OSHA Inspection: PACIFIC ANCHOR CHEMICAL CORP.

Issued

Oct 11, 1990

Abate by

Dec 10, 1990

Penalty

Initial $640 · Current $440 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 sever burns, and/or multiple traumatic injuries due to over
pressurization of reactor tank during the caustic washing of DEET:
Among other methods, one feasible and acceptable abatement method to
correct this hazard is to established 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 reviews 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 DEET 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, 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 system will automatically shut
down or con 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 reaction; improper addition of reactants
including any catalysts and material flow stoppages.
v) Review of operating equipment used in the processing of DEET
considering the adequacy of design and fabrication; effects of
corrosion, erosion and metal fatique; potential for exceeding
design limitations; equipment leaks and spills; equipment
malfunctions and failures; 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
instrumentation 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 manufacturing of DEET in mix tanks to assure
safe start-up and processing within controllable limits and to
provide for safe shutdown of equipment in the event of abnormal
conditions.
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 throughly 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.
i) Install high-temperature alarms and interlocks to prevent the
transfer of DEET from R10 to R9 if the DEET temperature
exceed establishe safe limits for mixing with the caustic wash
solution.
ii) Retro fit temperature gauges so that all gauges are reading
either Centigrade or Fahrenheit.
iii) Establish a regular maintenance/inspection program for reactor
tanks and associated equipment.

Issued

Oct 11, 1990

Abate by

Oct 30, 1990

Penalty

Initial $240 · Current $120 Reduced

Issued

Oct 11, 1990

Abate by

Oct 17, 1990