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 increased risk for injury related to fire, deflagration and explosions related to chemical processes in chemical manufacturing operations: Howard Industries -1840 Progress Avenue, Columbus, Ohio facility: a.)On April 13, 2011, an uncontrolled reaction involving the blending and packaging of a sodium chlorite product (Truox Precursor) caused a fire and explosion. The employer did not have procedures for evaluating chemical reaction, self-reaction and physical hazards when designing and operating the chemical processes associated with their manufacturing operations, such as the blending of chemicals that pose an increased risk for fire and explosion. Prior to initiating blending activities on this date, the employer had not properly evaluated the chemical reaction hazards, other physical hazards, and process equipment associated for the design of a chemical process for the production of a chemical, known as "Truox PreCursor," of which sodium chlorite, is the main ingredient. Sodium chlorite reacts with reducing agents, organic materials, heavy metals, and chlorine donors, self-reacts when reaching temperatures at or above 347 degree Fahrenheit and is sensitive to frictional forces and compaction. The employer did not evaluate the chemistry, the appropriate equipment for use, appropriate work procedures and instructions, ignition source control, or perform any small scale test batch runs for use in material testing and analyzing scale-up effects associated with this chemical manufacturing operation. During blending operations on April 13, 2011, a fire and subsequent explosion occurred involving sodium chlorite, the equipment used in the blending operation and the other associated chemicals involved in the blending operation. ABATEMENT NOTE: Among other methods, feasible and acceptable methods to correct this hazard would be (1) to develop procedures for determining the reactivity and chemical compatibility of manufacturing operation chemicals, determining the associated energy and rates of potential reaction(s), and determining equipment compatible with the manufacturing process or operation. The employer can utilize the following sources to incorporate a systematic approach in developing the aforementioned procedures: American Institute of Chemical Engineers Center for Chemical Process Safety (AICHE CCPS) Guidelines for Safe Storage and Handling of Reactive Materials, AICHE CCPS Guidelines for Chemical Reactivity, AICHE CCPS Guidelines for Process Safety in Batch Reaction Systems, Factory Mutual Global Report 7-43 Loss Prevention in Chemical Plants, Perry's Chemical Engineers' Handbook, National Fire Protection Association (NFPA) Fire Protection Handbook and AICHE CCPS Essential Practices for Managing Chemical Reactivity Hazards, (2) require information detailing hazards of reaction, energy and incompatibility for equipment from potential customers, (3) develop management of change procedures, or risk analysis procedures, for handling deviation from establishedor changes in previously performed operations, (4) utilizing the principles found in and/or complying with NFPA 77 Recommended Practice on Static Electricity, 2007 edition, Chapter 7, and (5) use of a third-party firm with appropriate experience and credentials for analyzing specific chemical manufacturing operations and developing safe operational processes, procedures, including identifying appropriate, compatible equipment for the purpose of developing these items, or for the purpose performing an audit, or verification of internally developed procedures.