Text For Citation: 02 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 while drying, handling, and packaging benzoyl peroxide were exposed to a fire/explosion hazard as a result of confinement, deflagration, and rapid explosive decomposition of the benzoyl peroxide: a.In the paste room of building #2, the employer utilized a Schwelmer glass-lined, double cone vacuum dryer without implementing effective controls for the drying of benzoyl peroxide. The employer exposed employees to a fire/explosion hazard as a result of confinement and rapid explosive decomposition of the benzoyl peroxide in the drying unit. On or about January 2, 2003, an uncontrolled explosion occurred in the vacuum dryer while benzoyl peroxide was being dried. Among other methods, feasible and acceptable abatement methods to correct this hazard include, but are not limited to, the following: Conduct an organized and systematic evaluation (process hazard analysis) of the drying operation at the facility that will effectively identify potential causes and consequences of safety and health hazards. The hazard analysis which identifies, evaluates, and controls the hazards should be performed and documented for items such as the following: Hazards of the process. Facility layout of operations. Selection of materials and equipment. Process control parameters. Personal protective equipment and barriers. Engineering and administrative controls. Consequences of failure of engineering and administrative controls. Human factors. Develop and implement written operating procedures that provide clear instructions for safely performing activities involved in the drying operation of benzoyl peroxide. Develop and implement a preventative maintenance program that provides for inspection, maintenance, and testing of the drying equipment and associated hardware. Develop and implement an equipment cleaning procedure and schedule for the dryer and all related equipment and tools. Develop and implement a contractor and hot work program for work that is conducted in the area where benzoyl peroxide is dried. Provide training for peroxide processors with the emphasis on the specific safety and health hazards of the process, emergency operations, and safe work practices applicable to the employee's job task. Ensure that no impurities are in the raw material by performing tests or the equivalent.Evaluate the damage to the glass lining inside the dryer to determine whether contact between benzoyl peroxide and the glass pieces or underlying carbon steel will create a hazardous condition, and take other necessary actions to guard against possible benzoyl peroxide contamination with other reactive materials. Ensure that the vacuum dryer and all attached equipment were effectively grounded and bonded to control static electricity. Guard against overheating the benzoyl peroxide by installing redundant temperature controls such as an upper high temperature limit control to shut off the source of heat if the temperature controller fails to operate properly. Do not rotate the benzoyl peroxide in the dryer due to the friction and shock sensitivity of the material and creation of a dust cloud. Do not confine the benzoyl peroxide while drying the material to greater than 97due to the potential for explosion unless adequate relief venting can be installed. Dry only small quantities of benzoyl peroxide at a time to minimize the hazard. Conduct the drying operation of the benzoyl peroxide remotely. Follow accepted industry guidelines and engineering standards such as Publication #AS-109 Safety and Handling of Organic Peroxides: A Guide, Classification Guidance of Organic Peroxides for NFPA 704, HMIS Classification Guidance for Organic Peroxides, and other information prepared by the Organic Peroxide Producers Safety Division of The Society of the Plastics Industry, Inc.; and procedures for the safety and handling of organic peroxides developed by competing businesses. Utilize good and accepted work practices such as those found in the following resources: Chemical Safety Data Sheet SD-81 Properties and Essential Information for Safe Handling and Use of Benzoyl Peroxide; NIOSH A Recommended Standard for Occupational Exposure to Benzoyl Peroxide; Explosive and Toxic Hazardous Materials by James H. Meidl; Occupational Health Guideline for Benzoyl Peroxide; and New Jersey Department of Health Hazardous Substance Fact Sheet. Follow the guidelines established by NFPA such as NFPA 77 Recommended Practice on Static Electricity; NFPA 432 Code for the Storage of Organic Peroxide Formulations; and NFPA 70 National Electrical Code. b.In the paste room of building #2, the employer failed to establish controls for the handling of dried benzoyl peroxide, such as the collection of QC samples, the unloading of the vacuum dryer, and the screening/packaging of dried benzoyl peroxide. Employees engaged in handling dried benzoyl peroxide were exposed to a fire/explosion hazard as a result of deflagration and/or rapid explosive decomposition. Among other methods, feasible and acceptable abatement methods to correct this hazard include, but are not limited to, the following: Conduct an organized and systematic evaluation (process hazard analysis) of the handling of dried benzoyl peroxide at the facility that will effectively identify potential causes and consequences of safety and health hazards. The hazard analysis which identifies, evaluates, and controls the hazards should be performed and documented for items such as the following:Hazards of the process. Facility layout of operations. Selection of materials and equipment. Process control parameters. Personal protective equipment and barriers. Engineering and administrative controls. Consequences of failure of engineering and administrative controls. Human factors. Develop and implement written operating procedures that provide clear instructions for safely performing activities involved in the handling of dried benzoyl peroxide. Develop and implement procedures for the decontamination of equipment and containers used to collect, transport and weigh the material. Develop and implement spill control and cleanup procedures including recovery of the spilled material and decontamination of the effected surfaces. Develop and implement a contractor and hot work program for work that is conducted in the area where dried benzoyl peroxide is handled. Provide training for peroxide processors with the emphasis on the specific safety and health hazards of the process, emergency operations, and safe work practices applicable to the employee's job task. Guard against possible benzoyl peroxide contamination with other reactive materials. Handle only small quantities of dried benzoyl peroxide at a time to minimize the hazard. Ensure that all hand tools such as the metal hanger used to collect samples and the crescent wrench are made of non-sparking materials. Ensure that transfer containers, equipment, and all components are properly grounded and bonded when collecting samples, unloading the dryer, transferring the material, and screening/packaging the product. Ground employees involved in collecting samples, unloading the dryer, transferring the material, and screening/packaging the product by using grounding ankle straps or conductive floors and conductive footwear. Test to ensure that all personnel and equipment grounding and bonding is adequate. Install and utilize a protective barrier or shield between the employees and the unloading of the dryer. Conduct the unloading and handling operation of the dried benzoyl peroxide remotely. Follow accepted industry guidelines and engineering standards such as Publication #AS-109 Safety and Handling of Organic Peroxides: A Guide, Classification Guidance of Organic Peroxides for NFPA 704, HMIS Classification Guidance for Organic Peroxides, Organic Peroxide Spill Clean Up, and other information prepared by the Organic Peroxide Producers Safety Division of The Society of the Plastics Industry, Inc.; and procedures for the safety and handling of organic peroxides developed by competing businesses. Utilize good and accepted work practices such as those found in the following resources: Chemical Safety Data Sheet SD-81 Properties and Essential Information for Safe Handling and Use of Benzoyl Peroxide; NIOSH A Recommended Standard for Occupational Exposure to Benzoyl Peroxide; Explosive and Toxic Hazardous Materials by James H. Meidl; Occupational Health Guideline for Benzoyl Peroxide; and New Jersey Department of Health Hazardous Substance Fact Sheet. Follow the guidelines established by NFPA such as NFPA 77 Recommended Practice on Static Electricity; NFPA 432 Code for the Storage of Organic Peroxide Formulations; and NFPA 70 National Electrical Code.rical