Bayer CropScience sought to reduce risks associated with the manufacturing and storage of the toxic chemical methyl isocyanate (MIC) at its processing plant in Institute, West Virginia, says a new congressionally mandated report from the National Research Council. However, the company did not make an effort to incorporate all possible hazard control methods, and the report found that not all chemical manufacturing plants have adopted safer processes that aim to minimize or eliminate hazards. The committee that wrote the report recommended that the US Chemical Safety Board (CSB) or another entity develop a framework to help managers at chemical plants choose among alternative processing options—considering factors such as safety, environmental impact, and product yield—to develop a safer chemical manufacturing system.
The 2008 explosion at the West Virginia Bayer plant, which stemmed from a fire within the production unit, resulted in the deaths of two employees and extensive damage to nearby structures. Debris from the blast hit the shield surrounding a storage tank for MIC—a volatile, highly toxic chemical used in the production of agricultural and residential pesticides. The liquid and vapor forms of MIC can be harmful when inhaled or ingested, or when eyes or skin are exposed to it. In 1984 a cloud of MIC gas from an explosion in Bhopal, India, killed nearly 3,800 people. Although the storage container at the West Virginia plant avoided damage, an investigation by the US Chemical Safety and Hazard Investigation Board found that debris could have struck a relief valve vent pipe resulting in the release of MIC into the atmosphere. Bayer intended to restart production of the pesticides involving MIC after plant modifications were complete, but last year announced it would cease production. Nevertheless, under the congressional mandate, the Research Council study examined the use and storage of MIC at the Bayer facility and possible alternative production processes.
Inherently Safer Process Assessments
OSHA process safety management regulations require companies to follow evaluative and organizational procedures to ensure a safe chemical manufacturing process. Companies must meet OSHA’s requirements, but are not limited to them, when additional hazard control methods are available. One of these additional methods is an inherently safer process assessment, which aims to minimize or eliminate the hazard. These assessments will not always result in a clear, well defined, and feasible path forward. Although one process may be inherently safer with respect to a specific hazard, the process may present other hazards, such as an increase risk of fire or more severe environmental impacts. For instance, changing from a flammable solvent in a process to a non-flammable one will eliminate a fire hazard, but if the new solvent is toxic, then using it introduces a new hazard that must be controlled. Moreover, judgments about what constitutes an inherently safer process varies among professionals, and the chemical industry lacks a common understanding and set of practice protocols for identifying safer processes.
The committee found that Bayer did incorporate some aspects of risk reduction that are associated with inherently safer process principles. However, the inherent safety considerations were not explicitly stated in Bayer’s process safety management guidelines and were dependent on the knowledge base of the individual facilitating the particular activity, such as a process hazard analysis. Moreover, Bayer and the previous owners of the plant performed hazard and safety assessments and made business decisions that resulted in MIC inventory reduction, elimination of above ground MIC storage, and adoption of various measures, but these assessments did not incorporate some of the key principles of the inherently safer process. The committee said that without an emphasis on incorporating inherently safer process assessments into process safety management, it is unlikely that these concepts would become part of corporate memory, and therefore could be forgotten or ignored over time. It suggested that Bayer formally incorporate inherently safer process assessments into the company’s process safety management system and training, and to record such assessments as part of its audit and review processes.
Alternative Methods for Producing MIC and Pesticides
In reviewing Bayer’s assessment of four alternative processes for the manufacture of MIC, the committee said that no method out-performed all others in every category. Bayer also evaluated trade-offs among the alternatives—considering costs and benefits such as risk, expense, quality of final product, and community perception—but excluded factors that could have been important in the decision, from the perspectives of both the company and the community. Although it posed higher risks to the surrounding community due to the volume of MIC stored at the facility, the process Bayer ultimately chose decreased the amount of wastewater produced compared with other methods, which in turn decreased the potential damage to local surface waters. The previous owners identified other possible methods that could have resulted in a reduction in MIC production and inventory but determined several limitations prohibited their implementation.
