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

Borden Chemical rates the flammability of the Durite phenolic resins as “1” (slight hazard), which
according to the NPCA applies to materials that must be preheated for ignition to occur. Borden
Chemical personnel stated that this hazard rating was appropriate because they found many examples of
combustible solids where the HMIS code for flammability was listed as “1.” However, the HMIS
Implementation Manual states that “materials that on account of their physical form or environmental
conditions can form explosive mixtures with air and that are readily dispersed in air, such as dusts of
combustible solids and mists of flammable or combustible liquid droplets” should be rated as “3” (serious
hazard; NPCA, 1976).
Of the seven other phenolic resin manufacturers’ MSDSs CSB compared with the Borden Chemical
MSDSs, four manufacturers provided HMIS ratings. Three of the four rated flammability as “1,” while
the fourth rated it as “2.”
8.2.3 Borden Chemical Product Stewardship
Borden Chemical was a member of the American Chemistry Council (ACC) at the time of the incident—
February 2003. As a condition of membership, Borden Chemical participated in the ACC Responsible
Care program. Members of ACC agree to develop voluntary practices to address management codes and
to submit annual reports of their progress. 21 The codes cover topics such as process safety management,
health and safety, and product stewardship. Management practices in the ACC Product Stewardship Code
include the following:
• Establish and maintain information on health, safety, and environmental hazards and
reasonably foreseeable exposures from new and existing products.
21 The Responsible Care elements referenced herein are those in place in February 2003. ACC has recently added a
requirement for independent third-party audits of member company programs.
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