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

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10.0 Regulatory Analysis CSB reviewed workplace safety regulations and building codes applicable to the CTA facility. These regulations are promulgated and enforced by the Kentucky Department of Labor and the Office of Housing, Buildings, and Construction, which are both part of the Environmental and Public Protection Cabinet (Appendix F). The regulatory analysis determined that the Kentucky Office of Occupational Safety and Health (OSH) conducted several comprehensive inspections of the facility but did not issue citations regarding combustible dust hazards. Also, the State Fire Marshal’s office had not inspected the facility since it was constructed in 1972. 10.1 Federal and Kentucky Workplace Safety Kentucky regulates workplace safety through a State plan approved by OSHA. Kentucky OSH enforces the state regulations, while the Occupational Safety and Health Standards Board adopts regulations identical to or at least as effective as Federal OSHA regulations. Kentucky OSH inspectors conducted wall-to-wall planned inspections of the Corbin facility in 1989, 1993, and 2000. No citations related to combustible dust hazards were issued. In December 2002, Kentucky OSH inspectors conducted a limited inspection after receiving a complaint regarding machine guarding and health hazards from resins. CTA was cited for inadequate machine guarding. However, inspectors determined that the health hazard allegation regarding resin was unfounded. Following the February 20, 2003 incident, Kentucky OSH issued citations to CTA—one of which stated that the company did not provide a place of employment free of recognized hazards likely to cause death or serious harm to employees. This requirement is known as the “general duty clause.” The citation further stated that compliance guidance for preventing dust fires and explosions is found in the NFPA 84
standards (Appendix D). Kentucky OSH issued other citations for inadequate ventilation and unapproved electrical equipment in areas where combustible dusts were present. Following the West Pharmaceutical dust explosion, the North Carolina Department of Labor (2003) issued an industry alert on combustible dust hazards. Kentucky OSH has issued no educational material to alert employers of the dangers of combustible dusts. Federal OSHA has adopted regulations that address the prevention of dust explosions in certain business sectors, including grain-handling facilities; pulp, paper, and paperboard mills; bakeries; and sawmills. In addition, it has adopted general industry regulations to control certain activities such as the use of electrical equipment and forklifts in environments that may contain combustible dusts. In 29 CFR 1910.272(j)(3), OSHA requires that grain-handling facilities have a written housekeeping program that sets the frequency and methods for controlling dust on exposed surfaces. These facilities must remove dust whenever it exceeds 0.125 inch in priority areas. In the grain standard, OSHA also warns that using compressed air for cleaning combustible dust can be hazardous if all potential ignition sources are not removed or controlled. Although both OSHA and the Kentucky Occupational Safety and Health Standards Board have adopted certain NFPA standards, neither has adopted NFPA 654 (2000)—which addresses dusts such as those found at CTA. NFPA 654 lists specific design and work practice precautions (Appendix D). 10.2 Kentucky Office of Housing, Buildings, and Construction 10.2.1 Code History In 1954, Kentucky Revised Statute Section 227.300 established rules and regulations known as the “Standards of Safety.” These standards established requirements for design and construction of various 85
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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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2.0 Key Findings 1. Combustible phe
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3.0 Facility Description 3.1 CTA Ac
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eams. Nonload-bearing masonry block
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Thirteen-foot-high freestanding enc
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4.0 Process Description The product
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4.1.2 Mat-former and Baghouse In th
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Circulating fans and dampers direct
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• Manually striking baghouse bags
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5.0 Incident Description 5.1 Pre-In
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Page 41 and 42: 5.3.3 Firefighting Activities 5.3.3
Page 43 and 44: 5.4 Incident Aftermath The CTA inci
Page 45 and 46: 6.0 Understanding Combustible Dust
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Page 57 and 58: Table 3 Borden Chemical Black Pheno
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Page 97 and 98: BY THE U.S. Chemical Safety and Haz
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Page 101 and 102: APPENDIX A: Fire and Explosion Dama
Page 103 and 104: APPENDIX B: Laboratory Testing of P
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Page 121 and 122: APPENDIX E: HMIS Rating System The
Page 123 and 124: APPENDIX F: Simplified Organization
Page 125 and 126: Subtree A Second dust explosion abo
Page 127: Subtree C Most CTA personnel had a
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