Inherently Safer Processes in Industry
A company’s consistent application of inherently safer process strategies could decrease the required scope of organizational emergency preparedness programs by decreasing the vulnerable zones around its facilities. However, a potential concern with using inherently safer process analysis is that it may become too narrowly focused, and as a consequence, may overlook certain outcomes. Even when multiple outcomes are recognized, they may be inappropriately weighted.
The committee recommended that the US CSB or other entity convene a working group to chart a plan for incorporating decision theory frameworks into inherently safer process assessments. The group should identify obstacles to employing methods from the decision sciences, options for tailoring these methods to the chemical process industry, and incentives that would encourage their use.
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How to Prepare for OSHA’s Globally Harmonized Hazard Communication Standard (GHS)
This means that virtually every product label, MSDS (called “safety data sheet” or SDS under the new standard), and written hazard communication plan must be revised to meet the new standard. Worker training must be updated so that workers can recognize and understand the symbols and pictograms on the new labels as well as the new hazard statements and precautions on SDSs.
Environmental Resource Center is offering webcast training for you to learn how the new rule differs from current requirements, how to implement the changes, and when the changes must be implemented.
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How to Author GHS Safety Data Sheets
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How to Label Hazardous Chemicals Using OSHA’s New GHS Hazcom Standard
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DeMoulas Super Markets Agrees to Correct Hazards at Market Basket Stores in Massachusetts and New Hampshire
The DOL has reached a settlement with DeMoulas Super Markets Inc., in which the Tewksbury, Massachusetts-based grocery chain has agreed to correct all hazards and take substantive steps to enhance safety and health measures for employees at all of the chain’s more than 60 Market Basket stores in Massachusetts and New Hampshire. The settlement resolves litigation that followed citations carrying $589,200 in fines issued by OSHA in October 2011 after inspections identified widespread fall and laceration hazards at the stores.
DeMoulas initially contested the citations to the independent Occupational Safety and Health Review Commission. The Labor Department’s regional solicitor’s office subsequently filed a complaint with the commission asking for enterprisewide correction of the hazards. As the result of settlement discussions with the solicitor’s office, DeMoulas has signed the agreement to correct the cited hazards and take additional preventive actions.
These improvements include a full-time safety and health director with the full authority and responsibility to develop, implement, monitor, and enforce the requirements of the company’s safety and health program; a written safety and health program for each workplace that will include inspections to monitor and evaluate the program’s effectiveness as well as provisions to identify, document, and remedy any hazards or violations; a written disciplinary program for all workplaces and all employees, including management; a safety and health liaison for each supermarket department; formal safety and health training for all new employees and all new and existing employees on an annual basis; and the inclusion of a safety and health evaluation as a material element in annual performance reviews of all store and department managers. The company also has paid a total of $400,000 in fines.
Uniform and Laundry Company Fined for Bloodborne Pathogens and Lead Exposure
A complaint alleging hazards prompted OSHA’s inspection. Proposed penalties total $186,000.
Three willful violations involve a failure to conduct proper training and provide hepatitis B vaccinations, as well as to have engineering and work practice controls in place to eliminate or minimize exposure to bloodborne pathogens. A willful violation is one committed with intentional knowing or voluntary disregard for the law’s requirements, or with plain indifference to worker safety and health. The citations carry $165,000 in penalties.
Four serious violations involve a locked emergency door, a lack of training on fire extinguisher use, lead-contaminated surfaces, inadequate training on OSHA’s lead standard, and not providing gloves to workers exposed to potentially contaminated clothing. A serious violation occurs when there is substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known. The citations carry $21,000 in penalties.
UniFirst Corp., employs 35 workers at the West Caldwell facility.
Quality Stone Veneer Inc. Fined $154,440 for Scaffolding Hazards
OSHA has proposed $154,440 in penalties following an inspection that was initiated after a compliance officer driving by the site observed workers on a scaffold that lacked fall protection measures.
The willful violation is failing to implement a fall arrest system or provide guardrails for employees working on a scaffold more than ten feet above the next lower level. The citation carries a $69,300 penalty.
