reactive chemical hazards that may be present in their operations. The first workshop was scheduled to be given at the AIChE 2005 Spring National Meeting, April 13, 2005 in Atlanta Georgia, however, it was cancelled due to a lack of enrollment. The Alliance implementation team is working to reschedule the workshop in conjunction with the Chlorine Institute 2005 Fall Meeting, September 25-28, 2005, Wyndham New Orleans, New Orleans, LA.
   
   Outreach and Communication Goals
    
   • Develop and disseminate information through print and electronic media, including electronic assistance tools and links from OSHA's and the signatories' Web sites.
      
     • Make the CCPS publication, Essential Practices for Managing Chemical Reactivity Hazards, available in the open literature through Signatories' web sites and other means.
        
     • Disseminate and encourage the use of the CCPS publication, Essential Practices for Managing Chemical Reactivity Hazards, to ACC, CI, MKOPSC, NACD, and SOCMA members and their respective value chains.
   Products
   
   OSHA's Chemical Reactivity Hazards Safety and Health Topics Page
   
   Representatives from the OSHA and Chemical Reactivity Hazards Management Alliance helped provide input and develop OSHA's Chemical Reactivity Hazards Safety and Health Topics page. This page was launched in December 2004 and is maintained as a product of the OSHA and Chemical Reactivity Hazards Management Alliance and the OSHA and The Dow Chemical Company Alliance. The following Alliance implementation team members serve on the page's editorial board:
    
   • Bill Almond, NACD; Arlington, VA
   • Scott Berger, CCPS; New York, NY
   • Eric Clark, SOCMA; Washington, DC
   • Art Dungan, CI; Arlington, VA
   • Dorothy Kellogg, ACC; Arlington, VA
   • Sam Mannan, Mary Kay O'Connor Process Safety Center; College Station, TX
   • Rob McArver, SOCMA; Washington, DC
   • Vanessa Rodriguez, EPA; Washington, DC
   • Irv Rosenthal, Wharton Risk Management and Decision Processes Center; Philadelphia, PA
   • Greg Smith, SOCMA; Washington, DC
   OSHA and the Chemical Reactivity Hazards Management Alliance Web page
   
   The OSHA and Chemical Reactivity Hazards Management Alliance Web page on OSHA's Web site includes links to the Alliance agreement and related documents, activities and events, milestones and successes, and products of the Alliance such as OSHA's Chemical Reactivity Hazards Safety and Health Topics page. For more information on the number of visits to the OSHA and the Reactive Alliance Web page, please see the Alliance Program Reach table on page 10. This Web page is updated on a regular basis.
   
   Publications and Newsletters
   
   Information and news releases on the OSHA and Chemical Reactivity Hazards Management Alliance signing and the activities of the Alliance have appeared in a number of publications produced by OSHA and the Chemical Reactivity Hazards Management Alliance signatories. In addition, information on the OSHA and Chemical Reactivity Hazards Management Alliance has been published in a number of safety and health publications. Please see the chart in this report under "Alliance Program Reach" for additional information.
   
   Essential Practices for Managing Chemical Reactivity Hazards Manual
   
   CCPS developed Essential Practices for Managing Chemical Reactivity Hazards and published the manual in 2003. The OSHA and Chemical Reactivity Hazards Management Alliance is helping to promote the availability of the manual. Free on-line access is also available through OSHA's Chemical Reactive Hazards Safety and Health Topics page. The manual focuses on preventing workplace incidents and addresses the following topics:
    
   • Identify, address, and manage chemical reactivity hazards;
   • Analyze the potential for chemical reactivity accidents;
   • Prevent reaction runaways, fires, explosions, toxic chemical releases, and
   • chemical spills; and
   • Apply this knowledge and tool set to processes of any scale.
   Process Safety Beacon
   
   Through the Alliance, OSHA is posting CCPS's Process Safety Beacons that have chemical reactivity information on OSHA's Chemical Reactivity Hazards Safety and Health Topics page. CCPS uses the Process Safety Beacon, to deliver safety messages to plant operators and other manufacturing personnel. Each issue presents a real-life accident, and describes the lessons learned and practical methods to prevent similar accidents in other facilities.
   
