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

Section 5(a)(1) of the Occuptational Safety and Health Act of 1970: The employer did not furnish employment and a place of emloyment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees in and around the pilot plant were exposed to the increased likelihood of fire and explosion due to over-pressurization of the reactor vessel during the paraclox process. Pilot Plant: On or about August 29, 1990 an over-pressurization and subsequent chemical release occurred in kettel #14 during the Paraclox production process. Conditions in the workplace which contributed to the hazard outlined above include the following: A) Standard operating procedures were inadequate, in that process vent lines were not checked prior to chemical additions. B) Operational controls provided were inadequate in that high temperature and pressure alarms were not provided on the reactor vessel. Among other methods, one feasible and acceptable abatement method to correct this hazard is to establish administrative and engineering controls over the work being performed that will include, but not necessarily be limited to, the following provisions: A) Chemical Process Hazard Review Conduct a chemical process system safety hazard review that will identify process deficiencies and upsets plus estimate their frequency and probable consequences. Operating parameters, procedures and/or process control instrumentation determined by this review to be critical for the safe processing of Paraclox shall be designed and constructed for either redundancy or back-up to assure maximum feasible safety to employees. This review shall be of a type generally recognized in chemical processing industries (such as What If, Cause/Consequenc, FMEA, Hazop, Fault Tree, etc.) and shall include, but not necessarily be limited to, the following: I) Preparation and review of process flow sheets to determine possible emergencies during start-up, normal operating and shutdown conditions and to evaluate the consequences of excessive temperatures and pressures or variations in material controls. II) Preparation and review of a piping and instrumentation diagram (P&ID) to assure that controls and instrumentation will detect unusual conditions and that the systems will automatically shut down or can be safely shut down in the event of operator or equipment error. III) Review of raw material MSDSs, product bulletins, technical and scientific literature considering fire, explosion, health, stability and reactivity characteristics including handling, storage, emergency procedures and special precautions. IV) Review of the chemical reaction process considering potential problems arising from abnormal temperature rises, pressure rises and rates of reation; improper addition of reactants including any catalysts and material flow stoppages. V) Review of operating equipment used in the processing of Paraclox considering the adequacy of design and fabrication; effects of corrosion, erosion limitations; equpment leaks and spills; equipment malfunctions and failure; plus maintenance, repair and replacement programs. VI) Review of operating design and potential for operational errors considering detailed operating descriptions and standard operating procedures; accuracy and readibility of control instrucmentation and operator training in process chemistry, hazards and operational procedures. B) Standard Operating Procedures I) Establish written detailed descriptions and standard operating procedures for the manufacture of Paraclox, to assure safe start-up and processing within controllable limits and to provide for safe shutdown of equipment in the event of abnormal conditions. These procedures shall address, but not necessarily be limited to, the following: 1) Start-up procedures for vessel(s) that will include checks to insure process equipment and controls are functioning properly, emergency devices are in proper working order and the vessel is clean and/or otherwise free of possible hazardous contaminants before use. 2) Normal operating procedures for the vessel(s) that will include a defined sequence of operating steps emphasizing those considered to be critical for process safety plus requirements for operator personal protective equipment and practices for safe operation. 3) Emergency shutdown procedures for the vessel(s) that will define abnormal operating conditions and specify sequential steps for safe shutdown of equipment or timely evacuation of operating personnel plus proper removal techniques of any residual flammable, unstable, corrosive or toxic materials. II) Instruct and train all affected management, supervisory and operations personnel in these Standard Operating Procedures. III) Periodically evaluate these standard operating procedures to determine their continued adequacy. Any changes made to these procedures should be thoroughly documented and reviewed. Personnel shall be trained in any revisions along with the reasons for them before they are implemented. C) Operational and Safety Controls Install the following operational and/or safety controls for the manufacture of Paraclox in the Pilot Plant: I) A discharge piping system to a safe location, such as but not limited to a blow down tank in accordance with ASME boiler and pressure vessel code and NFPA requirements. II) High temperature and pressure alarms or Rate of Rise alarms and fail-safe controls to prevent overheating or overpressurization during the precess of Paraclox.