OSHA Inspection: CLARIANT CORP.

Issued

Jan 11, 1991

Abate by

Feb 28, 1991

Penalty

Initial $810 · Current $567 Reduced

General-duty citation text

Section 5(a)(1) of the Occuptational Safety and Health Act of 1970: The
employer did not furnish employment and a place of emloyment which were
free from recognized hazards that were causing or likely to cause death
or serious physical harm to employees in that employees in and around
the pilot plant were exposed to the increased likelihood of fire and
explosion due to over-pressurization of the reactor vessel during the
paraclox process.
Pilot Plant: On or about August 29, 1990 an over-pressurization and
subsequent chemical release occurred in kettel #14 during the Paraclox
production process.
Conditions in the workplace which contributed to the hazard outlined
above include the following:
A) Standard operating procedures were inadequate, in that process vent
lines were not checked prior to chemical additions.
B) Operational controls provided were inadequate in that high
temperature and pressure alarms were not provided on the reactor
vessel.
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 hazard review that will
identify process deficiencies and upsets plus estimate their
frequency and probable consequences. Operating parameters, procedures
and/or process control instrumentation determined by this review to
be critical for the safe processing of Paraclox shall be designed and
constructed for either redundancy or 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/Consequenc, FMEA,
Hazop, Fault Tree, etc.) and shall include, but not necessarily be
limited to, the following:
I) 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 material controls.
II) Preparation and review of a piping and instrumentation diagram
(P&ID) to assure that controls and instrumentation will detect
unusual conditions and that the systems will automatically shut
down or can be safely shut down in the event of operator or
equipment error.
III) Review of raw material MSDSs, product bulletins, technical and
scientific literature considering fire, explosion, health,
stability and reactivity characteristics including handling,
storage, emergency procedures and special precautions.
IV) Review of the chemical reaction process considering potential
problems arising from abnormal temperature rises, pressure rises
and rates of reation; improper addition of reactants including any
catalysts and material flow stoppages.
V) Review of operating equipment used in the processing of Paraclox
considering the adequacy of design and fabrication; effects of
corrosion, erosion limitations; equpment leaks and spills;
equipment malfunctions and failure; plus maintenance, repair and
replacement programs.
VI) Review of operating design and potential for operational errors
considering detailed operating descriptions and standard operating
procedures; accuracy and readibility of control instrucmentation
and operator training in process chemistry, hazards and operational
procedures.
B) Standard Operating Procedures
I) Establish written detailed descriptions and standard operating
procedures for the manufacture of Paraclox, to assure safe start-up
and processing within controllable limits and to provide for safe
shutdown 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 vessel(s) that will include checks to insure
process equipment and controls are functioning properly, emergency
devices are in proper working order and the vessel is clean and/or
otherwise free of possible hazardous contaminants before use.
2) Normal operating procedures for the vessel(s) that will include a
defined sequence of operating steps emphasizing those considered to
be critical for process safety plus requirements for operator
personal protective equipment and practices for safe operation.
3) Emergency shutdown procedures for the vessel(s) that will define
abnormal operating conditions and specify sequential steps for safe
shutdown of equipment or timely evacuation of operating personnel
plus proper removal techniques of any residual flammable, unstable,
corrosive or toxic materials.
II) Instruct and train all affected management, supervisory and
operations personnel in these Standard Operating Procedures.
III) Periodically evaluate these standard operating procedures to
determine their continued adequacy. Any changes made to these
procedures should be thoroughly documented and reviewed.
Personnel shall be trained in any revisions along with the reasons
for them before they are implemented.
C) Operational and Safety Controls
Install the following operational and/or safety controls for the
manufacture of Paraclox in the Pilot Plant:
I) A discharge piping system to a safe location, such as but not
limited to a blow down tank in accordance with ASME boiler and
pressure vessel code and NFPA requirements.
II) High temperature and pressure alarms or Rate of Rise alarms and
fail-safe controls to prevent overheating or overpressurization
during the precess of Paraclox.

Issued

Jan 11, 1991

Abate by

Feb 11, 1991

Penalty

Initial $810 · Current $567 Reduced