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

T.C.A. 50-3-105(1): 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.Fire and explosion from not developing and following safe work practices or procedures for starting up and lighting the Super Allcase Endothermic Heat Treating Furnace. On 10/2/06 and 10/16/06 employees attempted to start up and ignite this furnace and were exposed the explosions and fires, which resulted in serious injuries to both. No safe work practice or procedure had been developed for the startup and ignition of this furnace (and others), and a startup procedure that did exist (although it did not include necessary initial steps for safety) was not used or followed. No safe startup and lighting procedure existed for the above-mentioned furnace existed on 9/27/07; b.Repeated accidents, such as those involving fire and explosion, from not having an accident/incident investigation procedure to discover causes and recommend actions to be taken to prevent recurrence of accidents/incidents of the same nature. No accident/incident investigation procedure existed and none was implemented after the 10/2/06 accident mentioned above (and none existed or had been implemented on 9/27/07). No corrective actions were determined and implemented to prevent the 10/16/06 accident (which involved the same cause) from occurring; c.Potential exposure to ammonia, from not having an emergency procedure in place to protect employees in the event of a possible leak of anhydrous ammonia. On 9/27/07, there was a 500 gallon tank (over 2,500 pounds) of anhydrous ammonia outside the plant building that was fed into the building by pipe for eventual feed to equipment such as endothermic heat treating furnaces. All employees were potentially exposed to this hazard; d.Potential exposure to ammonia and flammable gases, such as endothermic gases and natural gas, from lack of an equipment inspection/maintenance program and schedule for piping, valves, and other equipment in these gas delivery systems. These gases were piped into either the endothermic generator or endothermic heat treating furnaces, and lack of an equipment maintenance program made employee exposure to gas release hazards more likely. Developing and enforcing safe work practices or procedures, an accident/incident investigation procedure with recommended corrective actions, an emergency procedure for potential hazardous gas releases, and an equipment inspection/maintenance program for hazardous chemical (including gas) delivery systems equipment are all accepted elements of an effective safety and health program. With reasonable diligence, the employer is expected to have such an effective safety and health program. This hazard was reasonably foreseeable in that it was recognized by the industry and common sense. Among other methods, feasible and acceptable abatement methods for correcting this hazard are to: a.Develop and implement a safe work practice/procedure for startup and ignition of endothermic heat treating furnaces, such as the Super Allcase Furnace. Implement employee training to familiarize employees with the necessity of following such procedures, then enforce the procedures; b.Develop and implement an accident/incident investigation procedure that defines causes of accidents/incidents and provides recommendations to prevent their recurrence; c.Develop a safe emergency procedure for dealing with an anhydrous ammonia (and other hazardous gas) release. Train employees in the procedure, and practice it; and d.Develop and implement an equipment inspection/maintenance program for hazardous gas delivery piping, valves, and other system components where gas leaks are possible due to deteriorating, damaged, or otherwise faulty equipment. ABATEMENT VERIFICATION IS REQUIRED