OSHA Aligns with Society for Chemical Hazard Communication

October 23, 2003

Working with small businesses to provide information and education on chemical safety is the foundation of OSHA's newest national Alliance.

The Society for Chemical Hazard Communication (SCHC) joined with OSHA improve worker understanding in the areas of hazard communication and chemical safety.

"We're pleased to enhance our solid working relationship with SCHC on this very important issue," said OSHA Administrator John Henshaw. "Working with SCHC, we want to not only provide accurate, relevant, and valuable information and training on chemical safety, but also encourage employers and their workers to adopt safe work practices. This Alliance provides a good mechanism to focus resources on achieving this goal."

Added Michele Sullivan, Ph.D., Chairman of SCHC's Board of Directors: "With the 20th anniversary of OSHA's Hazard Communication Standard close at hand, SCHC is pleased to be signing an Alliance with the Agency to provide information and training on hazard communication and material safety data sheets (MSDS). This Alliance is another step in the hazard communication journey and the long-standing relationship between SCHC and OSHA to promote effective hazard communication."

A key feature of the Alliance is to distribute information and increase awareness about the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. GHS is a single, globally harmonized system to address the classification of chemicals, labels, and MSDS.

OSHA and SCHC will develop training and education programs to assist employers in complying with hazard communication requirements, and in preparing labels and more effective and accurate MSDSs. Information will be developed and disseminated through print and electronic media, including the use of electronic assistance tools and links from both organizations' websites.

Training seminars that address health and safety issues related to hazard communication, MSDS, and the GHS will be presented by OSHA and SCHC. Additionally, OSHA personnel will cross-train with industry safety and health professionals in SCHC's effective approaches, as jointly determined by both organizations.

Representatives of OSHA and SCHC will also participate in forums, roundtable discussions, or stakeholder meetings on hazard communication, MSDS and GHS issues to provide input and help forge innovative solutions in the workplace.

Based in Annandale, VA, SCHC is a nonprofit organization that promotes the improvement of the business of hazard communication for chemicals, and provides guidance or technical expertise to private, government, and nonprofit groups.

ConAgra Foods Recognized by OSHA for Excellence in Occupational Safety and Health

ConAgra Foods of Longmont, Colo. was recognized by OSHA as a Voluntary Protection Program (VPP) site for excellence in their safety and health program.

The Voluntary Protection Program is the Labor Department's premier initiative to promote and recognize excellence in occupational safety and health The company has been designated a VPP "Merit" site, meeting all the safety and health elements for the program, which far exceed minimum OSHA standards.

"Noteworthy aspects of ConAgra Foods' program are its safety training and computerized preventative maintenance system," said Herb Gibson, OSHA's area director in Denver. "Management fosters good ergonomic practices and supports a buddy system through its VPP committee to mentor employees on hazard identification."

VPP offers companies a unique opportunity to move beyond traditional safety programs by recognizing participants that successfully incorporate comprehensive safety and health programs into their total management systems. Requirements for earning VPP status include a high degree of management support and employee involvement in health and safety; a high-quality worksite analysis program; hazard prevention and control programs; and comprehensive safety and health training for all employees.

Each of these elements must be effective, in place and operational for at least one year before a business applies to join the program. A rigorous, week-long onsite OSHA evaluation verifies that the company has achieved excellence in safety and health.


CSB Investigators Present Final Report On First Chemical Corp. Explosion

Investigators from the U.S. Chemical Safety Board (CSB) have concluded that the October 2002 plant explosion occurred because First Chemical Corporation had not effectively evaluated the hazards of a chemical process that ran out of control. The blast blew the top off a distillation tower that was approximately 145 feet tall and propelled tons of fiery debris in the air, raining down onto adjacent industrial facilities and narrowly missing nearby hazardous chemical tanks.

The investigators’ report said that plant operators were unaware that a dangerous chemical reaction was taking place inside the tower.

The process involved mononitrotoluene or MNT, a chemical related to TNT that can be explosive when exposed to high temperatures. Operators thought the process had been shut down weeks earlier, with all sources of heat removed. Unrecognized by plant personnel, the valves used to shut off steam to the tower had deteriorated. Steam was leaking through the shut-off valves, heating the 1,200 gallons of MNT in the column to a critical temperature of over 450°F, initiating a violent reaction as the material decomposed.

