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

CTA maintenance superintendent had detailed knowledge of a catastrophic combustible dust explosion
(April 1962) at a company where he previously worked that used a process analogous to CTA’s. This
superintendent worked at the Corbin facility for over 30 years and retired a month prior to the explosion.
The CTA fire brigade training manual, revised in 1994, warned that a fire and an explosion could occur
“where accumulations of airborne dust, gas, or other combustible materials are present.”
Job safety analyses for cleaning process line dust collectors and ducts, developed in 1997, list explosion
as a potential hazard if the cleaning is done with tools capable of producing a spark. In addition, a 1997
job safety analysis on line 405 noted the hazard of using compressed air to clean the baghouse. It warned
that using air hoses causes combustible dust to be suspended in air and stated: “At no time is an air hose
to be used for cleaning out suction pipes or boxes.” Nonetheless, CTA continued to use compressed air to
clean the production lines.
8.3.1 Hazard Communication
The OSHA HazCom Standard (29 CFR. 1910.1200) requires employers to train employees on the hazards
of chemicals found in the workplace. OSHA does not require employers to evaluate chemicals to
determine their hazards. CTA relied on Borden Chemical MSDSs for hazard information. Borden’s
phenolic resin MSDSs referred CTA to NFPA 654 for safe handling practices, but CTA did not obtain or
apply this standard to its operations.
CTA’s HazCom training program consisted of an overview, a discussion on how to read an MSDS, a
review of hazardous chemicals and materials, a log sheet to identify the locations of materials in the
facility, and a video. CTA taught employees about hazard classes listed in the OSHA HazCom Standard
(i.e., combustible dusts are not defined in the HazCom standard) by citing examples of chemicals
typically used in the facility. This training also covered the HMIS labeling system used at the facility.
The plant’s safety department conducted this training annually.
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