   EPA's Alert: Identifying Chemical Reactivity Hazards: Preliminary Screening Method
   
   Through the Alliance, implementation team members provide feedback to the EPA on its Alert: Identifying Chemical Reactivity Hazards: Preliminary Screening Methods. In addition, the Alert recognizes the OSHA and Chemical Reactivity Hazards Management Alliance.
   
   The EPA issued the Alert in May 2004. The purpose of this Alert is to introduce small - and medium-sized facilities to a simple method developed by the CCPS, Essential Practices for Managing Chemical Reactivity Hazards, to screen facilities for chemical reactivity hazards. This Alert addresses the following topics:
    
   • • Identifying the Problem
     • Understanding the Hazard
     • Screening Flowchart
     • Controlling the Hazard
     • Information Resources
   • Speak, exhibit, or appear at appropriate OSHA, EPA or other signatory conferences, local meetings, or other such events as:
      
     • ACC Responsible Care® Regional Meetings,
     • AIChE Loss Prevention Symposium
     • AIChE local section meetings
     • Annual CCPS International Conference
     • CCPS Technical Steering Committee meetings
     • SACHE Workshops (process safety train-the-trainer for engineering professors)
     • NACD's Operations Seminar & Trade Show
     • SOCMA annual and regional meetings
     • Chlorine Institute Annual and fall meetings
     • MKOPSC Annual Symposium and Short Courses
     • MKOPSC engineering seminars and course work
     • PhD dissertations research on chemical reactivity hazards
   Events
   
   Texas Chemical Council and Association of Chemical Industry of Texas Environmental, Health and Safety Seminar, Galveston, Texas, June 7, 2004
   
   Dorothy Kellogg, Senior Director, Security and Operations, ACC, presented a PowerPoint® presentation entitled "Alliance to Identify and Manage Chemical Reactivity Hazards," June 7, 2004, at the Texas Chemical Council's and Association of Chemical Industry of Texas' Environmental, Health and Safety Seminar at the Moody Gardens Hotel in Galveston, Texas.
   
   National Association of Chemical Distributors 16th Annual Operations Seminar & Trade Show, Orlando, Florida, September 22-24, 2004
   
   Mark Davis, OSHA Region IV, Jacksonville, Florida Area Office, maintained a tabletop display and distributed Alliance Program materials, along with other OSHA publications, during the National Association of Chemical Distributors 16th Annual Operations Seminar & Trade Show, September 22-24, 2004 at The Renaissance Orlando Resort at Sea World, Orlando, Florida.
   
   10th Annual Transportation & Distribution Conference, New Orleans, Louisiana, January 14, 2005
   
   Bill Allmond, Director of Regulatory Public Affairs for NACD, made a presentation about reactive hazards management issues and the OSHA and Chemical Reactivity Hazards Management Alliance, January 14, 2005, during the 10th Annual Transportation & Distribution Conference at the Fairmont Hotel, New Orleans, Louisiana.
   
   Chlorine Institute 2005 Annual Meeting, Baltimore, MD, March 21 - 22, 2005
   
   OSHA, along with representatives from Maryland Occupational Safety and Health, and the EPA, maintained an exhibit table where they answered questions and distributed safety and health related materials during the Chlorine Institute 2005 Annual Meeting, March 21-22, 2005 in Baltimore, MD.
   
