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

Section 5(a)(1) of the Occaupational 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 contractor employees in the washer area were exposed to the recognized hazards of physical contact with hot stock and inhalation of sulfur dioxide gas in concentrations that exceeded 200 parts per million during single stage washing while washer rebuild was underway. The following conditions condtributed to the existence of this hazard: a) Following inadvertant shutdown of the #13 repulper, the interlocked washer automatically shutdown. There were no automatic interlocks between the washer (high level sensor or drum) and any of the following: 1) Washer supply pumps. 2) Filtrate pumps, or 3) Stock valves. Overflow of the #3 washer at the rate of 3000 gallons per minuted occured. b) The high level stock alarm was not hooked up prior to bringing #3 washer back on line; contractor employees working below had no warning of the overflow condition. c) Floor drains that were open to the heat exchanger floor below during repiping were not sealed nor were dikes constructed around #3 washer to contain a spill-overflow; hot stock spilled onto the washer floor and freely flowed through the open drains onto contract employees and heat exchangers where sulfur dioxide immediately flashed off at concentrations in excess of 200 ppm. d) Access to the vat drains was on the washer floor and not immediately accessable to washer operators. e) The employer did not perform a pre-starting safety review following system modification to ascertain that safety, operating, maintenance and emergency procedures were in place and adequate prior to startup. ABATEMENT NOTE: Feasible means of abatement, among others, include the following: 1) Conduct a pre-startup safety review to confirm the following prior to introducing hazardous chemicals into the process. a) Construction is in accordance with design specifications. b) All safety and emergency procedures are in place and are adequate. c) Process hazard analysis recommendations have been addressed and actions necessary for startup have been completed. d) Operating procedures are in place and training of each employee has been completed. 2) Install interlocks between the washer (high level sensor and supply pumps and valves. 3) Connect not only the alarm to high level sensors but install area sulfur dioxide monitors throughout the washer area. 4) During maintenance involing floor drain system, seal drains and dike operating washers, monitor closely maintenance activities beneath operating washers. 5) Move access to each vat drain to the operator's control room to expedite process and reduce exposure potential to operator helper required to open drain.