Reactive Hazards Management Bill Allmond NACD Director of Regulatory & Public Affairs Chemical Week’s Transportation & Distribution Conference January 14, 2005 New Orleans, LA

Chemical Week’s Transportation & Distribution Conference The following slides will explain: Reactive Hazards: Why There is Now Increased Attention to Them Challenge to Chemical Distribution Industry How Responsible DistributionSM Addresses Reactive Hazards Management Alliance w/ OSHA - Reactivity

What Is a Reactive Chemical Incident? CSB Definition of Reactive Chemical Incident A sudden event involving an uncontrolled chemical reaction with significant increases in temperature, pressure, and/or gas evolution that has the potential to, or has caused, serious harm to people, property or the environment.

Why There Is an Increased Attention Given to Reactive Chemical Hazards

Recent Industry Accidents Morton International

Recent Industry Accidents Morton International April 8, 1998 Chemical manufacturing facility Paterson, NJ Explosion & Fire occurred during production of Automate Yellow 96 Dye Runaway chemical reaction in over-pressurized 2,000-gallon chemical vessel 9 employees injured

Recent Industry Accidents Concept Sciences

Recent Industry Accidents Concept Sciences February 19, 1999 Allentown, PA Chemical manufacturing facility Violent explosion occurred during batch processing of hydroxylamine 4 facility employees + 1 manager of adjacent business killed, 6 employees injured

Recent Industry Accidents Napp Technologies

Recent Industry Accidents Napp Technologies April 21, 1995 Lodi, NJ Chemical production facility Explosion & fire due to inadvertent mixing of incompatible chemicals 5 employees killed

Recent Industry Accidents Bartlo Packaging

Recent Industry Accidents Bartlo Packaging May 8, 1997 West Helena, AR Bulk storage & distribution facility Explosion & fire occurred during repackaging operation 3 firefighters killed, 1 injured

U.S. Chemical Safety Board CSB Reactive Chemical Hazard Study Comprehensive study released in 2002. Analyzed 167 industrial accidents involving reactive chemicals. 48 resulted in 108 fatalities of workers &/or responders. 49 affected the public.

CSB Study Conclusions Findings Included: Reactive incidents are diverse; they occur in manufacturing as well as in storage and distribution. Nearly 30% of the accidents analyzed occurred in storage and handling. Sources of data on reactive hazards are inadequate. Industry not adequately obtaining existing knowledge on reactive hazards. Gap in regulations: OSHA & EPA. Gap in industry standards: NFPA. Gaps in industry practices: RC & RDP specifically listed.

Safety Recommendations Issued: OSHA: Expand PSM to cover reactive hazards. EPA: Expand RMP to cover reactive accidents. NACD, ACC, SOCMA: Expand your industry practices (i.e., RDP & RC).

Chemical Distribution Industry Challenge to Chemical Distribution Industry

Specific recommendation to NACD: “Expand the existing Responsible Distribution Process to include reactive hazard management as an area of emphasis. At a minimum, ensure that the revisions address storage and handling, including the hazards of inadvertent mixing of incompatible chemicals.”

Responsible DistributionSM Addresses Reactive Hazards Management How Responsible DistributionSM Addresses Reactive Hazards Management

RDP & Reactive Hazards Management What was Approved New requirement added to two (2) existing RDP elements of the “Handling & Storage” Section of the Code of Management Practice.

RDP & Reactive Hazards Management IV. Handling & Storage (new language in bold) C. Procedures for loading and unloading chemicals at member company’s facilities that result in protection of personnel, a reduction in emissions to the environment, and an increased awareness of hazards from inadvertent mixing of incompatible chemicals. D. A process for providing manufacturer guidance and information to customers, warehouses, terminals, and carriers on procedures for loading, unloading, and storing chemicals; and a process to increase awareness of hazards from inadvertent mixing of incompatible chemicals.

RDP & Reactive Hazards Management Why “Handling & Storage”? Because the CSB referenced this portion of Responsible DistributionSM as an area of emphasis. Because it is the most relevant RDP component in which reactive hazards can be managed.

RDP & Reactive Hazards Management Key to compliance: INCREASED COMMUNICATION with DISTRIBUTION EMPLOYEES, CUSTOMERS, WAREHOUSES, & CARRIERS about HAZARDS from INADVERTENT MIXING OF INCOMPATIBLE CHEMICALS

RDP & Reactive Hazards Management Compliance Factors Method will vary from distributor to distributor, product to product, facility to facility, hazard to hazard. Special attention to manufacturer MSDSs.

RDP & Reactive Hazards Management First steps to consider Review MSDSs received from suppliers. Check for any references to product incompatibility. Check for any references to hazards from inadvertent mixing. Consider how the references may be relevant, if not already stated specifically, to storage and handling.

RDP & Reactive Hazards Management First steps to consider (cont’d) Review existing company policies and procedures regarding Handling & Storage of chemicals. Consult employees who may have knowledge & experience with handling & storage potentially reactive chemicals stored & transported by NACD members. Decide how distribution policies and procedures will need to be updated to include new requirements.

RDP & Reactive Hazards Management Compliance Date: January 1, 2005. Third-Party Verifications to verify compliance include these two new requirements after this date.

RDP & Reactive Hazards Management Compliance Tools: NACD guidance: “Reactive Hazards Management Guidance for NACD Members to Address Requirements under the Responsible Distribution Process”. NACD’s alliance with OSHA & other industry trade associations to develop guidance & training.

Industry – OSHA Alliance Signed March 30, 2003 Partnership between industry & OSHA NACD, ACC, SOCMA, CI, CCPS, MKOC, EPA Committed to increasing awareness of reactive hazards among our memberships: distributors, manufacturers, employees, third-parties Help forge innovative solutions in the workplace

RDP & Reactive Hazards Management Recommendations Carriers: Check to see if suppliers and/or distributors are providing you with reactivity hazard information about the chemicals you are transporting. Distributors: if you are not a member of NACD, seriously consider how or if you address the potential for reactions in storage and handling. Other Industry Organizations: Consider making reactive hazards management requirements mandatory for companies adhering to your management systems. Chemical Week: Continue to cover issues involving reactive hazards management, including best practices being employed by industry.