OSHA Inspection: U.S. CHEMICAL & PLASTICS, INC DBA CATALYST SYSTEMS

Issued

Jun 26, 2003

Abate by

Sep 1, 2003

Penalty

Initial $1,500 · Current $750 Reduced

Issued

Jun 26, 2003

Abate by

Jan 15, 2004

Penalty

Initial $5,000 · Current $2,500 Reduced

Issued

Jun 26, 2003

Abate by

Jan 15, 2004

Penalty

Initial $5,000 · Current $2,500 Reduced

Issued

Jun 26, 2003

Abate by

Jan 15, 2004

Issued

Jun 26, 2003

Abate by

Jan 30, 2004

Penalty

Initial $5,000 · Current $2,500 Reduced

Issued

Jun 26, 2003

Abate by

Jul 29, 2003

Penalty

Initial $1,500 · Current $750 Reduced

Issued

Jun 26, 2003

Abate by

Jul 29, 2003

Penalty

Initial $5,000 · Current $2,500 Reduced

Issued

Jun 26, 2003

Abate by

Jul 29, 2003

Penalty

Initial $5,000 · Current $2,500 Reduced

Issued

Jun 26, 2003

Abate by

Jan 15, 2004

Penalty

Initial $70,000 · Current $49,000 Reduced

General-duty citation text

Ensure that transfer containers, equipment, and all components are
properly grounded
and bonded when collecting samples, unloading the dryer, transferring the
material,
and screening/packaging the product.
Ground employees involved in collecting samples, unloading the dryer,
transferring the
material, and screening/packaging the product by using grounding ankle
straps or
Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
conductive floors and conductive footwear.
Test to ensure that all personnel and equipment grounding and bonding is
adequate.
Install and utilize a protective barrier or shield between the employees
and the
unloading of the dryer.
Conduct the unloading and handling operation of the dried benzoyl peroxide
remotely.
Follow accepted industry guidelines and engineering standards such as
Publication
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 while
drying, handling, and packaging benzoyl
peroxide were exposed to a fire/explosion hazard as a result of
confinement, deflagration, and rapid explosive
decomposition of the benzoyl peroxide:
a.In the paste room of building #2, the employer utilized a Schwelmer
#AS-109 Safety and Handling of Organic Peroxides: A Guide, Classification
Guidance
of Organic Peroxides for NFPA 704, HMIS Classification Guidance for Organic
Peroxides, Organic Peroxide Spill Clean Up, and other information prepared
by the
Organic Peroxide Producers Safety Division of The Society of the Plastics
Industry,
Inc.; and procedures for the safety and handling of organic peroxides
developed by
glass-lined, double cone
competing businesses.
Utilize good and accepted work practices such as those found in the
following
resources:  Chemical Safety Data Sheet SD-81 Properties and Essential
Information for
Safe Handling and Use of Benzoyl Peroxide; NIOSH A Recommended Standard for
Occupational Exposure to Benzoyl Peroxide; Explosive and Toxic Hazardous
Materials
by James H. Meidl; Occupational Health Guideline for Benzoyl Peroxide; and
New
vacuum dryer without implementing effective controls for the drying of
Jersey Department of Health Hazardous Substance Fact Sheet.
Follow the guidelines established by NFPA such as NFPA 77 Recommended
Practice
benzoyl peroxide.  The
employer exposed employees to a fire/explosion hazard as a result of
confinement and rapid
explosive decomposition of the benzoyl peroxide in the drying unit.  On or
about January 2,
2003, an uncontrolled explosion occurred in the vacuum dryer while benzoyl
peroxide was
being dried.
on Static Electricity; NFPA 432 Code for the Storage of Organic Peroxide
Formulations; and NFPA 70 National Electrical Code.rical
Among other methods, feasible and acceptable abatement methods to correct
this
hazard
include, but are not limited to, the following:
Conduct an organized and systematic evaluation (process hazard analysis)
of the drying
operation at the facility that will effectively identify potential causes
and consequences
of safety and health hazards.  The hazard analysis which identifies,
evaluates, and
controls the hazards should be performed and documented for items such as
the
following:
Hazards of the process.
Facility layout of operations.
Selection of materials and equipment.
Process control parameters.
Personal protective equipment and barriers.
Engineering and administrative controls.
Consequences of failure of engineering and administrative controls.
Human factors.
Develop and implement written operating procedures that provide clear
instructions for
safely performing activities involved in the drying operation of benzoyl
peroxide.
Develop and implement a preventative maintenance program that provides for
inspection, maintenance, and testing of the drying equipment and
associated hardware.
Develop and implement an equipment cleaning procedure and schedule for the
dryer
and all related equipment and tools.
Develop and implement a contractor and hot work program for work that is
conducted
in the area where benzoyl peroxide is dried.
Provide training for peroxide processors with the emphasis on the specific
