September 20, 2001

Exposing employees to explosion hazards has led to $141,000 in proposed penalties against BP Amoco Polymers, Inc., by OSHA. The alleged willful and serious citations for violation of safety standards resulted from an inspection of a March 13 explosion and fire that killed three workers at the company's Clanton Road plant.

OSHA cited BP Amoco for two alleged willful violations with proposed penalties of $125,000 for exposing employees to the release of hazardous energy.

The accident occurred as three workers began removing bolts from a drum in preparation for maintenance and cleaning. Unknown to the men, the drum was overfilled with a polymer salt mixture which continued to react and clogged lines into and out of the vessel, eventually producing an elevated pressure condition inside the drum. Failure to initiate proper lockout/tagout procedures before attempting to remove the bolts from the cover plate contributed to this accident.

In 1990, before operations began at the unit, Amoco studies indicated the need for an effective indicator to measure the amount of mixture in the drum as a protection against hazards caused by overfilling the vessel. An effective device was never installed.

Again in August 2000 after two employees were seriously burned by a hot liquid release, recommendations were made -- but never implemented -- for an operations checklist to verify that vessels were fully drained, depressurized and energy sources disconnected before cleaning and maintenance began.

"This tragedy could have been avoided if the company had adhered to their own internal audit recommendations that improvements were needed in the lockout/tagout program," said William Grimes, OSHA's Atlanta-East area director. "Safety studies have little value if resulting recommendations go unheeded."

The company received three serious citations with proposed penalties totaling $16,000 for failing to: properly install pressure relief devices; require proper face protection for employees working with corrosive materials; and properly train employees on lockout/tagout.

BP Amoco, headquartered in Alpharetta, Ga., is a division of London, England-based British Petroleum. The company, which manufactures plastics materials and resins, has 15 working days to contest OSHA's citations and penalties before the independent Occupational Safety and Health Review Commission.


Far beneath the earth's surface where miners extract coal, the working environment can change in an instant. In case of a fire, roof collapse or explosion, specially trained teams of rescuers may make the difference between life and death. From Sept. 17 through Sept. 21, coal mine rescue teams from around the country are taking part in the 2001 National Mine Rescue, First Aid and Bench Contest at the Kentucky Fair and Exposition Center in Louisville, Ky.

"We have all admired the selfless dedication of the responders in last Tuesday's tragedies," said Dave Lauriski, assistant secretary of labor for mine safety and health. "In an underground coal mine emergency, the type of specialized teams now gathered in Louisville would be the ones to respond. In this contest, mine rescuers put the finishing touches on their preparedness as they test their skills against each other. Even as the recovery efforts go on in New York and Washington, D.C., these teams are working to keep their specialized skills sharp to respond to a different type of emergency.

Mine rescue competitions test the knowledge of highly trained teams of miners who have studied and practiced to respond to a mine emergency. Six-member teams must solve a hypothetical mine emergency problem while judges rate them on their adherence to mine rescue procedures and how quickly they complete specific tasks.

In other phases of the competition, benchmen - individuals who maintain rescue equipment - must thoroughly inspect breathing devices and correct defects as quickly as possible. In the first aid contest, emergency medical technicians tackle real-life scenarios.

Mine rescue training began in the United States in 1910. The training efforts evolved into local and regional competitions leading up to the national contest.


In industry, as elsewhere, change often brings progress. But it can also increase risks that, if not properly managed, create conditions that may lead to injuries, property damage or even death.

A new Safety Bulletin from the U.S. Chemical Safety and Hazard Investigation Board (CSB) released concerning "Management of Change" (No. 2001-04-SB, August 2001) discusses two incidents (one in Maryland and the other in Washington State) that occurred in the United States in 1998. The first incident involved a November 25th fire at an Equilon Enterprises oil refinery in Anacortes, Washington. The fire in the delayed coking unit caused six fatalities. The second incident on October 13th involved a reactor vessel explosion and fire at the CONDEA Vista Company detergent alkylate plant in Baltimore, Maryland that injured four people and caused extensive damage.

Each case history offers valuable insights into the importance of having a systematic method for management of change (i.e., managing changes in chemical processes using a formal Management of Change [MOC] program). An MOC methodology should be applied to operational deviations and variances, as well as to preplanned changes --- such as those involving technology, processes, and equipment.