Three repeat violations involve a failure to fully plank or deck platforms on all working levels of the scaffold; provide a safe means of access to and from scaffold platforms that are more than two feet above or below an access point; and provide competent supervision and direction whenever a scaffold is erected, moved, dismantled, or altered. The citations carry penalties of $69,300. A repeat violation exists when an employer previously has been cited for the same or a similar violation of a standard, regulation, rule or order at any other facility in federal enforcement states within the last five years. Similar violations were cited in 2011 at a site in Falling Waters, West Virginia.
Four serious violations involve failing to ensure that scaffold platforms extend at least six inches over the centerline support; brace scaffold frames and panels to secure vertical members together laterally; and have a qualified person train workers who use scaffolds as well as workers who erect, disassemble, move, operate, repair, maintain, or inspect scaffolds. The citations carry penalties of $15,840.
Quality Stone Veneer Inc., installs stone at commercial and residential sites.
Packaging Manufacturer Faces $130,000 in Fines Following Box Machine Fatality
The worker was fatally injured on November 7, 2011, while operating a corrugated box-making machine when he became entangled in an unguarded drive shaft that provides power to the machine.
A willful citation was issued for a violation involving the unguarded shaft, which lacked proper protection to prevent workers from being exposed to its moving parts.
Additionally, 11 serious violations involve a failure to prevent other machine guarding hazards, develop and implement a written chemical hazard communication program, provide worker training, cover electrical junction boxes, and address several deficiencies in the hazardous energy control program, which is designed to prevent machinery from unintentionally starting up during maintenance.
Horn Packaging Corp., faces a total of $130,300 in proposed fines.
Ware Milling Cited for 30 Safety and Health Violations after Worker Trapped in Cotton Bin
OSHA has cited Ware Milling Co., Inc., for 30 safety and health violations at the company’s Waycross, Georgia, facility. Proposed penalties total $157,500.
OSHA initiated an inspection in November 2011 after receiving a complaint that a worker had entered a milled cotton seed bin without preparation and appropriate equipment, and became trapped and hung from a lanyard for a lengthy time. The worker experienced leg numbness exerted by the pressure of the safety harness and fell more than ten feet onto the top of the cotton seed mill pile after the rope was cut.
Two willful safety violations include failing to perform lockout/tagout procedures for the energy source of the screw auger when workers are inside the bins and have a stationed observer who can provide emergency assistance. The citations carry penalties of $77,000.
Twenty-four serious safety and health violations include failing to select appropriate personal protective equipment and train workers on how it should fit; develop an emergency action plan; provide rescue equipment when workers enter the bins; provide respirators to workers and use engineering controls during exposure to unregulated particulates; properly guard stairways, open-sided platforms, pulleys, and belts; prevent combustible dust accumulation; address electrical deficiencies; develop and implement a hazard communication program; and label chemicals in the workplace and provide training on their usage. The citations carry penalties of $79,800.
Four other-than-serious health violations involve failing to maintain OSHA’s 300 log for 2011, provide Appendix D to workers wearing dust masks and certify workers’ forklift operation training. An other-than-serious violation is one that has a direct relationship to job safety and health, but probably would not cause death or serious physical harm. Penalties total $700.
AWC Frac Valves Fined $105,000 for Amputation Dangers
Proposed penalties total $105,000 following an inspection initiated on November 8, 2011, by OSHA.
The willful violation is failing to provide the required machine guarding to prevent employees from coming in contact with moving machinery parts such as vertical and manual lathes.
The serious violations include failing to ensure that working surfaces are clear of trash and debris; provide a lockout/tagout program for machines’ energy sources when they are being set up for production; and properly guard pulleys, belts, and live electrical circuits.
The other-than-serious violations include failing to properly maintain the required injury and illness logs, and adequately close openings on electrical equipment.
AWC Frac Valves employs about 100 workers in Conroe who fabricate high-pressure hydraulic fracturing valves for the oil and gas industry.
