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 phenethyltrichlorosilane in the 100 gallon still on June 21, 1994. The following conditions contributed to the existence of these hazards: a) The operating procedure for the phenethyltrichlorosilane (p0110) product did not provide clear instructions for safely conducting all activities involved in each step of the process. b) Employees were not properly trained in standard operating procedures and were not adequately trained in the safe handling, processing and storage of flammable liquids. c) The mechanical integrity and compatibility of all process equipment was not initially or periodically inspected as necessary by the hazards of the process or frequency of use. d) A complete hazard and operability study of the p0110 process was not conducted to determine likely hazards related to equipment, procedures and chemicals used in the process. ABATEMENT NOTE: Among other methods, one feasible and acceptable abatement method to correct this hazard is to: 1. Implementation of written Standard Operating Procedures for each chemical production and processing operation which contain, at least, the following (Instance (a)): a)General description of the process. b)Properties of the materials involved. c)Description of the equipment including process equipment, instrumentation, and protective equipment. d)Startup and shutdown procedures, including checkout 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)What constitutes an emergency? j)Emergency procedures. 2. Implementation of training program for all chemical operators to include the following (Instance (b)): a) Process goals economics, constraints and priorities b) Process flow diagramc)Unit operations d)Process reactions, thermal effects e)Control systems f)Process materials quality, yields g)Process effluent and wastes h)Plant equipment i)Instrumentation j)Equipment identification k)Equipment manipulation l)Operating procedures m)Equipment maintenance and cleaning n)Use of tools o)Permit Systems p)Equipment failure, services failure q)Fault administration r)Emergency procedures s)Fire fighting t)Malpractice u)Communication, record-keeping, reporting 3. Implementation of a program to inspect all process equipment and containers before initial use and thereafter on a periodic basis to included at least the following (Instance (c)): a)Reliability engineering b)Materials of construction c)Fabrication and inspection procedures d)Installation procedures c)Preventive Maintenance d)Process hardware and systems inspections and testing e)Maintenance procedures f)Alarm and instrument management g)Decommissioning and demolition procedures 4) Implementation of a program to evaluate and identify process hazards using procedures which have been recognized and used throughout the chemical industry. These procedures would include the gathering of process safety information and a formal evaluation of that information (Instance (d)).