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Study of the Morton Chemical explosion demonstrates failure of OSHA and EPA laws to address reactive chemical hazards.
On April 8, 1998, an explosion and fire at Morton Chemical International (now Rohm & Haas) in Paterson, New Jersey injured nine people, including two who were seriously injured. Hazardous materials were released into the community. The U.S. Chemical Safety and Hazard Investigation Board has completed its investigation of the plant. The Board concluded that a runaway reaction occurred inside a chemical processing “kettle” during the reactive process involved in producing Yellow 96 Dye. The chemical explosion demonstrates deficiencies in the OSHA and EPA laws which require planning and process design evaluations to prevent catastrophic chemical accidents. According to Dr. Andrea Taylor, a Chemical Safety Board (CSB) member and former UAW Health and Safety Department staff person, “although Material Safety Data Sheets (MSDSs) include the chemical makeup of agents used, it is not always known what chemical reaction might occur when these agents are used together.” The CSB found that safety programs used by Morton for managing reactive chemical hazards did not recognize or anticipate the potential for a catastrophic chemical reaction in the production of Yellow 96 Dye. They also found that important safety information and recommendations about the hazards of the Yellow 96 Dye production process were not made known to development and production personnel at the Paterson facility. This resulted in kettle design flaws and omissions in the operating instructions used to produce the dye.
Investigators determined that the kettle did not have the cooling capacity to safely control the temperature of the reaction during process upsets. The kettle was not equipped with safety features, such as a quench system or a reactor dump system to stop the process in the event of a runaway reaction. The CSB determined that company training and operating procedures did not go far enough. Operators were not trained on how to safely operate the dye process or to recognize hazardous situations that would require evacuation of the facility. A key finding from the investigation was that the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard covers only a small number of reactive chemicals. Also, the Environmental Protection Agency’s (EPA) Risk Management Program rule does not cover reactive chemicals as a class. As such, neither standard provides much guidance on reactive chemical process safety management issues like 1. the use of chemical screening techniques 2. the proper design of pressure relief systems 3. emergency coding and 4. safety interlock systems The CSB made a number of specific recommendations following its investigation. One recommendation was that OSHA and EPA issue joint guidelines for controlling reactive chemical hazards. It was recommended that both agencies (EPA and OSHA) participate in a joint project to evaluate of reactive chemical process safety using data from investigations conducted by the CSB. This joint project would seek to document the frequency and severity of reactive chemical incidents; examine how industry, OSHA, and EPA currently address reactive chemical hazards; analyze the effectiveness of industry and OSHA use of the National Fire Protection Association Reactivity Rating system for process safety management purposes. Such a study will result in a set of recommendations to reduce the number and severity of reactive chemical incidents. The Chemical Safety Board: An Excellent Resource The Chemical Safety Board provides an excellent resource to promote safer production practices. “Until this year,” Dr. Taylor noted, “the Board functioned with a skeleton investigations staff. We now have refocused our resources in a fairly dramatic way, putting the majority of our budget into investigations and recruiting a number of seasoned accident investigators and safety professionals. Over the next several years, we will build the capacity to conduct three to five major accident investigations per year. Well-trained teams will be dispatched to each accident site, and once deployed we will wrap each case up as expeditiously as possible.”
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