OSHA Inspection: MACDERMID INCORPORATION

Issued

Jul 12, 1994

Abate by

Aug 26, 1994

Penalty

Initial $1,625 · Current $813 Reduced

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 the batch blending process chemical fire and explosion of
MACro Alum #5 a
component mixture of Sodium Fluoroborate, Mono Sodium Phosphate, Potassium
Ferricyanide,
and Chromic acid Flake:
MacDermid, Incorporation, 526 Huntington Ave.,Waterbury, CT:  Employees
were exposed to
hazard of the batch blending process chemical fire and explosion of MACro
Alum #5 a
component mixture of Sodium Fluoroborate, Mono Sodium Phosphate, Potassium
Ferricyanide,
and Chromic acid Flake.  Employees were operating the process without the
benefit of adequate
operating procedures and training.  Among other methods, one feasible and
acceptable abatement
method to correct this hazard is the design and implementation of
operating
procedures and
training which shall include the following:
I  Operating procedures:
(1)  The employer shall develop and implement written operating procedures
that provide clear
instructions for safely conducting activities involved in the MACro Alum
#5 process consistent
with the process safety information and shall address at least the
following elements:
(i)  Steps for each operating phase:
(A)  Initial startup;
(B)  Normal operations;
(C)  Temporary operations;
(D)  Emergency shutdown including the conditions under which emergency
shutdown is
required, and the assignment of shutdown responsibility to qualified
operators to ensure
that emergency shutdown is executed in a safe and timely manner.
(E)  Emergency Operations;
(F)  Normal shutdown; and,
(G)  Startup following a turnaround, or after an emergency shutdown.
(ii)  Operating limits:
(A)   Consequences of deviation; and
(B)   Steps required to correct or avoid deviation.
(iii)  Safety and health considerations:
(A)  Properties of, and hazards presented by, the chemicals used in the
process; with
particular attention to MSDS information, process perturbations and/or
incidents, and
investigations on the hazards of the chemicals;
(B)  Precautions necessary to prevent exposure, including engineering
controls
administrative controls, and personal protective equipment;
(C)  Control measures to be taken if physical contact or airborne exposure
occurs;
(D)  Quality control for raw materials and control of hazardous chemical
inventory
levels; and,  (E)  Any special or unique hazards.
(iv)  Safety systems and their functions.
(2)Operating procedures shall be readily accessible to employees who work
in or maintain
a process.
(3)  The operating procedures shall be reviewed as often as necessary to
assure that they reflect
current operating practice, including changes that result from changes in
process chemicals,
technology, and equipment, and changes to facilities.  The employer shall
certify annually that
these operating procedures are current and accurate.
(4)  The employer shall develop and implement safe work practices to
provide for the control
of hazards during operations such as lockout/tagout; confined space entry;
opening process
equipment or piping; and control over entrance into a facility by
maintenance, contractor,
laboratory, or other support personnel.  These safe work practices shall
apply to employees and
contractor employees.
II  Training:
(1)  Initial training:
(i)Each employee presently involved in operating a process, and each
employee before
being involved in operating a newly assigned process, shall be trained in
an overview of
the process and in the operating procedures as specified above.  The
training shall
include emphasis on the specific safety and health hazards, emergency
operations
including shutdown, and safe work practices applicable to the employee's
job tasks.
(ii)In lieu of initial training for those employees already involved in
operating a process, an
employer may certify in writing that the employee has the required
knowledge, skills,
and abilities to safely carry out the duties and responsibilities as
specified in the operating
procedures.
(2)  Refresher training shall be provided at least every three years, and
more often if
necessary, to each employee involved in operating a process to assure that
the employee
understands and adheres to the current operating procedures of the
process.  The employer, in
consultation with the employees involved in operating the process, shall
determine the
appropriate frequency of refresher training.
(3)  The employer shall ascertain that each employee involved in operating
a process has
received and understood the training required by this paragraph.  The
employer shall prepare
a record which contains the identity of the employee, the date of
training, and the means used
to verify that the employee understood the training.