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

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in the HazCom Standard as “any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.” CSB determined that the Borden Chemical phenolic resin MSDSs did not provide adequate warning of the explosion hazard. The MSDSs state that the resin is a combustible dust; however, they only reference NFPA 654, rather than listing specific safety warnings. Also, the information in different sections of the MSDSs was incomplete and inconsistent, and CTA personnel did not have a copy of NFPA 654. 8.2.1 Comparison of Phenolic Resin MSDSs MSDSs were Borden Chemical’s primary means of communicating the hazards of phenolic resins to CTA. The two MSDSs for phenolic resin contained identical information with respect to fire and explosion hazards. The most recent revision of the MSDS for the black phenolic resin, Borden Chemical Durite SD-52SS, was dated January 31, 2003. The most recent revision of the MSDS for the natural (without carbon black) resin, Borden Chemical Durite SD-110A, was dated September 10, 2002. Borden Chemical personnel responsible for preparing MSDSs stated they followed the OSHA HazCom Standard as well as American National Standards Institute (ANSI) Z400.1, American National Standard for Hazardous Industrial Chemicals, Material Safety Data Sheets Preparation. Section 5.1 of ANSI Z400.1 states that qualitative flammable properties and reactivity hazards that enhance the fire and explosion potential of a chemical should be stated in the firefighting measures section of the MSDS. The standard lists several examples of language that can be used on an MSDS; the first example listed is: “Powdered material may form explosive dust-air mixture.” Borden Chemical was aware that phenolic resins could produce dust explosions. In 1988, the predecessor of FM Global—Factory Mutual—provided results of explosibility tests conducted on Borden Chemical Durite AD-6514 phenolic resin powder. (This particular powder was not used at CTA.) The tests showed 62
that the phenolic resin could explode. Following the Jahn Foundry explosion in 1999, which involved a phenolic resin manufactured by Borden Chemical (Section 8.8.1), OSHA requested additional information from Borden on the explosibility of phenolic resins. In response, Borden faxed to OSHA a copy of the 1988 Factory Mutual test results plus the following references, which further demonstrate that Borden was aware of the explosive hazards: • A copy of a British research report entitled Explosibility tests for industrial dusts (Raftery, 1975) that lists the explosion parameters for phenolic resins in its appendix. • Subchapter 5.5, entitled “Dust Explosions,” plus references from the book Phenolic Resins (Knop and Pilato, 1985). CSB compared the hazard warnings on the Borden’s phenolic resin MSDSs to hazard warnings on MSDSs from seven other manufacturers of phenolic resins having the same Chemical Abstracts Service (CAS) number. The results of this comparison are presented in Table 4. As CSB was only interested in comparing MSDS hazard warnings for this particular type of phenolic resin, hazards warnings on MSDSs for other types of phenolic resins were not examined. Therefore, the hazard warnings shown in the column entitled “Other Manufacturers” do not necessarily represent hazard warnings found on MSDSs for all types of phenolic resins. Also, CSB limited its comparison to publicly available MSDSs contained in database compilations and/or available on the Internet. CSB did not obtain MSDSs from all manufacturers of this particular type of phenolic resin. Based on an evaluation of the MSDSs collected by CSB, there were notable differences between Borden’s hazard warnings and those of other manufacturers. 63
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KEY ISSUES: U.S. CHEMICAL S AFETY A
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5.1.2 Line 405 Oven Temperature Con
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9.1 FM Global Guidelines...........
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Figures 1 Simplified Layout of CTA
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ACC American Chemistry Council Acro
Page 11 and 12: Executive Summary A February 20, 20
Page 13 and 14: 1.0 Introduction At approximately 7
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Page 97 and 98: BY THE U.S. Chemical Safety and Haz
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II controllers, only manufactured a
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Therefore, at any given time, it wa
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APPENDIX D: NFPA Guidelines In prom
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D.2 Other Pertinent NFPA Codes D.2.
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APPENDIX E: HMIS Rating System The
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APPENDIX F: Simplified Organization
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Subtree A Second dust explosion abo
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Subtree C Most CTA personnel had a
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