Text For Citation: 02 Item/Group: 001A 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 the hazard of explosions (detonations and/or deflagrations) due to runaway chemical reaction: BLDG 266: DUE TO IMPROPER APPLICATION OF CHEMICAL TECHNOLOGY, THE EMPLOYER ALLOWED CHEMICALS TO REACT SO AS TO CAUSE A RUNAWAY CHEMICAL REACTION WHICH EXPLODED. AMONG OTHER METHODS, ONE FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT THIS HAZARD IS TO ESTABLISH AND IMPLEMENT A CHEMICAL PROCESS SAFETY MANAGEMENT PROGRAM WHICH WILL INCLUDE, BUT NOT NECESSARILY BE LIMITED TO THE ELEMENTS OF 29 CFR 1910.119 AND THE FOLLOWING POLICY ELEMENTS. A. QUALITY CONTROL POLICY 1. ESTABLISH A CHEMICAL ANALYSIS PROGRAM WHEREBY ALL REAGENTS, SOLVENTS (NEW, RECYCLED OR RECYCLABLE) AND IN-HOUSE SYNTHESIZED INTERMEDIATES ARE CHECKED FOR CHEMICAL PURITY TO ENSURE EXPLOSIONS ARE NOT INITIATED BY CONTAMINANTS. B. SAFE PRACTICES POLICY 1. CONDUCT HEAT TRANSFER CALCULATIONS FOR REACTIONS AND EQUIPMENT TO ENSURE THAT REACTIONS CAN BE HELD WITHIN THE REQUIRED PARAMETERS TO PREVENT RUNAWAY REACTIONS WHICH COULD CAUSE EXPLOSIONS. 2. CONDUCT MASS BALANCE CALCULATIONS TO ENSURE THAT AN ACCOUNTING IS PROVIDED FOR ALL REACTANTS USED IN THE CHEMICAL REACTIONS. 3. COMPARE MASS BALANCE CALCULATIONS WITH ACTUAL INVENTORY DEPLETIONS TO ENSURE THAT REACTANTS ARE BEING USED IN PROPER RATIOS TO PREVENT REACTANTS FROM CONCENTRATING IN SOLVENT SYSTEMS AND INITIALLY UNANTICIPATED EXPLOSIONS C. HAZARD ANALYSIS/OPERATING PROCEDURE POLICY 1. OPERATING PROCEDURES SHALL INCLUDE METHODS FOR ELIMINATING THE CHEMICAL HAZARDS WHICH ARE CAPABLE OF CAUSING UNANTICIPATED EXPLOSIONS AND WERE IDENTIFIED IN THE HAZARD ANALYSIS OF THE CHEMICAL PROCESS. D. SCALE UP POLICY 1. CHANGES TO THE EXPERIMENTAL EXPLOSIVE MANUFACTURING PROCESS SHALL BE SCALED UP STEP WISE FROM TEST TUBE QUANTITIES, TO BENCH SCALE QUANTITIES, TO PILOT PLANT SCALE QUANTITY, TO ENSURE THAT CHEMICAL REACTIONS CAN BE CONTROLLED AND DO NOT RUN AWAY AND INITIATE EXPLOSIONS AND/OR EMIT HAZARDOUS VAPORS. E. REACTOR VESSEL DECONTAMINATION POLICY 1. BEFORE ANY REACTANTS ARE CHANGED INTO THE CHEMICAL REACTOR, IT SHALL BE THOROUGHLY CLEANED AND RINSED. THE RINSATE SHALL BE CHEMICALLY ANALYZED AT LEAST QUALITATIVELY WITH A PROPER INDICATOR (PH PAPER FOR EXAMPLE) TO ENSURE CONTAMINATES CAPABLE OF INITIATING AN EXPLOSION ARE NOT PRESENT. F. INCIDENT INVESTIGATION POLICY 1. ALL INCIDENTS WHICH COULD HAVE OR DID CAUSE EXPLOSIONS AND/OR FIRES MUST BE FORMALLY INVESTIGATED. THE INVESTIGATION MUST START WITHIN 48 HOURS OF THE OCCURENCE. THE REPORT MUST BE MADE BY A COMPETENT PERSON FAMILURE WITH THE PROCESS AND WILL CONTAIN A FINDING OF THE CAUSE OF THE INCIDENT AND RECOMMENDATIONS TO PREVENT RECURRENCE. THE EMPLOYER MUST RESPOND TO THE RECOMMENDATIONS AND DISCUSS THEM WITH THE AFFECTED EMPLOYEES. G. OPERATING EMPLOYEES TRAINING POLICY 1. ALL EMPLOYEES WHO WILL WORK ON THE DEVELOPMENT AND/OR PRODUCTION OF EXPLOSIVES WILL BE THOROUGHLY TRAINED ON THE CONTENTS OF 29 CFR 1910.119 AND THE POLICY ELEMENTS.