OSHA Inspection: CROMPTON KNOLLS COLORS INC.

Issued

Jan 10, 1992

Abate by

Mar 12, 1992

Penalty

Initial $3,000 · Current $2,000 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
hazard of sudden reaction runaway and uncontrolled pressure rise:
On 8/16/91, one (1) chemical operator in Building-16 was adding
nitrosylsulfuric acid (40%) to the Pflaudler five hundred (500) gallon glas s
lined kettle (Kettle #2) during a diazotization reaction, in the manufactur e
of Intrasperse Blue GFD Base,a diazo-dye intermediate.  The critical
temperature was not maintained,therebyleading to a self-accelerating
decomposition and a violent pressure increase.  The manhole to the kettle
was blown thru the room of Building-16 and the corrosive contents of the
kettle were spewed throughout the entire building and outside onto the
adjacent yard area.
Adequate engineering controls and work practice safeguards were not in
place to minimize the possibility of a runaway/uncontrolled decomposition.
Among other methods one feasible and acceptable abatement method to correct
this hazard is to establish administrative and engineering controls over
the work being performed that will include, but not necessarily be limited
to, the following provisions:
(A)  Chemical Process Hazard Review
Conduct a chemical process system safety review.  Predict upsets and
estimate their frequency and probable consequences.  Operating parameters,
procedures and/or process control instrumentation determined by this review
to be critical for the safe manufacture of Intrasperse Blue GFD base shall
be designed and constructed for redundancy and back-up to assure
maximum feasible safety to employees.  This review shall be of a type
generally recognized in chemical processing industries (such as What if,
Cause/Consequence, FMEA, HAZOP, Fault Tree, etc.) and shall include, but
not necessarily be limited to, the following:
(i)  Review process flow sheets to determine possible emergencies during
start-up, normal operating, and shut down condition, and to evaluate the
consequences of excessive temperatures and pressures or variations in
material control at all phases of the reaction.
(ii)  Review of a piping and instrumentation diagram (P & ID) to assure
that controls and instrumentation will detect unusual conditions and that
the system will AUTOMATICALLY shut down or can safely shut down in the
event of operator or equipment error or in the event of excessive
temperature, loss of agitation, loss of cooling water or any other
condition which could lead to dangerous decomposition.
(iii)  Review of the chemical reaction process considering potential
problems arising from abnormal temperature rises, pressure rises and rates  o
reaction; improper addition of reactants and material flow stoppages.
(iv)  Review of operating equipment used in the manufacture of Intrasperse
Blue GFD base considering the adequacy of design and fabrication; effects
of corrosion, erosion and metal fatigue, potential for exceeding design
limitations, equipment leaks and spills; equipment malfunctions and
failures; plus adequacy of maintenance, repair and replacement programs.
(v)  Review of operating design and the potential for operational errors
considering detailed operating descriptions and standard operating
procedures to minimize the potential for operator injury.
vi)  Review and assure control instrumentation reliability, clarity,
accuracy and where critical parameters are monitored, engineer in
redundancy with audible annunciators to warn of pending upset condition
e.g. excessive temperature and/or loss of agitation.
(vi) Assure raw material purity on a more frequent basis.
(B)  Review and Revision of Standard Operating Procedures.
(i)  Update written detailed descriptions and Standard Operating Procedures
for the manufacture of Intrasperse Blue GFD Base, to assure safe start up
and processing within critical limits and to provide safe shut-down of
equipment in the event of abnormal conditions.  These procedures shall
address, but not necessarily be limited to, the following:
(1)  Start-up procedures for Intrasperse Blue GFD base that will include
checks to insure process equipment and controls are functioning properly
and that emergency devices are in proper working order.
(2)  Emergency shut down procedures for the Intrasperse Blue GFD base
that will define abnormal operating conditions and specify Sequential steps
for safe shut down of equipment or timely evacuation of operating
personnel plus proper removal techniques of any residual flammable,
unstable, corrosive, or toxic, materials.
(3)  Update provision for purging of the system by installing emergency
solenoid activated "dump" valves and adequate inert pressure to "blow
over" contents which can be activated by the operator quickly and safely.
(C)  Operations and Safety Controls
(1)  Design reagent charging mechanisms that will fail safe or otherwise
stop any reagent charge which is contributing to an upset condition
such as:
(i)   loss of adequate cooling water pressure
(ii)  loss of inert atmosphere in the reactor
(iii) too low operating temperature
(iv)  too high operating temperature
(v)   loss of loss of agitation/loss of power to the agitator
(2)  Provide audible alarms that will indicate the above upset conditions
to the operator.
(3)  Maintain an inert atmosphere and install an explosion prevention
system(s) in accordance with NFPA-69 (1986 edition).
(D)  Adequate Emergency Relief Devices
Insure that emergency pressure-relieving devices on process kettles are
sufficiently rated to carry off the maximum generated or supplied quantity
of liquid and/or vapor based on the physical phenomenon of two phase flow
while permitting no more than a ten percent rise above the maximum
allowable working pressure within the vessel when these devices are
blowing.
(1)  Assure that these devices function as designed via periodic
preventitive maintenance

Issued

Jan 10, 1992

Abate by

Feb 11, 1992

Penalty

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

Issued

Jan 10, 1992

Abate by

Jan 13, 1992

Penalty

Initial $1,200 · Current $1,200

Issued

Jan 10, 1992

Abate by

Feb 11, 1992

Penalty

Initial $600 · Current $600