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 fire and explosion hazards during the production of Incrodet TD-7C on April 30, 1997. The following conditions contributed to the existence of these hazards: (a) The Manufacturing Procedure which was used as an operating procedure did not provide clear step-by-step instructions for the employees to safely conduct all operations involved in the process. (b) A complete hazard and operability study of the production of Incrodet TD-7C was not conducted to determine the hazards related to the equipment, the method of production and the chemicals used in the process. (c) A venting system or other method to eliminate and/or control any hazardous atmosphere in the headspace and the monitoring of the headspace was not ensured. (d) The presence of possible ignition sources had not been evaluated or eliminated. ABATEMENT NOTE Among other methods, one feasible and acceptable abatement method to correct this hazard is to: 1. Implement a Standard Operating Procedure for each processing operation which contains the following: (a) Description of the process; (b) Properties of the materials involved; (c) Description of the equipment, instrumentation, and protective equipment; (d) Startup and shutdown procedures; (e) Normal operating procedures; (f) Safety considerations relative to fire, explosion, accidents, and health; (g) Safe operating limits; (h) Precautions and actions to be avoided; (i) Emergency procedures. 2. Implement a program to identify and evaluate hazards using procedures recognized and used throughout the industry. These would include a compilation of process safety information and a review of the information. 3. Utilize a venting system or method to control and/or eliminate any hazardous atmosphere in the headspace of the reactor and monitor this to ensure its effectiveness. 4. Identify and eliminate all possible ignition sources.