Text For Citation: 01 Item/Group: 003B Hazard: EXPLOSION

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 fire and explosion from use of flammable liquids in an OXAD Mother Liquor (ML) distillation process on August 2 and 3, 2006, before job and expert hazard analyses were conducted to identify and control hazards in the process. On August 2 and 3, 2006, the employer ran an OXAD Mother Liquor (ML) distillation process in tank T-644, in line 3 of building 6. There was a reported 3,451 pounds of flammable liquid (methanol) in tank T-644 at the beginning of the distillation. (There were more flammable liquids in tanks in the same line and in the building that could have also been involved in a fire or explosion.) Employees such as Operators, Shift Leaders, a Process Engineer, and an Operations Manager, were potentially exposed to a fire and/or explosion when working on the process. An explosion and fire did occur on 8/3/06. No job or expert hazard analysis was performed before the distillation to identify and control the potential hazards in the OXAD ML distillation process. Such hazard analyses are elements of an effective safety and health program. This hazard was reasonably foreseeable in that it was recognized by employer representatives, the industry, and common sense. Among other methods, one feasible and acceptable abatement method for correcting this hazard is to perform a hazard analysis that is adequate for the complexity of the process. The hazard analysis would include differential scanning calorimetry (DSC) or similar tests, on all mixtures in the distillation. In an OXAD ML distillation operation the hazard analyses would include analyses of: 1.PYM, 2. OXAD Mother liquor, and 3. OXAD Mother liquor after the methyl alcohol distillation removed most of the methyl alcohol. A DSC on the Mother liquor before and after the methyl alcohol was distilled off would help the employer develop the temperature parameters under which it must operate. A DSC on the Mother liquor after the methyl alcohol distillation is necessary because there are many compounds in the Mother liquor which may undergo thermal decomposition at the temperatures used for the methyl alcohol distillation, and their breakdown products may affect the temperatures at which the PYM is distilled. The company must define the temperature limitations of such a distillation before performing it, including boiling points at the pressure of the vacuum, and DSC test exotherm points with respect to the pressure of the vacuum, to avoid thermal decomposition. ABATEMENT VERIFICATION IS REQUIRED