OSHA Inspection: SAVAGE INDUSTRIES INC,

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Penalty

Initial $640 · Current $540 Reduced

General-duty citation text

Section 5(a)(1): The employer did not furnish employment and a placeof
employment which were free from recognized hazards that were causing or
likely to cause death or serious physical harm to employee(s) in that
employees were exposed to fire and explosion hazards during the
production of Isopropylacrylamide in the 200 gallon glass lined reactor
on January 7, 1987. The following conditions contributed to the
existence of these hazards:
a) An operating procedure for the Isopropylacrylamide production process
was not developed and communicated in writing to employee(s),
including shift supervision, directly involved in the charing and
operation of the 200 gallon glass lined reactor.
b) The cooling jacket of the 200 gallon glass lined reactor was not
supplied with water during the charging of acrylonitrile and sulfuric
acid as a means of controlling heat generation resulting from the
intermixing of these two (2) substances.
c) A high temperature alarm was not installed on the 200 gallon glass
lined reactor to provide an early warning of uncontrolled temperature
increases resulting form teh exothermic reaction of acrylonitrile,
sulfuric acid and isopropanol.
d) A common length of flexible polyethylene piping and a polypropylene
pump were used to charge the 200 gallon glass lined reactor with
acrylonitrile then sulfuric acid without first purging or
decontaminating the piping and pump. These two (2) substances are
incompatable and likelyto result in heat generation when mixed.
Feasible and accepted abatement method(s), among others, include:
1) Implementation of written Standard Operating Procedures for chemical
production and processing operations which contain the following
(Instance (a)):
a) General description of the process
b) Properties of the materials involved
c) Description of the equipment including process equipment,
instrumentation, and protective equipment.
d) Startup and shutdown procedures, including checkout procedures.
e) Normal operating procedures.
f) Safety considerations relative to fire, explosion, accidents, and
health.
g) Safe operating limits.
h) Precautions and actions to be avoided.
i) What constitutes and emergency?
j) Emergency procedures.
2) Utilization of cooling facilities (water jackets, heat exchanges,
etc.) on vessel(s) involved in exothermic reactions as a means to
maintain reaction temperature(s) within safe limits (Instance (b)).
3) Installation of temperature alarm systems on vessel(s) invovled in
reactions where temperature limits are critical to the safety of the
process (Instance (c)).
4) Implementation and enforcement of a policy which assures that common
piping systems are not used to transfer incompatable materials until
such systems are purged and decontaminated (Instance (d)).

Issued

Mar 24, 1987

Abate by

Mar 27, 1987

Penalty

Initial $640 · Current $425 Reduced

General-duty citation text

Section 5(a)(1): 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 employee(s) in that
employee(s) were exposed to health hazards and fire and explosion
hazards, along with hazards of physical injury resulting from the
unintentional activation of reactor agitator(s), during entry into
reactor(s) for the purpose of cleaning such vessels, February 9, 1987.
The following conditions contributed to the existence of these hazards:
a) Flammable organic solvents, including acetone and toluene, were used
by employees while inside the reactor(s) for cleaning the interior
walls of the reactor(s).
b) Air monitoring for flammable vapors or gases and oxygen content was
not performed prior to or during entry in these reactors.
c) In the absence of monitoring for toxic levels of air contaminants,
air supplied respirator(s) with an auxiliary air supply operated in
the positive pressure mode with a full facepiece were not worn by
employee(s) while inside the reactor(s).
d) Employee(s) were not equipped with lifelines and safety harnesses
while inside the reactor(s).
e) Standby worker(s) with suitable rescue equipment were not positioned
immediately outside the manhole with constant communications
capability with the employees in the reactor(s).
f) Positive ventilation was not provided inside the reactor(s), prior to
and during entry, by the use of fans or air movers.
g) Electrical power to the reactor agitator(s) were not locked in the
off position while employee(s) were inside the reactor(s).
A feasible and accepted abatement method, among others, includes the
implementation and enforcement of a tank or confined area entry
procedure which allows entry into a confined space only by "Written
Entry Permit" issued by a responsible supervisor or other qualified
person. This procedure should include, at a minimum, mandatory
provisions for:
1) Prohibiting the use of organic solvents from being used for cleaning
the interior walls of the reactor(s) while employee(s) are inside
the reactor(s) (Instance (a)).
2) Monitoring flammable vapors and gases and oxygen content of the air
inside the reactor(s) (Instance (b)).
3) Monitoring toxic levels of air contaminants inside the reactor(s) or,
in the absence of such monitoring, the requirement that only air
supplied respirator(s) with an auxiliary air supply operated in the
positive pressure mode with a full facepiece be used by employee(s)
while inside the reactor(s) (Instance (c)).
4) Use of lifelines and safety harnesses by employee(s) while inside
reactor(s) (Instance (d)).
5) Standby worker(s) to be continually present immediately outside the
manhole while employee(s) are in the reactor(s). These standby
workers should be equipped with (1) a hoisting device or other
effective means to lift employee(s) from the reactor(s), and suitable
personal protective equipment (Instance (e)).
6) Ventilating the interior of the reactor with mechanical ventilation
prior to and during occupancy (Instance (f)).
7) Locking out the electrical power to the reactor agitator(s) prior to
entry (Instance (g)).