Food and Beverage Manufacturer Cited for Repeat Amputation and Laceration Safety Hazards
OSHA has cited Kerry Ingredients & Flavours Inc., headquartered in Beloit, Wisconsin, for three repeat violations at its Flemington, New Jersey, facility. Proposed penalties total $50,000 following an inspection conducted under OSHA’s Site-Specific Targeting Program for industries with high injury and illness rates.
The violations involve amputation and laceration hazards due to a lack of lockout procedures for the energy sources of specific equipment, and the improper adjustment of bench rests and guards on a bench grinder. Similar violations were cited at the company’s Chicago facility in May and October 2008.
Kerry Ingredients & Flavours Inc., manufactures cereal, soft drinks, and seasonings, and employs 45 workers at the Flemington site. The company has 15 business days from receipt of the citations to comply, ask for an informal conference with OSHA’s area director, or contest the citations and proposed penalties before the independent Occupational Safety and Health Review Commission.
Auto Body Parts Supplier Fined $46,000 after Loading Dock Fatality
OSHA has cited Salt Lake City, Utah-based CertiFit Inc., for nine serious safety violations at the company’s facility in San Antonio, Texas. OSHA’s San Antonio Area Office initiated an inspection on January 3 after an employee was killed when a delivery truck backed into a loading dock while the worker was preparing the dock for the delivery.
OSHA found that the company failed to ensure that a trained and competent person is present who can administer first aid, provide training on evacuation procedures in the event of a fire, repair and maintain electrical equipment and rolling ladders, ensure that ladders are used correctly, and properly mount fire extinguishers.
Proposed penalties total $46,000 for the auto body parts supplier, which employs about seven workers at the San Antonio facility.
Cleveland Cement Contractors for Cited Following Casino Parking Garage Collapse
OSHA has cited Cleveland Cement Contractors Inc., for six serious safety violations, including not following design and construction standards, following an investigation into the partial collapse of a casino’s second floor parking garage during concrete placement. Several workers suffered sprains and strains during the December 16 incident in downtown Cleveland, Ohio. Proposed fines total $38,000.
The violations include failing to properly design, construct, and maintain concrete forming and shoring systems; avoid eccentric loading of shoring stringers; secure shoring stringers to shoring heads as needed; adequately inspect forming and shoring prior to and during concrete placement; guard all exposed protruding reinforcing steel; and ensure that workers use face protection while operating a pneumatic hose.
Cleveland Cement Contractors Inc., specializes in the construction of parking garages and other cast-in-place concrete structures.
Cabinetry Company Fined $45,000 for Electrical Hazards
OSHA has cited Zamco Inc., doing business as Concepts in Cabinetry, with 14 safety and health violations—including one repeat—for electrical, respiratory, and other hazards at the company’s facility in St. Hedwig, Texas. OSHA’s San Antonio Area Office began an inspection on February 9 as part of the agency’s Site-Specific Targeting Program for industries with high injury and illness rates. Proposed penalties total $45,000.
The serious violations include failing to ensure the safety of electrical wiring in the spray booth area; provide the required machine guarding around equipment such as an automated clamp carrier; implement an effective respiratory protection program; provide lockout/tagout procedures for machines’ energy sources and train workers on the procedures; and ensure that work areas are free from saw dust accumulations, which are combustible.
The repeat violation is failing to ensure that the disconnect panel boxes are accessible. A similar violation was cited in 2010.
The company employs about 23 workers.
OSHA Cites Bazzini Holdings After Worker’s Arm Amputated
OSHA has cited Bazzini Holdings LLC, with 15 workplace safety and health violations following an incident in which a worker’s arm was amputated at the company’s Allentown, Pennsylvania, facility. Bazzini Holdings, which employs about 250 workers at the Allentown site, manufactures fine chocolates and nut products.
OSHA’s inspection, initiated in November 2011 after the agency was notified of the amputation, found three repeat, eight serious, and four other-than-serious violations.
The repeat violations involve electrical hazards and uncovered projecting shafts. The same violations were cited in 2008.
