OSHA Inspection: FUJIFILM HUNT CHEMICALS USA INC

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

General-duty citation text

T.C.A. 50-3-105(1):  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 and
explosion from use of
flammable and combustible materials in an OXAD Mother Liquor (ML)
distillation process on
August 2 and 3, 2006, without equipment having recognized and generally
accepted engineering
controls to avert and/or abate a runaway reaction, and to alert
potentially exposed employees that
action, including controls and evacuation, was necessary.
On August 2 and 3, 2006, the employer ran an OXAD Mother Liquor (ML)
distillation process
in tank T-644, in line 3 of building 6.  There was a reported 3,451 pounds
of flammable liquid
(methanol) in tank T-644 at the beginning of the distillation.  (There
were more flammable
liquids in tanks in the same line and in the building that could have also
been involved in a fire
or explosion.)
Employees such as Operators, Shift Leaders, a Process Engineer, and an
Operations Manager,
were potentially exposed to a fire and/or explosion when working on the
process.  An explosion
and fire did occur on 8/3/06.
This hazard was reasonably foreseeable in that it was recognized by
employer representatives
and the industry.
Among other methods, one feasible and acceptable abatement method for
correcting this hazard
is to have electronic monitoring of heating jacket vs. batch temperatures
that automatically
initiates control actions when an (unwanted or unexpected) exothermic
reaction occurs.  Such
control actions might include cooling jacket activation, dumping batch
contents to an unheated
tank, a form of quenching (when possible), or a combination of such
controls.  A necessary
element of the control system would be automatic alarm activation to
notify
exposed employees
of necessary control actions and evacuation.
ABATEMENT VERIFICATION IS REQUIRED

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

General-duty citation text

T.C.A. 50-3-105(1):  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
and explosion
from use of flammable liquids in an OXAD Mother Liquor (ML) distillation
process on
August 2 and 3, 2006, before job and expert hazard analyses were conducted
to identify and
control hazards in the process.
On August 2 and 3, 2006, the employer ran an OXAD Mother Liquor (ML)
distillation
process in tank T-644, in line 3 of building 6.  There was a reported
3,451 pounds of
flammable liquid (methanol) in tank T-644 at the beginning of the
distillation.
(There were
more flammable liquids in tanks in the same line and in the building that
could have also
been involved in a fire or explosion.)
Employees such as Operators, Shift Leaders, a Process Engineer, and an
Operations
Manager, were potentially exposed to a fire and/or explosion when working
on the process.
An explosion and fire did occur on 8/3/06.
No job or expert hazard analysis was performed before the distillation to
identify and control
the potential hazards in the OXAD ML distillation process.  Such hazard
analyses are
elements of an effective safety and health program.
This hazard was reasonably foreseeable in that it was recognized by
employer
representatives, the industry, and common sense.
Among other methods, one feasible and acceptable abatement method for
correcting this
hazard is to perform a hazard analysis that is adequate for the complexity
of the process.
The hazard analysis would include differential scanning calorimetry (DSC)
or similar tests,
on all mixtures in the distillation.  In an OXAD ML distillation operation
the hazard analyses
would include analyses of: 1.PYM, 2. OXAD Mother liquor, and 3. OXAD
Mother liquor
after the methyl alcohol distillation removed most of the methyl alcohol.
A DSC on the Mother liquor before and after the methyl alcohol was
distilled off would help
the employer develop the temperature parameters under which it must
operate.  A DSC on
the Mother liquor after the methyl alcohol distillation is necessary
because there are many
compounds in the Mother liquor which may undergo thermal decomposition at
the
temperatures used for the methyl alcohol distillation, and their breakdown
products may
affect the temperatures at which the PYM is distilled.  The company must
define the
temperature limitations of such a distillation before performing it,
including
boiling points at
the pressure of the vacuum, and DSC test exotherm points with respect to
the pressure of the
vacuum, to avoid thermal decomposition.
ABATEMENT VERIFICATION IS REQUIRED

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

General-duty citation text

T.C.A. 50-3-105(1):  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 and
explosion from use of
flammable liquids in an OXAD Mother Liquor (ML) distillation process on
August 2 and 3,
2006, without an effective safe work practice (which is an element of an
effective safety and
health program) in place.
On August 2 and 3, 2006, the employer ran an OXAD Mother Liquor (ML)
distillation process
in tank T-644, in line 3 of building 6.  (OXAD was
3-(4-nitrophenyl)-5-(2-oxo-3,3-dimethyl
butyl)-1,2,4-oxadiazole.)  There was a reported 3,451 pounds of flammable
liquid (methanol)
in tank T-644 at the beginning of the distillation.  (There were more
flammable liquids in tanks
in the same line and in the building that could have also been involved in
a fire or explosion.)
The written work practice for the distillation, which was the "Plant
Operating Standard for
OXAD Mother Liquor Distillation in T-644," was not effectively safe.  For
example, no safe
upper temperature limit for the OXAD ML was provided in the procedure for
the last phase of
the distillation.
Employees such as Operators, Shift Leaders, a Process Engineer, and an
Operations Manager,
were potentially exposed to a fire and/or explosion when working on the
process.  An explosion
and fire did occur on 8/3/06.
This hazard was reasonably foreseeable in that it was recognized by
employer
representatives,
the industry, and common sense.
Among other methods, one feasible and acceptable abatement method for
correcting this hazard
is to develop an effectively safe work practice for the OXAD ML
distillation procedure, with
upper batch temperature limits (and limits on the length of time that the
batch can be held at
elevated temperatures).
ABATEMENT VERIFICATION IS REQUIRED

