Text For Citation: 01 Item/Group: 013 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. An example on 4/1/04 through 7/19/04 was the suspect accuracy of the portable methyl iodide ToxiRAE monitors used by First Operators, Team Managers, and Utility Operators in plant 22. The instruments were used to define when evacuation was necessary and when respirators such as self-contained breathing apparatus (SCBAs) were required for re-entry into the containment area, during methyl iodide release and exposure situations. Calibration data for the instruments provided for the dates listed above showed that 20 of 30 (67) of the instruments had failed calibration in the "as found" state. No records were kept of how far out of calibration the instruments were, and the calibration interval (2 months) was not adjusted in consideration of the failure record. The employer recognized the toxicity of methyl iodide (MeI), as evidenced by its material safety data sheet (MSDS) on that chemical. He also recognized the need for protection against exposures to the gas, as evidenced by his "Acetic Anhydride Department Policy for MeI Personal Protective Equipment and Response to MeI Leak" and "MeI Containment System Normal Operating Procedure - Normal Operation - MeI Spill or Leak Indicated in Plant 22 Containment Area" procedures. The above-listed employees were potentially exposed to hot (242.6oF) chemical vapors and liquids from process chemicals which could be released if equipment leaked. Such a leak occurred on heat exchanger 22E-26 on 3/29/04, and it proved fatal. One of the process chemicals was methyl iodide. The hazard of inaccurate portable MeI monitors was reasonably foreseeable. Among other methods, one feasible and acceptable abatement method to correct this hazard was: a.Keeping full "as found" calibration concentration records for "benchmarking tests" ("bump tests," "accuracy tests," or "calibration as found tests") so that the level of inaccuracy of a failed test would be known; and b.Adjusting the frequency of calibration so that the accuracy of the portable monitors could be ensured. Note that the Operation and Maintenance Manual for the ToxiRAE instrument, in section 4.4, page 4-7, states: "For maximum safety, the accuracy of the ToxiRAE should be checked by exposing the sensor(s) to known concentration calibration gas before each day's use." ABATEMENT VERIFICATION IS REQUIRED.