The tower exploded at 5:25 a.m. on Sunday, October 13, 2002. Three plant employees were injured when glass windows shattered into the control room where they were working. The CSB report said the room was located too close to the MNT tower and was not reinforced to withstand blast pressure. A projectile from the explosion pierced an MNT storage tank some distance away, igniting a fire that burned for almost three hours. Other debris landed a few feet from a large cylinder of anhydrous ammonia without doing serious damage. Area residents were directed to seek shelter in their homes, though the CSB learned at a public meeting later that this direction was not effectively communicated to them. Additionally, residents were not aware of the appropriate action to take while they sought shelter.

Board member Dr. Gerald Poje said, “We are very fortunate that shrapnel from the tower did not cause a greater chemical release or a more damaging fire. This accident underscores once again the vital importance of properly managing dangerous reactive chemicals and the processes that use them. When the Board voted last September to recommend that EPA and OSHA strengthen their regulations to reduce such dangers, we hardly imagined such a dramatic demonstration of the need would occur just three weeks later.”

In a report presented in September 2002, the CSB noted significant gaps in regulatory coverage of reactive chemicals. The CSB Board called on OSHA and EPA to expand the regulatory coverage of reactive chemicals and mixtures under their process safety rules. Those rules specify various safety measures for chemical processes – such as performing hazard analyses, safety audits, and preventive maintenance. However, at present only a limited number of chemicals trigger such coverage. OSHA and EPA have yet to act on the Board’s 2002 rulemaking recommendation, and existing regulations do not cover MNT.

Stephen J. Wallace, CSB lead investigator, said, “The plant did not have adequate systems for evaluating the hazards of processing MNT.” He added that “First Chemical had learned of the instability of MNT during a safety analysis of a similar unit in 1996 but had not applied those safety lessons to the process that exploded – a root cause of the blast.” Mr. Wallace also noted that the facility did not have an effective program for maintaining critical process equipment like the steam shut-off valves.

The report further found that the plant did not have adequate systems to warn operations personnel of unexpected temperature increases, one sign of a runaway chemical reaction. Nor were there systems to automatically bring the process back to a safe state. Column C 501 – the tower used to distill MNT – had no temperature alarms, no automatic shutoff of the heating source, and no adequate system to relieve pressure build-up and mitigate the effects of an explosion.

The report proposes several recommendations be directed to the Pascagoula facility and the DuPont Corporation, which purchased First Chemical after the accident: that the facility improve its hazard analyses, conduct process safety audits, and install appropriate warning devices, and that DuPont Corporation track the facility’s progress. In addition, the report recommends Jackson County improve its community notification system for such emergencies.

The CSB also recommended that the American Chemistry Council (ACC) and the Synthetic Organic Chemical Manufacturers Association (SOCMA) improve their industry management code, known as Responsible Care, under which member companies agree to comply with various safety policies.

The report found that First Chemical Corporation, a SOCMA member at the time of the accident, had earlier asserted to SOCMA that it was following those agreed-upon safety policies – including performing hazard analyses – even though no evaluation had been done for the MNT unit.

The CSB is an independent federal agency charged with investigating industrial chemical accidents. CSB investigations look into all aspects of such events, including physical causes like equipment failure, as well as inadequacies in safety management systems. Typically, the investigations involve extensive witness interviews, examination of physical evidence, and chemical and forensic testing.

NIOSH Announces Criteria for Certifying Escape Respirators for Workplace Preparedness

The U.S. Centers for Disease Control and Prevention’s (CDC) National Institute for Occupational Safety and Health (NIOSH) announced criteria on October 8, 2003, that it will use under an expedited program to test and certify escape respirators for emergency preparedness in the workplace.

Escape respirators, also called escape hoods, are designed to protect users from breathing harmful gases, vapors, fumes, and dusts for a limited amount of time needed to reach fresh air.

Escape respirators that pass the full set of tests will be approved by NIOSH, allowing manufacturers to label the approved products as NIOSH-certified against chemical, biological, radiological, and nuclear (CBRN) agents in workplace escape emergencies.

NIOSH certification will help employers and users select escape respirators with greater confidence, while simultaneously driving the development of newer, more advanced devices. Partial funding for the development of the NIOSH certification standards was provided by the Department of Homeland Security, the National Institute of Justice, and the National Institute for Standards and Technology.