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Penalty

Initial $7,000 · Current $7,000

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

General-duty citation text

T.C.A. 50-3-105(1):  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 and
explosion from use of
flammable liquids in an OXAD Mother Liquor (ML) distillation process on
August 2 and 3,
2006, without proper preparation for emergency situations (which is an
element
of an effective
safety and health program) in place.
On August 2 and 3, 2006, the employer ran an OXAD Mother Liquor (ML)
distillation process
in tank T-644, in line 3 of building 6.  (OXAD was
3-(4-nitrophenyl)-5-(2-oxo-3,3-dimethyl
butyl)-1,2,4-oxadiazole.)  There was a reported 3,451 pounds of flammable
liquid (methanol)
in tank T-644 at the beginning of the distillation.  (There were more
flammable liquids in tanks
in the same line and in the building that could have also been involved in
a fire or explosion.)
The written work practice for the distillation, which was the "Plant
Operating Standard for
OXAD Mother Liquor Distillation in T-644," did not have instructions for
dealing with
emergency situations.  Such an emergency situation was the development of
a runaway
exothermic reaction in the distillation tank.
Employees such as Operators, Shift Leaders, a Process Engineer, and an
Operations
Manager,
were potentially exposed to a fire and/or explosion when working on the
process.  An explosion
and fire did occur on 8/3/06.
This hazard was reasonably foreseeable in that it was recognized by
employer representatives,
the industry, and common sense.
Among other methods, one feasible and acceptable abatement method for
correcting this hazard
is to develop proper emergency procedures for the OXAD ML distillation
procedure.  The
emergency preparation would include instructions for dealing with
emergency situations, such
as the development of a runaway exothermic reaction in the distillation
tank.
ABATEMENT VERIFICATION IS REQUIRED

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

General-duty citation text

T.C.A. 50-3-105(1):  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 and
explosion from use of
flammable liquids in an OXAD Mother Liquor (ML) distillation process on
August 2 and 3,
2006, without appropriate safety training in the "Plant Operating Standard
for OXAD Mother
Liquor Distillation in T-644."  Such appropriate safety training is an
element of an effective
safety and health program.
On August 2 and 3, 2006, the employer ran an OXAD Mother Liquor (ML)
distillation process
in tank T-644, in line 3 of building 6.  (OXAD was
3-(4-nitrophenyl)-5-(2-oxo-3,3-dimethyl
butyl)-1,2,4-oxadiazole.)  There was a reported 3,451 pounds of flammable
liquid (methanol)
in tank T-644 at the beginning of the distillation.  (There were more
flammable liquids in tanks
in the same line and in the building that could have also been involved in
a fire or explosion.)
The Operators and Shift Leaders of the distillation process had not
received training in the
procedure before it was utilized on August 2 and 3, 2006.  The procedure
was reportedly
composed on 7/31/06 and signed for approval on 8/1/06.
Employees such as Operators, Shift Leaders, a Process Engineer, and an
Operations Manager,
were potentially exposed to a fire and/or explosion when working on the
process.  An explosion
and fire did occur on 8/3/06.
This hazard was reasonably foreseeable in that it was recognized by
employer representatives,
the industry, and common sense.
Among other methods, one feasible and acceptable abatement method for
correcting this hazard
is to ensure that all employees operating a procedure are trained on the
procedure and its safety
aspects before it is used.
ABATEMENT VERIFICATION IS REQUIRED

