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

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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. 66
• Characterize new and existing products with respect to their risks using information about health, safety, and environmental hazards and reasonably foreseeable exposures. • Provide health, safety, and environmental information to direct product receivers. Commensurate with product risk, collaborate on fostering proper use, handling, recycling, disposal, and transmittal of information to downstream users. When a company identifies improper practices involving a product, work with the product receiver to improve those practices. If, in the company’s independent judgment, improvement is not evident, take further measures—up to and including termination of product sale. Borden Chemical was also a member of the Society of the Plastics Industry (SPI) until 1999. This trade association represents processors, machinery and equipment manufacturers, and raw material suppliers of plastics, including phenolic resins. This association works with technical and regulatory groups to develop standards for product performance and safety. In March 2004, SPI issued a new product stewardship policy to help plastics manufacturers identify and manage the health, safety, and environmental aspects of their products. SPI has a division dedicated to phenolic resins that keeps its members updated on safety and health issues; however, it has not issued any publications on phenolic resin hazards. 8.2.3.1 Phenolic Resin Product Stewardship Efforts In 1997, Borden Chemical developed a 2-page fact sheet entitled Phenolic Resin Powders: Frequently Asked Environmental, Health and Safety Questions. In answer to: “How finely ground are phenolic resin powders?”, the sheet explains that 90 percent of phenolic resin particles are below 40 microns in size. In answer to: “Do phenolic resin dusts pose an explosion hazard?”, the fact sheet states: 67
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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
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Executive Summary A February 20, 20
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1.0 Introduction At approximately 7
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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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