Escape respirators, which also are known as escape hoods, come in two types. One type, called a self contained escape respirator, consists of a hood with a tightly fitting neck piece and a contained source of breathing air. The hood provides a barrier against contaminated outside air, and the user breathes air from the attached source. In the other type, called an air purifying escape respirator, a filter canister is mounted on the hood. The user breathes outside air through the canister, which filters out harmful contaminants before the air is breathed.

On November 6, 2003, NIOSH will begin accepting applications to test and evaluate air-purifying respirators for use against CBRN agents. On January 2, 2004, NIOSH will begin accepting applications to test and evaluate self-contained escape respirators for use against CBRB agents.

"Escape respirator manufacturers and other stakeholders share NIOSH’s goal of ensuring that employers and employees have effective, reliable, and practical devices as part of their emergency preparedness programs," said NIOSH Director John Howard, M.D. "NIOSH appreciates the technical assistance offered by those partners, which allowed us to meet the demand for a certification program as quickly as possible, while ensuring that our testing criteria are stringent and practical."

NIOSH approvals will be based on positive results from rigorous tests on sample units voluntarily submitted to NIOSH by manufacturers, and from stringent evaluation of manufacturers’ quality-control practices, technical specifications, and other documentation. Both types of escape respirators will be tested against the chemical warfare agents Sarin and mustard. Air purifying escape respirators also will be tested against 10 chemicals and a particulate that will represent a wider range of 139 chemical gases and vapors, biological particulates, and radiological and nuclear dust particles.

NIOSH developed the criteria with extensive advice and review by respirator manufacturers and other stakeholders, including other federal agencies, industry organizations, and labor representatives.

NIOSH contacted respirator manufacturers directly by letter to notify them of the new criteria for testing and certifying escape respirators.  In addition, NIOSH will post the names and models of certified devices as soon as they are approved. The program to certify escape respirators for the general working population follows earlier NIOSH certification programs for self contained breathing apparatus and air purifying respirators used by emergency responders for chemical, biological, radiological, and nuclear exposures.


OSHA Offers New Resources on Chemical Reactivity Safety


The new page features information on the recognition, evaluation and control of chemical reactive hazards, and includes compliance requirements and available training resources. The page also offers free access to a new book by the Center for Chemical Process Safety (CCPS) that includes a compendium of best practices from leaders in chemical processing.

"There have been too many reminders in recent years just how tragic and catastrophic chemical reactions can be if unpredicted and not properly controlled or contained," said OSHA Administrator John Henshaw. "Our goal and commitment is to work with chemical safety stakeholders throughout the country to prevent these incidents in the future. The information we're presenting on this new webpage is only a part of OSHA's far-reaching strategy to protect workers in this industry."

Visitors to the new webpage can access OSHA standards and fact sheets on process safety management (PSM) as well as additional reactive material hazard information from CCPS. Additionally, one click will take readers to a chemical reactivity worksheet provided by the National Oceanographic and Atmospheric Administration's Office of Response and Restoration. The worksheet includes a database of reactivity information for more than 6,000 common hazardous chemicals and also details on what dangers can arise during chemical mixing.

OSHA is also providing free access to the CCPS book Essential Practices for Managing Chemical Reactivity Hazards. The book is useful for safety and health managers, engineers, chemists and others involved in chemical manufacturing or operations to identify, address and manage chemical reactivity hazards.

The new webpage also includes reports on various reactive chemical incidents and resulting investigative reports, as well as references to other sources of information on chemical safety.

Henshaw unveiled the agency's multi-faceted strategy in chemical reactive safety at the Center for Chemical Process Safety's 18th Annual International Conference in Scottsdale, AZ, last month. In addition to the new webpage, Henshaw told the group that OSHA is working on additional guidance on hazard communication, including material safety data sheets, and will also revise the compliance directive for the PSM standard. He said the agency will participate in the American Institute of Chemical Engineers' Reactivity Management Roundtable this month and is also developing an Alliance with a number of groups in the chemical industry.

"I believe our comprehensive approach to address hazards posed by reactive chemicals is a sound one," Henshaw said. "This new webpage is an important part of a well-rounded strategy that will result in fewer reactive chemical incidents and fewer worker injuries and deaths."