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

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Phenolic resin dusts should be regarded as explosible <strong>and</strong> liable to give rise to a dust<br />

explosion hazard provided the concentration in air is very high, i.e., 20 [g/m 3 ] <strong>and</strong> the<br />

ignition temperature of 450°C is reached.<br />

This fact sheet was provided to Borden <strong>Chemical</strong> manufacturing, sales, marketing, <strong>and</strong> research <strong>and</strong><br />

development personnel. It was not systematically distributed to Borden <strong>Chemical</strong> customers, <strong>and</strong> it was<br />

not provided to <strong>CTA</strong>.<br />

In April 2000, Borden <strong>Chemical</strong> prepared a draft “Dear Customer” letter to discuss the Jahn Foundry<br />

explosion, which involved a Borden <strong>Chemical</strong> Durite phenolic resin (Section 8.8.1). The letter listed the<br />

causal factors that led to the explosion, as concluded by a joint OSHA/Massachusetts Department of Fire<br />

Services/Springfield Arson <strong>and</strong> Bomb Squad report. The draft letter recommended that Borden <strong>Chemical</strong><br />

customers follow good housekeeping practices <strong>and</strong> the requirements of NFPA 654 to prevent dust<br />

explosions. A copy of the joint investigation report was to be attached; however, Borden <strong>Chemical</strong> did<br />

not send the letter or the report. Also, Borden <strong>Chemical</strong> reviewed the language on its MSDSs <strong>and</strong> labels<br />

for Durite resins, but determined that no changes were needed.<br />

In June of 2004, more than one year after the <strong>CTA</strong> explosion, Borden <strong>Chemical</strong> distributed safe h<strong>and</strong>ling<br />

guidelines (8 pages) to its phenolic resin customers entitled Phenolic Resin/Powders, Flakes <strong>and</strong><br />

Pastilles: Dust <strong>Hazard</strong>s <strong>and</strong> Recommended Control Practices. These guidelines include: a discussion of<br />

the hazardous properties of phenolic resins, including the conditions needed for a dust explosion; typical<br />

material characteristics (e.g., Kst, MIE, MEC, Pmax); protective measures; <strong>and</strong> NFPA 654 excerpts<br />

(including information on dust control, inspection, maintenance, <strong>and</strong> training).<br />

8.2.3.2 Borden <strong>Chemical</strong>’s Product Stewardship Efforts With <strong>CTA</strong> Acoustics<br />

A Borden <strong>Chemical</strong> safety engineer stated that in 1995 he sent a letter addressed to <strong>CTA</strong> to follow up on a<br />

telephone conversation with the <strong>CTA</strong> engineering manager concerning a proposed process change<br />

involving Borden <strong>Chemical</strong> phenolic resins. In the letter, the Borden <strong>Chemical</strong> safety engineer advised<br />

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