UNITED STATES
DEPARTMENT OF LABOR

Text For Citation: 01 Item/Group: 001 Hazard:

OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which was 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 hazards while working with pyrophoric liquids. Location: Cylinder Prep 1 On or about January 7, 2016, the employer failed to adequately design, inspect, maintain and operate the trimethyl aluminum cylinder reclaim process to prevent oxygen (e.g. in air or water) from contacting and igniting trimethyl aluminum, a pyrophoric chemical, resulting in fire and to explosion hazards to employees Among other methods, feasible and acceptable abatement method to correct this hazardous condition include the following: 1. Performing non-destructive testing on the welds to ensure they are full thickness welds and are of the appropriate materials. The American Welding Society D1.1/D1.1M:2010, Structural Welding Code ? Steel The requirement for welding procedures is in Part A, Section 3. The requirement for NDT (non-destructive) inspection is in Part C, Paragraph 6.11.1 which states, ?6.11.1 Tubular Connection Requirements. For Complete Joint Penetrations groove butt welds welded from one side without backing, the entire length of all completed tubular production welds shall be examined by either RT (radiographic) or UT (ultrasonic). The acceptance criteria shall conform to 6.12.1 or 6.13.3 as applicable.? 2. Implement a regular inspection schedule for all items used with pyrophoric chemicals. NFPA 400, Hazardous Materials Code, Section 6.1.16 states, "Equipment, machinery, and required detection and alarm systems associated with hazardous materials shall be maintained in an operable condition. The following shall apply to defective containers, cylinders, and tanks: (1) They shall be removed from service, repaired, or disposed of in an approved manner." Center for Chemical Process Safety (CCPS), Guidelines for Mechanical Integrity Systems, states, "In many respects the Inspection, Testing and Preventive Maintenance (ITPM) program is the core of the mechanical integrity program. The ITPM's objective is to identify and implement maintenance tasks needed to ensure the ongoing integrity of the equipment." CCPS, Guidelines for Safe Storage and Handling of Reactive Materials, states, "A management system is needed to ensure that all parts of a reactive materials containment system is constructed and maintained to a high degree of mechanical integrity for obvious reasons. The components of such a management system include preventive maintenance, inspection and testing" 3. Thoroughly investigate any incident of smoke, fire or explosion and ensure similar controls are implemented for all processes where pyrophoric liquids are handled. CCPS, Guidelines for Safe Storage and Handling of Reactive Materials, states, "Prompt and careful investigation of such accidents should identify the underlying management system failures, develop necessary corrective actions, and effectively communicate the results of the investigation to all affected parties and regulatory authorities as required by law." CCPS, Guidelines for Process Safety Fundamentals in General Plant Operations, states, "In an ongoing safety program, incidents and accidents are investigated and analyzed to reduce the likelihood of recurrence. The information gained from these investigations is used to develop corrective action. An assigned group should investigate both personal injury and property damage incidents. The seriousness or potential of the incident will dictate the extent of the investigation. Such an investigation identifies and locates principle hazards and outdated or inefficient processes and procedures. The analysis should produce recommendations for changes to work methods, equipment, processes and training programs." 4. Perform all work with pyrophoric chemicals in an inert atmosphere such as a glove box. The U.S. Department of Energy PNNL-18668 states "Therefore, it is highly recommended that reagents (liquids or solids) be used whenever possible within the confines of the glovebox or equivalent. Caution must be exercised when removing pyrophoric contaminated glassware, wipes, spatulas, gloves, or septa from the glovebox. When possible, the contaminated equipment should be neutralized inside the glovebox prior to removal." 5. Create procedures to troubleshoot a rate-of-rise test and for trap change out. NFPA 400, Hazardous Materials Code, Section 7.3.1 states, "Operating procedures shall be developed for processes regulated by this chapter and implemented in accordance with Section 7.3. Operating procedures shall address the following: (1) Each operating phase including, but not limited to, startup, operation, shutdown, and startup after unscheduled shutdown (2) Operating limits (3) Safety and health controls (4) Safety systems." CCPS, Guidelines for Safe Storage and Handling of Reactive Materials, states, "Due to the hazardous nature of reactive materials, they are often handled in smaller quantities and container sizes than bulk commodity chemicals. For this reason, manual handling of containers ranging from small cartons to drums and tote bins is commonly required. However, manual handling inherently has different incident potentials than piping system transfers. In particular, the close proximity of the operator to the reactive material and the potential for dropping or collision? Therefore, some companies avoid all manual handling of certain highly reactive materials." CCPS, Guidelines for Process Safety Fundamentals in General Plant Operations, states, "Process equipment and procedures? A group of common considerations applies? Design? safe operating limits must be defined. Materials of construction and seals must be appropriate for the application? Operations. The equipment must be operated within design conditions. Operating procedures must be available and scrupulously observed?"