OSHA Inspection: HOWARD INDUSTRIES, INC.

Issued

Sep 22, 2011

Abate by

Nov 24, 2011

Penalty

Initial $4,620 · Current $2,772 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 increased risk for injury related to fire, deflagration
and explosions related to
chemical processes in chemical manufacturing operations:
Howard Industries -1840 Progress Avenue, Columbus, Ohio facility:
a.)On April 13, 2011, an uncontrolled reaction involving the blending and
packaging
of a sodium chlorite product (Truox Precursor) caused a fire and
explosion. The
employer did not have procedures for evaluating chemical reaction,
self-reaction
and physical hazards when designing and operating the chemical processes
associated with their manufacturing operations, such as the blending of
chemicals
that pose an increased risk for fire and explosion. Prior to initiating
blending
activities on this date, the employer had not properly evaluated the
chemical
reaction hazards, other physical hazards, and process equipment associated
for the
design of a chemical process for the production of a chemical, known as
"Truox
PreCursor," of which sodium chlorite, is the main ingredient. Sodium
chlorite
reacts with reducing agents, organic materials, heavy metals, and chlorine
donors,
self-reacts when reaching temperatures at or above 347 degree Fahrenheit
and is
sensitive to frictional forces and compaction. The employer did not
evaluate the
chemistry, the appropriate equipment for use, appropriate work procedures
and
instructions, ignition source control, or perform any small scale test
batch runs
for use in material testing and analyzing scale-up effects associated with
this
chemical manufacturing operation. During blending operations on April 13,
2011,
a fire and subsequent explosion occurred involving sodium chlorite, the
equipment
used in the blending operation and the other associated chemicals involved
in the
blending operation.
ABATEMENT NOTE: Among other methods, feasible and acceptable methods
to correct this hazard would be (1) to develop procedures for determining
the
reactivity and chemical compatibility of manufacturing operation chemicals,
determining the associated energy and rates of potential reaction(s), and
determining equipment compatible with the manufacturing process or
operation.
The employer can utilize the following sources to incorporate a systematic
approach in developing the aforementioned procedures: American Institute of
Chemical Engineers Center for Chemical Process Safety (AICHE CCPS)
Guidelines for Safe Storage and Handling of Reactive Materials, AICHE CCPS
Guidelines for Chemical Reactivity, AICHE CCPS Guidelines for Process
Safety
in Batch Reaction Systems, Factory Mutual Global Report 7-43 Loss
Prevention
in Chemical Plants, Perry's Chemical Engineers' Handbook, National Fire
Protection Association (NFPA) Fire Protection Handbook and AICHE CCPS
Essential Practices for Managing Chemical Reactivity Hazards, (2) require
information detailing hazards of reaction, energy and incompatibility for
equipment from potential customers, (3) develop management of change
procedures, or risk analysis procedures, for handling deviation from
establishedor changes in previously performed operations, (4) utilizing
the principles found
in and/or complying with NFPA 77 Recommended Practice on Static
Electricity,
2007 edition, Chapter 7, and (5) use of a third-party firm with appropriate
experience and credentials for analyzing specific chemical manufacturing
operations and developing safe operational processes, procedures, including
identifying appropriate, compatible equipment for the purpose of
developing these
items, or for the purpose performing an audit, or verification of
internally
developed procedures.

Issued

Sep 22, 2011

Abate by

Dec 1, 2011

Penalty

Initial $3,300 · Current $1,980 Reduced

Issued

Sep 22, 2011

Abate by

Dec 1, 2011

Penalty

Initial $3,300 · Current $1,980 Reduced

Issued

Sep 22, 2011

Abate by

Oct 25, 2011

Issued

Sep 22, 2011

Abate by

Oct 25, 2011

Penalty

Initial $3,300 · Current $1,980 Reduced