Embed Size (px)
Citation preview
Reactive Hazards Management
Bill AllmondNACD Director of Regulatory & Public Affairs
Chemical Week’sTransportation & Distribution Conference
January 14, 2005New Orleans, LA
Chemical Week’sTransportation & Distribution Conference
The following slides will explain: Reactive Hazards: Why There is Now
Increased Attention to Them Challenge to Chemical Distribution
Industry How Responsible DistributionSM Addresses
Reactive Hazards Management Alliance w/ OSHA - Reactivity
What Is a Reactive Chemical Incident?
CSB Definition of Reactive Chemical Incident
A sudden event involving an uncontrolled chemical reaction with significant increases
in temperature, pressure, and/or gas evolution that has the potential to, or has
caused, serious harm to people, property or the environment.
Why There Is an Increased Attention Given to
Reactive ChemicalHazards
Recent Industry AccidentsMorton International
Recent Industry AccidentsMorton International
April 8, 1998 Chemical manufacturing facility Paterson, NJ Explosion & Fire occurred during
production of Automate Yellow 96 Dye Runaway chemical reaction in over-
pressurized 2,000-gallon chemical vessel 9 employees injured
Recent Industry Accidents
Concept Sciences
Recent Industry Accidents
Concept Sciences
February 19, 1999 Allentown, PA Chemical manufacturing facility Violent explosion occurred during
batch processing of hydroxylamine 4 facility employees + 1 manager of
adjacent business killed, 6 employees injured
Recent Industry Accidents Napp Technologies
Recent Industry Accidents Napp Technologies
April 21, 1995 Lodi, NJ Chemical production facility Explosion & fire due to inadvertent
mixing of incompatible chemicals 5 employees killed
Recent Industry Accidents Bartlo Packaging
Recent Industry Accidents Bartlo Packaging
May 8, 1997 West Helena, AR Bulk storage & distribution facility Explosion & fire occurred during
repackaging operation 3 firefighters killed, 1 injured
U.S. Chemical Safety Board
CSB Reactive Chemical Hazard Study Comprehensive study released in 2002. Analyzed 167 industrial accidents
involving reactive chemicals. 48 resulted in 108 fatalities of workers
&/or responders. 49 affected the public.
CSB Study Conclusions
Findings Included: Reactive incidents are diverse; they occur in
manufacturing as well as in storage and distribution. Nearly 30% of the accidents analyzed occurred in
storage and handling. Sources of data on reactive hazards are inadequate. Industry not adequately obtaining existing
knowledge on reactive hazards. Gap in regulations: OSHA & EPA. Gap in industry standards: NFPA. Gaps in industry practices: RC & RDP
specifically listed.
Safety Recommendations Issued: OSHA: Expand PSM to cover reactive
hazards. EPA: Expand RMP to cover reactive
accidents. NACD, ACC, SOCMA: Expand your industry
practices (i.e., RDP & RC).
Challenge to Chemical Distribution
Industry
Specific recommendation to NACD:“Expand the existing ResponsibleDistribution Process to include reactivehazard management as an area ofemphasis. At a minimum, ensure that therevisions address storage and handling,including the hazards of inadvertent mixingof incompatible chemicals.”
How Responsible DistributionSM
Addresses Reactive Hazards
Management
RDP & Reactive Hazards Management
What was Approved
New requirement added to two (2) existing RDP elements of the “Handling & Storage” Section of the Code of Management Practice.
RDP & Reactive Hazards Management
IV. Handling & Storage (new language in bold) C. Procedures for loading and unloading chemicals at
member company’s facilities that result in protection of personnel, a reduction in emissions to the
environment, and an increased awareness of hazards from inadvertent mixing of incompatible chemicals.
D. A process for providing manufacturer guidance and information to customers, warehouses, terminals,
and carriers on procedures for loading, unloading, and storing chemicals; and a process to increase
awareness of hazards from inadvertent mixing of incompatible chemicals.
RDP & Reactive Hazards Management
Why “Handling & Storage”?
Because the CSB referenced this portion of Responsible DistributionSM as an area of emphasis.
Because it is the most relevant RDP component in which reactive hazards can be managed.
RDP & Reactive Hazards Management
Key to compliance:
INCREASED COMMUNICATIONwith
DISTRIBUTION EMPLOYEES, CUSTOMERS, WAREHOUSES, & CARRIERS
about HAZARDS from INADVERTENT MIXING OF
INCOMPATIBLE CHEMICALS
RDP & Reactive Hazards Management
Compliance Factors Method will vary from distributor to
distributor, product to product, facility to facility, hazard to hazard.
Special attention to manufacturer MSDSs.
RDP & Reactive Hazards Management
First steps to consider
Review MSDSs received from suppliers. Check for any references to product
incompatibility. Check for any references to hazards from
inadvertent mixing. Consider how the references may be
relevant, if not already stated specifically, to storage and handling.
RDP & Reactive Hazards Management
First steps to consider (cont’d)
Review existing company policies and procedures regarding Handling & Storage of chemicals.
Consult employees who may have knowledge & experience with handling & storage potentially reactive chemicals stored & transported by NACD members.
Decide how distribution policies and procedures will need to be updated to include new requirements.
RDP & Reactive Hazards Management
Compliance Date: January 1, 2005.
Third-Party Verifications to verify compliance include these two new
requirements after this date.
RDP & Reactive Hazards Management
Compliance Tools: NACD guidance: “Reactive Hazards
Management Guidance for NACD Members to Address Requirements under the Responsible Distribution Process”.
NACD’s alliance with OSHA & other industry trade associations to develop guidance & training.
Industry – OSHA Alliance Signed March 30, 2003 Partnership between industry
& OSHA NACD, ACC, SOCMA, CI,
CCPS, MKOC, EPA Committed to increasing
awareness of reactive hazards among our memberships: distributors, manufacturers, employees, third-parties
Help forge innovative solutions in theworkplace
RDP & Reactive Hazards Management
Recommendations Carriers: Check to see if suppliers and/or distributors
are providing you with reactivity hazard information about the chemicals you are transporting.
Distributors: if you are not a member of NACD, seriously consider how or if you address the potential for reactions in storage and handling.
Other Industry Organizations: Consider making reactive hazards management requirements mandatory for companies adhering to your management systems.
Chemical Week: Continue to cover issues involving reactive hazards management, including best practices being employed by industry.