The serious violations include additional electrical hazards as well as the company’s failure to use specific procedures for controlling hazardous energy; provide general machine and power transmission guarding; develop and implement a hazard communication program; and implement a hearing conservation program that includes noise engineering controls, noise monitoring, audiometric testing, and hearing conservation training.
The other-than-serious violations involve missing electrical covers, unsecured machinery, and personal protective equipment deficiencies.
Proposed penalties total $56,400.
OSHA Kicks off Heat-Related Illnesses and Fatalities Prevention Campaign
OSHA has kicked off a national outreach initiative to educate workers and their employers about the hazards of working outdoors in hot weather. The outreach effort builds on last year’s successful summer campaign to raise awareness about the dangers of too much sun and heat.
“For outdoor workers, water, rest, and shade are three words that can make the difference between life and death,” Secretary of Labor Hilda L. Solis said. “If employers take reasonable precautions, and look out for their workers, we can beat the heat.”
Every year, thousands of workers across the country suffer from serious heat-related illnesses. If not quickly addressed, heat exhaustion can become heat stroke, which has killed—on average—more than 30 workers annually since 2003. Labor-intensive activities in hot weather can raise body temperatures beyond the level that normally can be cooled by sweating. Heat illness initially may manifest as heat rash or heat cramps, but quickly can become heat exhaustion and then heat stroke if simple prevention steps are not followed.
“It is essential for workers and employers to take proactive steps to stay safe in extreme heat, and become aware of symptoms of heat exhaustion before they get worse,” said Dr. David Michaels, assistant secretary of labor for occupational safety and health. “Agriculture workers; building, road, and other construction workers; utility workers; baggage handlers; roofers; landscapers; and others who work outside are all at risk. Drinking plenty of water and taking frequent breaks in cool, shaded areas are incredibly important in the hot summer months.”
In preparation for the summer season, OSHA has developed heat illness educational materials in English and Spanish, as well as a curriculum to be used for workplace training. Additionally, a website provides information and resources on heat illness—including how to prevent it and what to do in case of an emergency—for workers and employers.
OSHA also has released a free application for mobile devices that enables workers and supervisors to monitor the heat index at their work sites. The app displays a risk level for workers based on the heat index, as well as reminders about protective measures that should be taken at that risk level.
In developing last year’s inaugural national campaign, federal OSHA worked closely with the California OSHA and adapted materials from that state’s successful campaign. Additionally, OSHA is partnering with NOAA for the second year to incorporate worker safety precautions when heat alerts are issued across the nation.
OSHA and the Laser Institute of America Renew Alliance to Protect Workers from Laser Hazards
OSHA has renewed its Alliance with the Laser Institute of America (LIA) to reduce and prevent worker exposure to laser beam and non-beam hazards in industrial, research, and medical workplaces. The Alliance will also share information on laser regulations and standards, effects lasers have on the eyes and skin, laser control measures, and laser safety program administration.
“Worker exposure to laser beams can result in eye and skin damage, and in more serious cases, blindness and skin cancer,” said Assistant Secretary of Labor for Occupational Safety and Health David Michaels. “This renewed Alliance will help broaden outreach efforts to workers and employers and share critical education and information to reduce preventable injuries.”
During the two-year agreement, the Alliance will develop fact sheets with questions that should be asked at facilities that use lasers, and will conduct Laser Safety Seminars for OSHA field staff.
LIA, founded in 1968, is a professional society for laser applications and safety, and it provides technical information and networking opportunities to industrial, medical, research, and government communities worldwide. LIA represents approximately 1,500 members.
OSHA’s Safety and Health Topics pages on Laser Hazards, Laser/Electrosurgery Plume, and Radiation provide information on how to recognize and reduce laser hazards, OSHA standards related to lasers, and training on laser safety.
Through the Alliance Program, OSHA works with groups committed to worker safety and health to prevent workplace fatalities, injuries, and illnesses. These groups include unions, consulates, trade or professional organizations, faith- and community-based organizations, businesses, and educational institutions. OSHA and the groups work together to develop compliance assistance tools and resources, share information with workers and employers, and educate workers and employers about their rights and responsibilities.
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