CTA Report, Draft 1, ISP Review - US Chemical Safety and Hazard ...

8.0 Incident Analysis
The incident analysis explored reasons why:
• The facility design lacked effective firewalls and blast-resistant construction.
• Inefficient baghouse operations and improper production line cleaning activities dispersed
combustible dust and deposited it on elevated flat surfaces, where it accumulated.
• Lack of housekeeping on elevated flat surfaces allowed combustible dust to build up to
unsafe levels.
• Borden Chemical did not communicate to CTA the safety lessons from the 1999 Jahn
Foundry dust explosions that involved a similar phenolic resin.
CSB investigators constructed a logic tree diagram to assist in the incident analysis (Appendix G). The
Board concluded from this analysis that most CTA personnel had a lack of understanding of the explosive
hazards posed by combustible dusts. CSB determined that were three reasons for this lack of
understanding. First, CTA did not implement effective measures to prevent combustible dust explosions.
This was due to the fact that CTA did not obtain and apply NFPA 654 guidelines as recommended by
Borden Chemical in its phenolic resin MSDSs. Second, the CTA hazard communication program did not
address combustible dusts. And finally, Borden Chemical did not explicitly communicate the explosive
hazard of phenolic resins to CTA.
8.1 Explosive Hazards of Phenolic Resins
The Occupational Safety and Health Administration (OSHA) Hazard Communication (HazCom)
Standard requires that chemical manufacturers such as Borden Chemical evaluate their products to
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