OSHA Inspection: CRODA INC

Issued

Sep 16, 1997

Abate by

Nov 19, 1997

Penalty

Initial $1,375 · Current $1,375

General-duty citation text

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 fire and explosion hazards during the production of
Incrodet TD-7C on April
30, 1997.  The following conditions contributed to the existence of these
hazards:
(a)  The Manufacturing Procedure which was used as an operating procedure
did not
provide clear step-by-step instructions for the employees to safely
conduct all operations
involved in the process.
(b)  A complete hazard and operability study of the production of Incrodet
TD-7C was
not conducted to determine the hazards related to the equipment, the
method
of
production and the chemicals used in the process.
(c)  A venting system or other method to eliminate and/or control any
hazardous
atmosphere in the headspace and the monitoring of the headspace was not
ensured.
(d)  The presence of possible ignition sources had not been evaluated or
eliminated.
ABATEMENT NOTE
Among other methods, one feasible and acceptable abatement method to
correct this hazard is
to:
1.  Implement a Standard Operating Procedure for each processing operation
which contains the
following:
(a)  Description of the process;
(b)  Properties of the materials involved;
(c)  Description of the equipment, instrumentation, and protective
equipment;
(d)  Startup and shutdown 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)  Emergency procedures.
2.  Implement a program to identify and evaluate hazards using procedures
recognized and used
throughout the industry.  These would include a compilation of process
safety information and
a review of the information.
3.  Utilize a venting system or method to control and/or eliminate any
hazardous atmosphere in
the headspace of the reactor and monitor this to ensure its effectiveness.
4.  Identify and eliminate all possible ignition sources.

Issued

Sep 16, 1997

Abate by

Oct 21, 1997

Penalty

Initial $825 · Current $825

Issued

Sep 16, 1997

Abate by

Nov 7, 1997