Issued

Mar 24, 1987

Abate by

Mar 27, 1987

Penalty

Initial $360 · Current $260 Reduced

General-duty citation text

Section 5(a)(1): 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 employee(s) in that
employee(s) were exposed to an explosion hazard and health hazard
(resulting from possible los of containment of this material) during the
storage of "Acrylamid-50" (50% aqueous solution of acrylamide monomer)
in the 3,000 gallon stainless teel "Darko" tank and the 2,000 gallon
stainless steel reactor on January 7, 1987.
a) The following condition(s) contributed to the existence of this
hazard at the 3,000 gallon stainless steel "Darko" tank:
i) The tank was not provided with installed cooling and heating (with
tempered water) capability as a means to safely control the
temperature of the "Acrylamide-50."
ii) A continuous air sparging system providing clean, filtered,
temperature monitored air to the "Acrylamide-to" was not installed
on the tank to insure that oxygen is maintained in the solution.
iii) A temperature sensor connected to an alarm was not installed on
the tank to insure that the temperature of the "Acrylamide-50" is
maintained between 60 degrees and 90 degrees F and to immediately
warn of a sudden upward movement in tank temperature.
iv) There was an opening of approximately three (3) feet by two (2)
feet in the top of the tank which would facilitate the accidental
contamination of the "Acrylamide-50" solution.
v) The volume of "Acrylamide-50" in the tank was not maintained below
75% of the tanks capacity to allow adequate room for dilution with
water should polymerization begin.
Feasible and accepted abatement method(s), among others, include:
1) Replacement of the existing "Acrylamide-50"storage vessel with a
closed top vessel equipped with both cooling and heating (with
tempered water) capability. This vessel should also contain an air
sparge system and temperature sensor both of which are connected to
an alarm. Reference the American Cyanamid Company publication
"Handling & Storage Procedures - Acrylamide-50" (Instances (i) (ii)
(iii) and (iv).
Abatement Note: Closed vessels containing "Acrylamide-50" must be
provided with emergency relief pressure vents(s) to protect against
pressure buildup in the event that polymerization of the "Acrylamide-50"
is accidently initiated.
2) Limiting storage in "Acrylamide-50 storage vessels to volumes less
than 75% of the vessel's capacity (Instance (v)).
b) The following conditions contributed to the existence of this hazard
at the 2,000 gallon stainless steel reactor:
i) Heating (with tempered water) of the "Acrylamide-50" solution,
stored in this outside reactor, was not performed during the one (1)
week (approximate) period prior to January 7, 1987 in order to
maintain the temperature of the solution above 60 degrees F.
ii) A continuous air sparging system providing clean, filtered,
temperature monitored air to the "Acrylamide-50" was not installed
on the reactor to insure that oxygen is maintained in the solution.
iii) A temperature sensor connected to an alarm was not installed on the
reactor to insure that temperatures of the "Acrylamide-50" is
maintained between 60 degrees and 90 degrees F and to immediately
warn of a sudden upward movement in reactor temperature.
iv) Emergency relief pressure vent(s) were not installed on the reactor
as a means to relieve reactor pressure in the event that
polymerization of the "Acrylamide-50" is accidnetly initiated.
v) The volume of "Acrylamide-50" in the reactor was not maintained
below 75% of the reactor's capacity to allow adequate room for
dilution with water should polymerization begin.
Feasible and accepted abatement methods, among other, include:
1) Utilization of the reactor's heat exchanger jacket (with tempered
water) to continually maintain stored "Acrylamide-50" at temperatures
between 60 degrees and 90 degrees F.
2) Installation of a continuous-alarmed air sparging system on the
vessel (Instance (ii)).
3) Installation of a temperature sensor connected to a continuous
monitoring indicator and alarm (Instance (iii)).
4) Installation of emergency relief pressure vent(s) properly sized for
the volume of "Acrylamide-50" stored in the vessel (Instance (iv)).
5) Limiting storage in "Acrylamide-50" storage vessels to volumes less
than 75% of the vessel's capacity (instance (v)).

