Text For Citation: 02 Item/Group: 001 Hazard: CRUSHING

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: The increased likelihood of leaks, spills and/or uncontrolled releases of hazardous amounts of toluene diisocyanate (TDI) from the A- and B-line urethane foam molding systems resulting from: a) Inadequate safety controls resulting in overflow of the systems' process surge tanks. b) Equipment malfunctions causing resin flow stoppages resulting in unreacted TDI reaching molds. c) Inadequate employee training regarding the systems' operational control features and process valves. d) TDI vapor leaks from the A-line curing over. e) TDI vapor leaks from the threaded joints of process piping in the Tank Room and Surge Tank areas. f) TDI vapor leaks from the seals on process pumps. g) Ineffective local exhaust ventilation on the A- and B-line molding systems. Among other methods, one feasible and acceptable method to correct this hazard is to establish work practice and engineering controls over the work being performed during the manufacture of urethane foam parts such as stipulated by the Chemical Manufacturer's Association, International Isocyanate Institute. Polyurethane Manufacturer's Association and TDI manufacturers that will include, but not necessarily be limited to, the following provisions: a) CHEMICAL PROCESS HAZARD REVIEW Conduct a chemical system process 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 urethane foam products shall be designed and constructed for either redundancy or failure in a safe manner to assure maximum feasible safety to potentially exposed employees. This review shall be documented and of a type generally recognized in the chemical processing industries (such as What if, Cause/Consequence, FMECA, 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 emergency situations that are likely to be encountered during start-up, normal operations, and shutdown conditions in order to evaluate the consequences of excessive temperatures, flows and pressures, or variations in material quantities during these phases of operation. ii) Preparation and review of piping and instrumentation diagram (P&ID) to assure that sufficient controls and instrumentation are provided to detect hazardous process conditions so that the system will either shut down automatically, or can be manually shut down, in a safe manner in the event of operator error or equipment malfunction. iii) Review of raw material MSDS's, product bulletins, technical and scientific literature considering the fire, explosion, health, stability and reactivity characteristics of the chemicals used in the processing systems including handling, storage, emergency procedures and special precautions. iv) Review of the chemical reaction process considering potential problems posed by abnormal temperature rises, pressure rises and rates of reaction; improper addition of reactants, including catalysts; and material flow stoppages. v) Review of the operating equipment used in the processing systems considering the adequacy or design and construction; effects of corrosion, erosion and metal fatigue; potential for exceeding design limitatiosn; equipment leaks and spills; equipment malfunctions and failures; plust 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 reliability of control instrumentation; 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 urethane parts to assure safe start-up, processing within controllable limits and to provide for safe shutdown of equipment in the event of abnormal conditions. These procedures shall include, but not necessarily be limited to the following: 1) Start-up procedures for the processing systems that include checks to insure process equipment and controls are functioning properly and emergency devices are in proper working order. 2) Normal operating procedures for the processing systems that include a defined sequence of operating steps emphasizing those considered to be critical for process safety plus requirements for operator personal protective equipment and work practices for continued safe operation. 3) Emergency shutdown procedures for the processing systems that will define abnormal operating conditions and specify sequential steps for safe shutdown of equipment, timely evacuation of operating personnel and 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 Oeprating Procedures to determine their continued adequacy. Any changes made to these procedures should be thoroughly documented and reviewed before being implemented. Operating personnel shall be trained in any revisions, along with the rationale behing them, before they are introduced. C) OPERATIONAL AND SAFETY ENGINEERING CONTROLS i) Install and/or properly maintain local exhaust ventilation systems capable of adequately removing TDI vapors at the point they are liberated from the process at the following locations on the A- and B-line urethane part molding systems: pour areas, crushing areas and at the openings to the curing ovens. This system could include enclosing the product lines in a ventilated tunnel where feasible. ii) Install continuous ambient air measurement instruments to monitor levels of TDI vapors at strategic locations along the A- and B-line urethane part molding systems to assure ventilation rates are suffi sufficient to keep airborne TDI vapor levels in employee work areas below OSHA Permissible Exposure Limits under all manufacturing conditions. These monitors shall incorporate audible alarms and/or interlocks to initiate safe process shutdown should airborne levels exceed these limits. iii) Install independent high-level alarms and trip systems, incorporating different principles of measurement from the process production controls, that will automaticall stop the flow into process surge tanks to prevent TDI spills resulting from overflows. iv) Weld all permanent threaded connections on TDI transfer lines and associated equipment and/or provide flanges with appropriate mechanical seals at joints where interchangeability is required in order to stop leaks at these locations. v) Identify all manual shut-off valves on the A- and B-line urethane parts molding systems as to purpose and direction of "open" and "shut". vi) Assure that discharge piping from pressure-relieving safety devices and ventilation duct exhausts on the A- and B-line urethane parts molding systems are directed away from platforms, plant air intake ports and other areas used by personnel. It is recommended that such piping terminate at an appropriate scrubber to assure all TDI vapors are properly neutralized prior to discharge from the above source. A written detailed plan of abatement shall be submitted (within 30 days) to the Area Director outlining a schedule for the implementation of engineering and/or administrative measures to control employee exposure. Thirty (30) day progress reports are required during the abatement period.