OSHA Inspection: ROHM AND HAAS CHEMICALS, LLC

Issued

May 12, 2006

Abate by

Jun 29, 2006

Penalty

Initial $5,000 · Current $5,000

Hazardous substances 1480

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 were likely to cause death or serious physical harm
to employees in that
workers were exposed to contact with or inhalation of process chemicals or
gases capable of
causing serious injury or illness such as:
a) On or about February 15, 2006, maintenance workers were exposed to the
hazards created by excessive airborne levels of hydrogen sulfide in
Building #3
where: (a) No line breaking permits were completed for opening process
equipment; (b) No locking out or tagging out of valving leading to the 4D
Ejection system was performed; (c) No isolating of the vent/drain line for
the
4D Ejectors was performed; (d) No pre-flushing of the system with water was
performed to remove materials which could liberate Hydrogen Sulfide (also,
pre-flushing could detect the presence of blockages and leaks in the
system);
and, (e) No air monitoring was done of any potentially hazardous hydrogen
sulfide, carbon monoxide or flammable vapor levels.
b) Chemical operators regularly opened up process equipment in order to
clean
or replace traps and filters without performing any air monitoring,
locking or
tagging out of the equipment to be serviced, and completing a Line Breaking
Permit and Lockout/Tagout Permit, potentially exposing them to process
chemical contact or inhalation hazards.
Among other methods, one feasible and acceptable method to correct this
hazard is to
completely implement an equipment opening procedure that includes
appropriate: pre-
flushing, and air monitoring for all potential chemical hazards that could
be reasonably
expected in the building or process area where the work is taking place
and that is applicable
to both operations workers and maintenance workers.nce

Issued

May 12, 2006

Abate by

Aug 11, 2006

Penalty

Initial $5,000 · Current $5,000

Hazardous substances 1480

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 were likely to cause death or serious physical harm
to employees in that
the Process Hazard Analysis performed by the employer did not address the
following
conditions that created hydrogen sulfide exposure hazards to workers:
a) The HAZOP performed in 2001 on the 2MET and TO26 processes did not
address the following conditions: (1) 2-Mercapto Ethanol begins to
decompose
at 150 degrees Celsius, releasing highly toxic and flammable Hydrogen
Sulfide
gas; (2) Any 2-Mercapto Ethanol which passed through the condenser will
encounter 160 degree Celsius steam lines; (3) Due to the presence of
additives,
any 2-Mercapto Ethanol which travels beyond the steam ejector system may
polymerize and either partially or completely plug pipes through which it
has
the opportunity to travel, including the scrubber line and the surge tank
vent
line; (4) The absence of monitors in the scrubber line or in the surge
tank vent
line which would alert the operator in the control room to the presence of
abnormal pressures or flow rates in these lines, which could be due to the
presence of a blockage, such as 2-ME polymer; and (5) A common surge tank
vent line which could become plugged was being used to vent both processes
-
to vent the 4E Ejector Vacuum System for the 2-MET Process and to vent the
4D Ejector Vacuum System for the TO-26 Process.
Among other methods, one feasible and acceptable method to correct these
hazards is to: (A)
Install monitors into the scrubber line and into the surge tank vent line
which would detect
and alert the control room regarding any abnormalities in line flow rates
and pressures which
could be caused by an accumulating blockage in these lines; or (B) Test or
inspect the
Scrubber Line and the Surge Tank Vent Line for blockages on a frequent
basis, and remove
any accumulations of polymer which are found; (C) Install separate surge
tank vent lines for
the 4E System and for the 4D System; (D) Independently ventilate the drain
lines for the
Steam Ejector systems; (E) Install different types of vacuum systems which
do not require
the use of steam.e