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Occupational Safety and Health Administration OSHA

Violation Detail

Standard Cited: 5A0001 OSH Act General Duty Paragraph

Violation Items

Nr: 301669537 Citation: 01001 Issuance: 08/19/2002 ReportingID: 0111100

Viol Type:Serious NrInstances:1 Contest Date:
Abatement Date:09/21/2002 X Nr Exposed:50 Final Order:
Initial Penalty: $4,500.00 REC:R Emphasis:
Current Penalty: $3,200.00 Gravity:10 Haz Category:CHEMICAL

Penalty and Failure to Abate Event History
Type Event Date Penalty Abatement Type FTA Insp
Penalty Z: Issued 08/19/2002 $4,500.00 09/21/2002 Serious  
Penalty I: Informal Settlement 09/06/2002 $3,200.00 09/21/2002 Serious  

Text For Citation: 01 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 were exposed to the hazards of gas and vapor explosions: a)At the Polyester Reactors, including the Let Down Kettle Reactor - Employees were exposed to the hazards of gas explosions or gas and vapor explosions from the ignition of the flammable decomposition products of chemical additives. b)Specialty Resins Department, Reactors, including the Polyester Reactors and the Let Down Kettle Reactor - Employees were exposed to the potential hazards of gas and/or vapor fires and explosions in the manufacture of resins. Will abate item (6) as was done in item (a) completion date 01/31/03 Included among the feasible controls for these fire and explosion hazards were: 1.Instead of charging additives through large material charge openings (manways) in reactors, design and install closed pots at the reactors to be able to charge additives without opening the large manway openings. 2.Calculate, provide, control, and specify in operating procedures an adequate flow of nitrogen through the reactors to ensure a nitrogen purge of oxygen from the headspace of the reactors when the manway doors are opened. Test for oxygen in the reactor headspace and test for concentrations of vapors at the face of the manway openings to ensure that vapor concentrations do not exceed 10of the lower explosive limit. 3.Identify all other potentially hazardous additives that could potential trigger incidents of fire or explosion. For these additives institute the controls described in items 1.and 2. above. 4.Conduct Process Hazard Analyses (PHAs) on written procedures involving potentially hazardous additives. Provide written hazard danger warnings in written manufacturing procedures at steps prior to a danger in which an operator mistake could lead to a serious incident. Consider engineering or administrative controls to limit these hazardous steps. Where PSM (Process Safety Management) processes are involved, conduct PHAs on the standard operating procedures and add appropriate danger warnings prior to potential hazardous steps in the procedures. 5.Add potentially hazardous additives to other materials to lower their hazard potential when they are being added to reactors. 6.Train operators in the explosive and decomposition hazards of resin ingredients, including additives. List decomposition temperatures of materials that are belowthe highest operating temperatures. List the flash points of liquids that are below the highest operating temperatures. Train operators in the specific hazards identified by these lists and add appropriate danger warnings to the written operating procedures involving these materials. 7.Install alarmed sensors or monitors at the face of the reactor manways when they are opened to assure no vapors concentrations above 10of the Lower Explosive Limit (LEL) existed at the open manways.

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