Text For Citation: 01 Item/Group: 001 Hazard: CHEMICAL

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to: a. In that employees working in the vicinity of the 2,000 gallon reactor (N1001) during process operations (such as the production of R-Glycidol and the treatment of "Raffenate Waste") were exposed to increased risks of fires, explosions, hot materials, and toxic materials caused by the release of processed materials from the reactor or its associated equipment, and due to the employer not taking adequate measures to prevent the hazardous release of corrosive, flammable, and/or toxic mateials, in that: 1. The pressure relieving device for the reactor was a pressure safety valve one inch in diameter. There was no documentation available to describe its design, sizing and relieving capacity. It was not documented that it was accurately sized to safely handle runaway reactions and fire load situations. 2. Formulation changes were made by Organic Technologies, Inc. to the "Raffenate Waste" including, but not limited to, replacing sodium meta bisulphite with formaldehyde in the reduction and treatment of peroxides. The company made the changes without re-evaluating the adequancy of the N1001 reactor vessel and its safety line and valve to ensure its ability to safely handle runaway reactions and fire load situations. 3. The discharge locations and the orientation of the safety valves and vents of the reactor, and of its associated equipment (including the condensor, its saftey valve, and the reactor's vent line) were not directed to a catch tank, header pipe, flare system, fire pit, or other safe location. The chemicals that were processed were known to be highly reactive, corrosive, flammable, and/or toxic. 4. Operating practices were inadequate. The employer did not provide formal written operating procedures to be used in normal and abnormal situations. The employer did not clearly define the boundaries between normal and abnormal operating situations. The employer did not clearly define the steps that were to be taken to return the operating situation from abnormal back to normal operation. The employer did not clearly define the operator's authority to exercise the steps to return the operation to normal, nor did the employer clearly define the situations under which the operators were to declare an emergency, inform management, and turn over the control responsibility to the plant manager or to his/her designated emergency manager. 5. The employer did not establish a formal training program to instruct the operators in their duties and responsibilities regarding the reactor operating procedure. The employer did not test the operators to ensure their full understanding of their responsibilities. Having not given the operators specific operating instructions and no formal training, the employer did not closely monitor and control the actions of the operators, using managers who had been formally educated in chemical engineering and in the operation of chemical reactors.