The CSB MOC Safety Bulletin explains that lack of time for safety decision-making was not a factor in causing the incidents. According to the Bulletin:

Neither the Equilon Enterprises oil refinery nor the CONDEA Vista Company explosion and fire involved emergencies that required rapid decision making. In each instance, time was available to look into the circumstances more thoroughly. Each situation could have been avoided with a more analytical and structured approach to problem solving.

The CSB found that there were numerous contributing factors that caused these incidents. However, the CSB believes that properly conceived and executed MOC programs could have helped to prevent or mitigate the effects of both events.

Both OSHA's Process Safety Management standard and EPA's Risk Management Plan require facilities to manage changes in covered processes handling highly hazardous materials using a formal MOC program. However, the Bulletin states, "it is good practice to do so, irrespective of the specific regulatory requirements."

The CSB urges organizations to review their MOC policy to be sure it covers operational variances in addition to physical changes. If your organization doesn't have a systematic method for handling changes, develop and implement one.

To maximize the effectiveness of your MOC system, the Bulletin suggests that the following activities be included:

  • Define safe limits for process conditions, variables and activities --- and train personnel to recognize significant changes. Combined with knowledge of established operating procedures, this additional training will enable personnel to activate the MOC system when appropriate.

  • Apply multidisciplinary and specialized expertise when analyzing deviations.

  • Use appropriate hazard analysis techniques.

  • Authorize changes at a level commensurate with risks and hazards.

  • Communicate the essential elements of new operating procedures in writing.

  • Communicate potential hazards and safe operating limits in writing.

  • Provide training in new procedures commensurate with their complexity.

  • Conduct periodic audits to determine if the program is effective.


U.S. Labor Secretary Elaine L. Chao announced that the Occupational Safety and Health Administration (OSHA) is providing advice and technical assistance to employers and federal agencies to help protect workers from exposure to hazardous substances in the New York City and Pentagon disaster sites.

In New York, OSHA is testing asbestos levels in buildings within a several block radius surrounding the perimeter of the World Trade Center emergency site.

"OSHA is working with other federal agencies to help employees return to their jobsites as quickly as possible. Initial reports on asbestos levels in outlying buildings are extremely encouraging. OSHA's goal is to ensure that people who enter buildings near or downwind from the emergency area are protected and provided with all of the safety information possible," said Labor Secretary Elaine L. Chao.

OSHA inspectors are working in conjunction with the Environmental Protection Agency (EPA) to test asbestos levels in New York City. EPA sampling of ambient air quality have found either no asbestos or very low levels of asbestos. Sampling of bulk materials and dust found generally low levels of asbestos.

OSHA has also been advising Consolidated Edison regarding safety standards for employees who are digging trenches because of leaking gas lines underground. The agency is advising the Federal Bureau of Investigations and the Bureau of Alcohol, Tobacco and Firearms regarding worker protection during rescue operations.

At the Pentagon, OSHA is assisting with concerns about asbestos exposure and structural damage during rescue operations.

In addition to OSHA's role, Chao also highlighted the role of the Department of Labor's Office of Workers Compensation Claims (OWCP), which has established teams to expedite processing of workers' compensation claims for eligible federal staff and emergency personnel.

The Federal Employees' Compensation Act covers all civilian federal employees who sustain injuries while on duty assisting recovery efforts in the Pentagon and World Trade Center attacks and subsequent rescue operations. Surviving spouses and dependent children are also entitled to benefits.

The Department of Defense has set up a crisis center in Crystal City to assist Pentagon personnel and their relatives, and the Department of Labor has OWCP staff and computer equipment on site to process claims immediately. Federal civilian employees are also encouraged to call 1-866-999-FECA for assistance on compensation claims.

"As President Bush stated, our way of life, our very freedom came under attack this week," said Labor Secretary Chao. "In the midst of this tragedy, we have resolved to do the work of the people. Checks should go out; claims should be processed; and work sites should be inspected. The only way these attacks will succeed is if they prevent our government from serving the American people. This will not happen. Our resolve to do our duty and serve the country we love will not be deterred or diminished by terrorist acts."


EPA and OSHA announced last week that the majority of air and dust samples monitored in New York's financial district do not indicate levels of concern for asbestos. The new samples confirm previous reports that ambient air quality meets OSHA standards and consequently is not a case for public concern. New OSHA data also indicates that indoor air quality in downtown buildings will meet standards.