   SOCMA Responsible Care Regional Networking Meetings
   
   Through the OSHA and Chemical Reactivity Hazards Management Alliance, SOCMA invited OSHA representatives to speak at their Responsible Care® Regional Networking meetings at various locations across the nation. As a result, OSHA spoke at the following meetings about the Agency's priorities, initiatives and compliance assistance resources:
    
   • • March 22, 2005: SOCMA - Midwest Region Responsible Care® Regional Networking Meeting. Julie Weis, Region V, Cleveland, Ohio Area Office, Compliance Assistance Specialist, spoke to the group at the Noveon, Inc. in Cleveland, Ohio.
       
       March 24, 2005: SOCMA - Southwest Region Responsible Care® Regional Networking Meeting. Chuck Williams, Region VI, Area Director, Houston South, Texas, spoke to the group at the Dixie Chemical Company in Pasadena, Texas.
   • Collaborate with other Alliances on specific issues and projects on the identification and management of chemical reactivity hazards that are addressed and developed through the Alliance Program.
   Products
   
   OSHA's Chemical Reactivity Hazards Safety and Health Topics page and EPA's Alerts (See also Outreach and Communication Goals, Products)
   
   Chemical Reactivity Hazards Management Alliance members were able to collaborate with OSHA Alliance Program participant, The Dow Chemical Company, to provide input and information on the development of OSHA's Chemical Reactivity Hazards Safety and Health Topics page.
   
   In addition, members of the OSHA and Chemical Reactivity Hazards Management Alliance and The Dow Chemical Company worked with the EPA on the Agency's Chemical Safety Alert: "Identifying Reactivity Hazards: Preliminary Screening Method," that introduces small and medium sized facilities to the methodology for chemical reactivity hazard management.
   
   Promoting the National Dialogue on Workplace Safety and Health Goals
    
   • Convene or participate in forums, round table discussions, or stakeholder meetings on chemical reactivity hazards to help forge innovative solutions in the workplace or to provide input on safety and health issues.
   Events
   
   Alliance Program's Hazard Communication Roundtable, Washington, DC, February 15, 2005
   
   Through the Alliance Program, OSHA held an Alliance Program Hazard Communication Roundtable February 15, 2005 in Washington, DC. This roundtable provided the Program's participants with an opportunity to learn about the status of OSHA's Hazard Communication Initiative; share information about their own Alliances, including any activities related to Hazard Communication; and learn about what other Alliances are doing to address Hazard Communication issues. Representatives from 18 Alliances participated in the roundtable. Arthur E. Dungan, Vice President - Safety, Health, and Environment at the Chlorine Institute participated on behalf of the OSHA and Chemical Reactivity Hazards Management Alliance.
   
   At the meeting, workgroups were established and projects were identified for the Alliance participants to work on together to develop Hazard Communication related compliance assistance resources. Three workgroups were established to address:
    
   • Hazard Communication Awareness and Training
   • Developing Model MSDSs
   • Promoting the Globally Harmonized System of Classification and Labeling of Chemicals
   Mr. Dungan is participating on the Hazard Communication Awareness and Training workgroup.
2. Executive Summary
   
   Through the Alliance, OSHA and the chemical industry signatories have developed an excellent working relationship and are producing a number of programs and products for the chemical industry. These products are designed to produce information and guidance and increase access to training resources to protect communities and employees' health and safety through better identification and management of chemical reactivity hazards.
   
   OSHA and Chemical Reactivity Hazards Management Alliance implementation team members contributed information and comments on OSHA's Safety and Health Topics page, Chemical Reactivity Hazards, as it was developed. In addition, implementation team members are on the Topics page's editorial board. The page was posted on OSHA's Web site in December 2004.
   
   Through the OSHA and Chemical Reactivity Hazards Management Alliance a wide assortment of resources are being made available to the chemical industry through OSHA's Safety and Health Topics page on Chemical Reactivity Hazards, including:
    
   • EPA's Alerts, Chemical Safety Alert: Identifying Chemical Reactivity Hazards: Preliminary Screening Method
   • CCPS's Blue Book, Essential Practices for Managing Chemical Reactivity Hazards
   • CCPS's Process Safety Beacon
   During the Alliance's first year, implementation team members began developing a one day Reactive Chemicals Workshop to assist the chemical industry to identify reactive chemical hazards during manufacturing, blending, and storage of chemicals. This workshop is designed to assist small and medium size businesses to make them aware of the basics and provide strategies and tools for identifying and preventing reactivity incidents at those facilities.
   