safety and
health hazards of the process, emergency operations, and safe work
practices
applicable to the employee's job task.
Ensure that no impurities are in the raw material by performing tests or
the equivalent.Evaluate the damage to the glass lining inside the dryer to
determine whether contact
between benzoyl peroxide and the glass pieces or underlying carbon steel
will create a
hazardous condition, and take other necessary actions to guard against
possible benzoyl
peroxide contamination with other reactive materials.
Ensure that the vacuum dryer and all attached equipment were effectively
grounded
and bonded to control static electricity.
Guard against overheating the benzoyl peroxide by installing redundant
temperature
controls such as an upper high temperature limit control to shut off the
source of heat
if the temperature controller fails to operate properly.
Do not rotate the benzoyl peroxide in the dryer due to the friction and
shock sensitivity
of the material and creation of a dust cloud.
Do not confine the benzoyl peroxide while drying the material to greater
than 97due
to the potential for explosion unless adequate relief venting can be
installed.
Dry only small quantities of benzoyl peroxide at a time to minimize the
hazard.
Conduct the drying operation of the benzoyl peroxide remotely.
Follow accepted industry guidelines and engineering standards such as
Publication
#AS-109 Safety and Handling of Organic Peroxides: A Guide, Classification
Guidance
of Organic Peroxides for NFPA 704, HMIS Classification Guidance for Organic
Peroxides, and other information prepared by the Organic Peroxide
Producers Safety
Division of The Society of the Plastics Industry, Inc.; and procedures for
the safety
and handling of organic peroxides developed by competing businesses.
Utilize good and accepted work practices such as those found in the
following
resources:  Chemical Safety Data Sheet SD-81 Properties and Essential
Information for
Safe Handling and Use of Benzoyl Peroxide; NIOSH A Recommended Standard for
Occupational Exposure to Benzoyl Peroxide; Explosive and Toxic Hazardous
Materials
by James H. Meidl; Occupational Health Guideline for Benzoyl Peroxide; and
New
Jersey Department of Health Hazardous Substance Fact Sheet.
Follow the guidelines established by NFPA such as NFPA 77 Recommended
Practice
on Static Electricity; NFPA 432 Code for the Storage of Organic Peroxide
Formulations; and NFPA 70 National Electrical Code.
b.In the paste room of building #2, the employer failed to establish
controls for the handling of
dried benzoyl peroxide, such as the collection of QC samples, the
unloading of the vacuum
dryer, and the screening/packaging of dried benzoyl peroxide.  Employees
engaged in handling
dried benzoyl peroxide were exposed to a fire/explosion hazard as a result
of deflagration
and/or rapid explosive decomposition.
Among other methods, feasible and acceptable abatement methods to correct
this hazard
include, but are not limited to, the following:
Conduct an organized and systematic evaluation (process hazard analysis)
of the
handling of dried benzoyl peroxide at the facility that will effectively
identify potential
causes and consequences of safety and health hazards.  The hazard analysis
which
identifies, evaluates, and controls the hazards should be performed and
documented for
items such as the following:Hazards of the process.
Facility layout of operations.
Selection of materials and equipment.
Process control parameters.
Personal protective equipment and barriers.
Engineering and administrative controls.
Consequences of failure of engineering and administrative controls.
Human factors.
Develop and implement written operating procedures that provide clear
instructions for
safely performing activities involved in the handling of dried benzoyl
peroxide.
Develop and implement procedures for the decontamination of equipment and
containers used to collect, transport and weigh the material.
Develop and implement spill control and cleanup procedures including
recovery of the
spilled material and decontamination of the effected surfaces.
Develop and implement a contractor and hot work program for work that is
conducted
in the area where dried benzoyl peroxide is handled.
Provide training for peroxide processors with the emphasis on the specific
safety and
health hazards of the process, emergency operations, and safe work
practices
applicable to the employee's job task.
Guard against possible benzoyl peroxide contamination with other reactive
materials.
Handle only small quantities of dried benzoyl peroxide at a time to
minimize the
hazard.
Ensure that all hand tools such as the metal hanger used to collect
samples and the
crescent wrench are made of non-sparking materials.

Issued

Jun 26, 2003

Abate by

Jul 29, 2003

Penalty

Initial $7,500 · Current $3,750 Reduced

Issued

Jun 26, 2003

Abate by

Jul 29, 2003

Issued

Jun 26, 2003

Abate by

Jul 29, 2003