EPA has found variable asbestos levels in bulk debris and dust on the ground, but EPA continues to believe that there is no significant health risk to the general public in the coming days. Appropriate steps are being taken to clean up this dust and debris.

"Our tests show that it is safe for New Yorkers to go back to work in New York's Financial District" said John L. Henshaw, Assistant Secretary of Labor for OSHA. "Keeping the streets clean and being careful not to track dust into buildings will help protect workers from remaining debris."

OSHA staff walked through New York's Financial District on September 13th wearing personal air monitors and collected data on potential asbestos exposure levels. All but two samples contained no asbestos. Two samples contained very low levels of unknown fiber, which is still being analyzed.

Air samples taken on September 13th inside buildings in New York's financial district were negative for asbestos. Debris samples collected outside buildings on cars and other surfaces contained small percentages of asbestos, ranging from 2.1 to 3.3 -- slightly above the 1 per cent trigger for defining asbestos material.

"EPA will be deploying sixteen vacuum trucks in an effort to remove as much of the dust and debris as possible from the site where the samples were obtained" said EPA Administrator, Christine Whitman. "In addition, we will be moving six continuous air monitoring stations into the area. We will put five near ground zero and one on Canal Street. The good news continues to be that the air samples have all been at levels that cause us no concern.


Speakers will use real-life examples to demonstrate strategies for reducing worker risks and lowering costs, both human and financial, during a Ft. Lauderdale conference sponsored by the U.S. Labor Department's Occupational Safety and Health Administration.

The conference, scheduled to begin at 1:00 p.m., Tues., Sept. 25 and end at 4:00 p.m. Wed., Sept. 26, will be held at The Embassy Suites Hotel, 1100 SE 17th Street, Fort Lauderdale.

OSHA's Atlanta regional office, along with mental health professionals, administrators, researchers and regulators from all parts of the country, developed the program in response to the increasing number of injuries and deaths reported among psychiatric workers.

"Working together, employers and employees can develop and implement a set of actions appropriate for their facilities," said Cindy Coe, OSHA regional administrator, Atlanta. "Education and prevention are key to reducing worker exposure to conditions that lead to injury and death."

The free conference is for chief executive officers, senior managers and risk managers, but is open to the media and the public. Further information may be obtained by calling Ben Ross at the Atlanta regional office, phone: (404) 562-2284, or 2300; Luis Santiago at the OSHA Ft. Lauderdale area office, phone: (954) 424-0242 ext. 29.


OSHA cited Eufaula Pulpwood Company, Inc. and proposed penalties totaling $80,150 following a fatal accident at a Georgetown, Ga., job site.

OSHA began an inspection in response to an accident on April 2 which resulted in the death of an employee who was pulled into the rollers of a chipper machine and crushed. The chipper was turned on while the worker was inside the feed-in section of the machine replacing its chains.

During the inspection, OSHA found that company officials had received training from a forestry association about lockout/tagout procedures which require that a machine be de-energized during maintenance and repair. Additional training on safe operation and maintenance of the chipper, including locking out the machine during maintenance, was provided by a manufacturer's representative.

OSHA cited the company for one alleged willful violation of "lockout/tagout" standards and proposed a $49,000 penalty. A willful violation is one committed with an intentional disregard of, or plain indifference to, the requirements of the Occupational Safety and Health Act.

"This employer received extensive training on lockout/tagout requirements," said Teresa Harrison, OSHA's Savannah area director. "Additionally, numerous warning signs warned of the danger of not locking out the machine. Following all the safety precautions would have prevented this tragic accident."

The remaining $31,150 penalty was proposed for nine serious safety violations, including failing to provide equipment for eye and face protection; not developing a lockout/tagout program; failing to follow the manufacturer's maintenance instructions; not providing proper railing on the machine platform; failing to develop and implement a hazard communication program, and not providing employees job hazard training or training in first aid and CPR. A serious violation is one in which there is substantial probability that death or serious physical harm could result and that the employer knew or should have known of the hazard.

Eufaula Pulpwood, which employs 80 workers, has 15 working days to contest the citations and proposed penalties before the independent Occupational Safety and Health Review Commission.

OSHA has a national initiative targeting logging because of the high number of injuries and deaths in the industry.