   The OSHA and Chemical Reactivity Hazards Management Alliance has allowed the Agency and chemical industry signatories to speak about OSHA's compliance assistance materials and the Alliance Program at a number of events including:
    
   • Texas Chemical Council and Association of Chemical Industry of Texas Environmental, Health and Safety Seminar, Galveston, Texas, June 7, 2004
   • 10th Annual Transportation & Distribution Conference, New Orleans. Louisiana, January 14, 2005
   • Midwest Region Responsible Care Regional Networking Meeting SOCMA, Cleveland, Ohio, March 22, 2005
   • Southwest Region Responsible Care Regional Networking Meeting for SOCMA, Pasadena, Texas, March 24, 2005
   In addition, OSHA staff along with representatives from the Maryland Occupational Safety and Health office manned an exhibit table at the Chlorine Institute Annual Meeting, Baltimore, Maryland, March 21-22, 2005. Also through the Alliance, implementation team member Art Dungan participated in the Alliance Program's Hazard Communication Roundtable, in Washington, DC, February 15, 2005.
   
   Articles about the OSHA and Chemical Reactivity Hazards Management Alliance appeared in a number of publications including: Occupational Hazards Magazine, Bureau of National Affairs (BNA) Occupational Safety and Health Reporter, Environmental Health and Safety EHSDirect, Labor-Management Construction Safety Alliance, and the 2005 CCPS Process Safety Report.
   
   The Alliance team has also formed a marketing workgroup which is developing a marketing plan that will assist in developing awareness of the Alliance and its products in the reactives chemical industry.
   
   Due to their interest in the Alliance's work, the U.S. Chemical Safety Board attends implementation team meetings as an observer to the OSHA and Chemical Reactivity Hazards Management Alliance. Finally, the American Chemical Society approached the Alliance and requested to become a signatory and join the Alliance in 2005.
    
3. Alliance Program Reach

IV. Upcoming Milestones

In the upcoming year, the OSHA and Chemical Reactivity Hazards Management Alliance will continue to work together to identify opportunities to assist the chemical industry in creating a safer working environment for the community and their workers.

The members of the Alliance implementation team are planning to present the first Reactive Chemicals Workshop at the Chlorine Institute 2005 Fall Meeting, September 26, 2005 at the Wyndham New Orleans, New Orleans, LA.
The Alliance team is also evaluating helping the Reactivity Management Roundtable's update of the CCPS Flow Chart that is used to screen facilities for chemical reactivity hazards. This chart would be made available to the downstream customers of chemical manufacturers through various electronic and media outlets.

Implementation team member, Mr. Art Dungan, will continue to participate on the Alliance Program's Hazard Communication Roundtable workgroup addressing hazard communication awareness and training.

In addition, the Alliance team members will be speaking and exhibiting at a number of events during the upcoming year, including:

• SOCMA - Regional Responsible Care® Regional Networking Meeting, April 5, 2005, at OMNOVA Solutions, Inc., Chester, South Carolina
• SOCMA - Regional Responsible Care® Regional Networking Meeting, April 7, 2005, at MFG Chemical, Inc., Dalton, Georgia
• Texas Chemical Council and Association of Chemical Industry of Texas Environmental, Health and Safety Seminar, June 6-9, 2005, Moody Gardens Hotel, Galveston, Texas

OSHA and Chemical Reactivity Hazards Management Alliance implementation team members will also continue to update OSHA's Safety and Health Topics page; Chemical Reactivity Hazards and serve on the Topics page's editorial board. In addition, each signat