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

General-duty citation text

T.C.A. 50-3-105(1):  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 and
explosion from use of
flammable liquids in an OXAD Mother Liquor (ML) distillation process on
August 2 and 3,
2006, without effective safety change analysis of the newly-developed
process, including its
operating procedures, before the distillation process was conducted.  Such
change analysis for
new processes would be a necessary sub-element of an effective safety and
health program's
hazard anticipation and detection element.
On August 2 and 3, 2006, the employer ran an OXAD Mother Liquor (ML)
distillation process
in tank T-644, in line 3 of building 6.  (OXAD was
3-(4-nitrophenyl)-5-(2-oxo-3,3-dimethyl
butyl)-1,2,4-oxadiazole.)  There was a reported 3,451 pounds of flammable
liquid
(methanol)
in tank T-644 at the beginning of the distillation.  (There were more
flammable liquids in tanks
in the same line and in the building that could have also been involved in
a fire or explosion.)
The written work practice for the distillation, which was the "Plant
Operating Standard for
OXAD Mother Liquor Distillation in T-644," was not effectively safe.  For
example, no safe
upper temperature limit for the OXAD ML was provided in the procedure for
the last phase of
the distillation.  The OXAD ML distillation procedure was reportedly
composed on 7/31/06,
signed for approval on 8/1/06, and used on 8/2/06.  No effective safety
change analysis of the
newly-developed process, including its operating procedures, was conducted
before the
distillation process was performed.
Employees such as Operators, Shift Leaders, a Process Engineer, and an
Operations Manager,
were potentially exposed to a fire and/or explosion when working on the
process.
An explosion
and fire did occur on 8/3/06.
This hazard was reasonably foreseeable in that it was recognized by
employer representatives,
the industry, and common sense.
Among other methods, one feasible and acceptable abatement method for
correcting this hazard
is to conduct effective safety change analysis of a newly-developed
process, including its
operating procedures, before the process is performed.
ABATEMENT VERIFICATION IS REQUIRED

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

General-duty citation text

T.C.A. 50-3-105(1):  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 and
explosion from use of
flammable liquids in an OXAD Mother Liquor (ML) distillation process on
August
2 and 3,
2006, without change analysis being performed whenever a change in process
procedures
occurred that could have an effect on safety.  Such change analysis is an
element of an effective
safety and health program.
On August 2 and 3, 2006, the employer ran an OXAD Mother Liquor (ML)
distillation process
in tank T-644, in line 3 of building 6.  (OXAD was
3-(4-nitrophenyl)-5-(2-oxo-3,3-dimethyl
butyl)-1,2,4-oxadiazole.)  There was a reported 3,451 pounds of flammable
liquid (methanol)
in tank T-644 at the beginning of the distillation.  (There were more
flammable liquids in tanks
in the same line and in the building that could have also been involved in
a fire or explosion.)
The written distillation process procedure, which was the "Plant Operating
Standard for OXAD
Mother Liquor Distillation in T-644," was deviated from in that the
temperature was raised
beyond any temperature listed in the procedure (and beyond a safe
temperature
level).  No
change analysis was performed when temperatures in the distillation were
raised to unsafe levels.
Employees such as Operators, Shift Leaders, a Process Engineer, and an
Operations Manager,
were potentially exposed to a fire and/or explosion when working on the
process.  An explosion
and fire did occur on 8/3/06.
This hazard was reasonably foreseeable in that it was recognized by
employer representatives,
the industry, and common sense.
Among other methods, one feasible and acceptable abatement method for
correcting this hazard
is to perform change analysis whenever a change in facilities, equipment,
materials, or processes
procedures occurs.
ABATEMENT VERIFICATION IS REQUIRED

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

General-duty citation text

T.C.A. 50-3-105(1):  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 and
explosion from use of
flammable liquids in an OXAD Mother Liquor (ML) distillation process on
August 2 and 3,
2006, without having employee participation, including Operators and/or
Operator/Shift Leaders,
in the development of work practice procedures and in any hazard analysis
for the process.
Such employee participation is an element of an effective safety and
health program.
On August 2 and 3, 2006, the employer ran an OXAD Mother Liquor (ML)
distillation process
in tank T-644, in line 3 of building 6.  (OXAD was
3-(4-nitrophenyl)-5-(2-oxo-3,3-dimethyl
butyl)-1,2,4-oxadiazole.)  There was a reported 3,451 pounds of flammable
liquid (methanol)
in tank T-644 at the beginning of the distillation.  (There were more
flammable liquids in tanks
in the same line and in the building that could have also been involved in
a fire or explosion.)
The written work practice for the distillation, which was the "Plant
Operating Standard for
OXAD Mother Liquor Distillation in T-644," was reportedly developed by one
person, a Process
Engineer, on 7/31/06, signed for approval by several management personnel
on 8/1/06, and used
on 8/2/06.  No Operators or Operator/Shift Leaders were consulted in the
development of the
OXAD ML distillation procedure.  Operators or Operator/Shift Leaders also
were not consulted
on the development of any hazard analysis for the operation.
Employees such as Operators, Shift Leaders, a Process Engineer, and an
Operations Manager,
were potentially exposed to a fire and/or explosion when working on the
process.  An explosion
and fire did occur on 8/3/06.
This hazard was reasonably foreseeable in that it was recognized by
employer representatives,
the industry, and common sense.
Among other methods, one feasible and acceptable abatement method for
correcting this hazard
is to ensure employee participation, including Operators and/or
Operator/Shift Leader
participation, in the development of work practice procedures for
processes and in any hazard
analysis for the processes.  Such employee participation is an element of
an effective safety and
health program.
ABATEMENT VERIFICATION IS REQUIRED

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Penalty

Initial $7,000 · Current $7,000

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Penalty

Initial $7,000 · Current $7,000

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880

Issued

Jan 26, 2007

Abate by

Mar 17, 2007

Hazardous substances 8880