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Penalty

Initial $360 · Current $240 Reduced

General-duty citation text

Section (5)(a)(1): 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 employee(s) in
that employee(s) were exposed to fire and explosion hazards during the
charging and processing of flammable liquids in the 150 gallon and 1000
gallon "Pfaudler" glass lines reactors on February 9, 1987. The
following condition(s) contributed to the existence of these hazards:
a) Outside area (east side of building), an open vent from the 150
gallon "Pfaudler" glass lined reactor was not protected by a flame
arresting device or pressure vacuum (PV) valve.
b) Outside area (east side of building), an open vent from the 1,000
gallon "Pfaudler" glass lined reactor was not protected by a flame
arresting device or pressure vacuum (PV) valve.
Feasible and accepted abatement method(s), among others, include:
1) Installation of a pilot-operated relief valve, a pressure relief
valve(s), a pressure vacuum (PV) valve(s) or a flame arrester on
the opern vent(s) (Instances (a) & (b)).

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Penalty

Initial $810 · Current $600 Reduced

Issued

Mar 24, 1987

Abate by

Apr 8, 1987

Penalty

Initial $360 · Current $240 Reduced

Issued

Mar 24, 1987

Abate by

Apr 8, 1987

Issued

Mar 24, 1987

Abate by

May 30, 1987

Penalty

Initial $360 · Current $300 Reduced

Issued

Mar 24, 1987

Abate by

Apr 8, 1987

Issued

Mar 24, 1987

Abate by

Mar 31, 1987

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Penalty

Initial $300 · Current $200 Reduced

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Issued

Mar 24, 1987

Abate by

Apr 8, 1987

Penalty

Initial $300 · Current $200 Reduced

Issued

Mar 24, 1987

Abate by

Apr 8, 1987

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Penalty

Initial $640 · Current $540 Reduced

Issued

Mar 24, 1987

Abate by

May 30, 1987

Penalty

Initial $4,200 · Current $2,800 Reduced

Issued

Mar 24, 1987

Abate by

Mar 27, 1987

Issued

Mar 24, 1987

Abate by

Mar 27, 1987

Issued

Mar 24, 1987

Abate by

Mar 27, 1987

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Issued

Mar 24, 1987

Abate by

Mar 27, 1987

Issued

Mar 24, 1987

Abate by

Jun 15, 1987

Issued

Mar 24, 1987

Abate by

Jun 15, 1987

Issued

Mar 24, 1987

Abate by

Jun 15, 1987

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Issued

Mar 24, 1987

Abate by

Apr 30, 1987

Issued

Mar 24, 1987

Abate by

Apr 30, 1987