OSHA Inspection: BORDEN CHEMICALS & PLASTICS

Issued

Apr 28, 1992

Abate by

May 31, 1992

Penalty

Initial $3,500 · Current $3,500

General-duty citation text

The employer is not limited to abatement methods suggested by OSHA,
i.e., methods explained are general and may not be effective in all
cases.  Other methods of abatement may be equally or more appropriate.
Ultimate responsibility for determining the most appropriate abatement
methods rests with the employer, given its superior knowledge of the
specific conditions on its worksite.
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:
(a) On or about 3/12/92, the ventilation system air intakes
to the methanol, formaldehyde, ammonia, acetylene, vinyl chloride
monomer A, vinyl chloride monomer E, and poly vinyl chloride
control buildings did not prevent the entrance of flammable
vapors/gases such as, but not limited to methanol, ethylene
formaldehyde, ammonia, ethylene dichloride, vinyl chloride,
hydrogen, carbon monoxide and natural gas into the control room.
Feasible abatement methods to correct this hazard may include,
but are not limited to:
(1)  Provision of monitoring/alarm devices at the
ventilation system's air intake that detect and
provide audible and/or visual warning of an
accidental/uncontrolled release of flammable
vapors/gases, and that through an automatic interlock,
close the ventilation system as referenced in NFPA
496, Chapter 3.
(2)  Implementation of a hazard identification program
designed to detect and correct such a hazard, and
to maintain the proper functioning of those devices
through periodic inspections.
(3)  Locate the ventilation system air intakes in an area
that is unlikely to be contaminated with flammable
vapors or gases.
(b) On or about 3/17/92, the ammonia, methanol, formaldehyde,
vinyl chloride monomer A, and vinyl chloride E unit control
buildings walls had unnecessary openings which would allow the
entrance of flammable vapors/gases such as but not limited to
ammonia, methanol, formaldehyde, ethylene, ethylene dichloride,
vinyl chloride, caron monoxide, hydrogen and natural gas into
the control rooms.
Feasible abatement methods to correct this hazard may include,
but are not limited to:
(1)  Close all unnecessary openings with acceptable
materials to provide at least the fire and explosion
resistance of the existing building.
(2)  Implementation of a hazard identification program
designed to detect and correct such a hazard and to
insure the integrity of these structures through
periodic inspections and timely repairs.
(c) on or about 3/17/92, the ammonia, methanol, formaldehyde,
vinyl chloride monomer A, vinyl chloride monomer E and acetylene
unit control buildings walls had unnecessary windows, which would
allow the occupants to be stuck with projectiles and be engulfed
by fire during a catastrophic failure of the units equipment.
Feasible abatement methods to correct this hazard may include,
but are not limited to:
(1)  Close all unnecessary window openings with acceptable
materials to provide at least the fire and explosion
resistance of the existing building.
(2)  Implementation of a hazard identification program
designed to detect and correct such a hazard and to
insure the integrity of these structures by updating
them in a timely manner.
(d) On or about 3/17/92, a chemical process hazard review had
not been conducted for the methanl, vinyl chloride monomer A,
vinyl chloride monomer E, poly vinyl chloride, urea, oxygen and
utilities units that would identify process deficiencies and
upset conditons, plus estimate their frequency and probable
consequences.
Feasible abatement methods to correct this hazard may include,
but are not limited to:
(1)  Preparation and review of process flow sheets to
determine possible emergencies during start-up, normal
operating and shutdown conditions and to evaluate
the consequences of excessive temperatures and
pressures or variations in process controls.
(2)  Preparation and reviews of current piping and
instrumentation diagrams to assure that controls
and instrumentation will detect unusual conditions
and that the system will automatically shut down or
can be safely shut down in the event of operator or
equipment failure.
(3)  Review of the chemical reaction process considering
potential problems arising from abnormal temperature
rises, pressure rises, rates of reaction, and improper
addition of reactants, including any catalysts and
material flow stoppages.
(4)  Review of operating design and potential for
operational errors considering detailed operating
descriptions and standard operating procedures,
accuracy and readibility of control instrumentation,
and operator training in process chemistry, hazards,
and operational procedures.
(e) On or about 3/17/92, safety relief device block valves were
missing a means to seal/lock them open to prevent their
indadvertant closing from causing a catastrophic system failure.
Feasible abatement methods to correct this hazard may include,
but are not limited to:
(1)  Providing the appropriate hardware necessary to secure
the safety relief device block valves in the open
position.
(2)  Implementation of a hazard identification program
designed to detect and correct such a hazard, and
to conduct periodic inspections to insure proper
installation and use of required locks/seals.

Issued

Apr 28, 1992

Abate by

May 5, 1992

Penalty

Initial $1,500

Issued

Apr 28, 1992

Abate by

May 5, 1992

Penalty

Initial $1,875 · Current $750 Reduced

Issued

Apr 28, 1992

Abate by

May 8, 1992

Penalty

Initial $1,500 · Current $1,000 Reduced

Issued

Apr 28, 1992

Abate by

May 5, 1992

Penalty

Initial $1,500 · Current $1,000 Reduced

Issued

Apr 28, 1992

Abate by

May 5, 1992

Penalty

Initial $1,500 · Current $500 Reduced

Issued

Apr 28, 1992

Abate by

May 4, 1992

Penalty

Initial $1,875 · Current $500 Reduced

Issued

Apr 28, 1992

Abate by

May 5, 1992

Penalty

Initial $2,625

Issued

Apr 28, 1992

Abate by

May 4, 1992

Penalty

Initial $1,875 · Current $500 Reduced

Issued

Apr 28, 1992

Abate by

Jul 30, 1992

Penalty

Initial $1,875 · Current $500 Reduced

Hazardous substances 2580

Issued

Apr 28, 1992

Abate by

Jul 30, 1992

Hazardous substances 2580

Issued

Apr 28, 1992

Abate by

Jul 30, 1992

Issued

Apr 28, 1992

Abate by

Jul 30, 1992

Penalty

Initial $1,875 · Current $500 Reduced

Hazardous substances 1290

Issued

Apr 28, 1992

Abate by

Jul 30, 1992

Issued

Apr 28, 1992

Abate by

Jul 30, 1992

Hazardous substances 1290

Issued

Apr 28, 1992

Abate by

May 5, 1992

Penalty

Initial $1,125

Issued

Apr 28, 1992

Abate by

May 5, 1992

Penalty

Initial $750 · Current $750

Issued

Apr 28, 1992

Abate by

May 5, 1992

Issued

Apr 28, 1992

Abate by

May 15, 1992

Issued

Apr 28, 1992

Abate by

May 15, 1992

Issued

Apr 28, 1992

Abate by

May 15, 1992