# Presentation: 154975

## Reactive Hazards Management

*Bill Allmond*
*NACD Director of Regulatory & Public Affairs*
*Chemical Week’s*
- Transportation & Distribution Conference
- January 14, 2005
- New Orleans, LA

## Chemical Week’sTransportation & 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 Chemical
- Hazards

## Recent Industry AccidentsMorton International

## Recent Industry AccidentsMorton 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 Responsible*
*Distribution Process to include reactive*
*hazard management as an area of*
*emphasis. At a minimum, ensure that the*
*revisions address storage and handling,*
*including the hazards of inadvertent mixing*
*of incompatible chemicals.”*

- How
**Responsible Distribution****SM** 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 COMMUNICATION
- with
- 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 the
- 	workplace

## 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.