OSHA Inspection: RHONE-POULENC, INC.

Issued

Oct 3, 1995

Abate by

Nov 5, 1995

Penalty

Initial $7,000 · Current $7,000

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 hazard:
a)  Phosphorus Pentasulfide Plant - The explosion prevention system for
the flaker
equipment was not maintained at an oxygen concentration low enough to
prevent a fire
during the cleanout of phosphorus pentasulfide material from the flaker.
Specifically,
a fire incident occurred on May 22, 1995, during the cleanout of this
material due, in
part, to air intrusion into the flaker equipment.  Potential spark and
heat producing tools
(e.g., a steel hoe and metal bars) were used by employees to manually push
the
phosphorous pentasulfide material, which is energy-sensitive and
combustible.
The employer did not have an inspection and preventive maintenance program
for the
explosion prevention system, and the post-incident investigation
discovered pipeline
defects, which caused nitrogen purge gas leakage.  An effective inspection
and preventive
maintenance program should have revealed such defects.  Also, the system's
plans and
specifications were not available for review by the employer.  Therefore,
the bearing of
the scrubber ventilation system dynamics on the effectiveness of the
explosion prevention
system was not known by the employer.  The employer's investigation
revealed that the
scrubber exhaust volume rate had a causal relationship with whether there
was positive
or negative static pressure in the flaker system.  (Static pressure
directly affects the
potential for air intrusion.)
Another contributing factor to the fire incident was the employer's
failure to monitor the
oxygen concentrations inside the flaker unit prior to cleanout of the
phosphorous
pentasulfide material from the flaker.  Such monitoring is necessary to
assure that oxygen
levels are below recognized safety margins for the phosphorous
pentasulfide combustible
dust (e.g., 9.3 percent oxygen by volume for nitrogen atmospheres at room
temperatures
and pressures).  This monitoring is essential for fire protection.
ABATEMENT NOTE:  Amoung other methods, one feasible and acceptable
abatement method
to correct this hazard is to comply with the NFPA 69 Standard on explosion
prevention systems
- 1992 edition and to follow the Rhone-Poulenc Basic Chemicals Company
Material Safety Data
Sheet for phosphorus pentasulfide precautions and use of non-sparking
tools.

Issued

Oct 3, 1995

Abate by

Nov 5, 1995

Issued

Oct 3, 1995

Abate by

Jan 31, 1996

Penalty

Initial $7,000 · Current $5,000 Reduced

Issued

Oct 3, 1995

Abate by

Jan 31, 1996

Issued

Oct 3, 1995

Abate by

Jan 31, 1996

Issued

Oct 3, 1995

Abate by

Jan 31, 1996

Issued

Oct 3, 1995

Abate by

Jan 31, 1996

Issued

Oct 3, 1995

Abate by

Jan 31, 1996