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

2. 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

3. 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.

4. Why There Is an Increased Attention Given to
Reactive Chemical
Hazards

5. Recent Industry Accidents Morton International

6. 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

7. Recent Industry Accidents Concept Sciences

8. 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

9. Recent Industry Accidents Napp Technologies

10. 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

11. Recent Industry Accidents Bartlo Packaging

12. 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

13. 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.

14. 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.

15. 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).

16. Chemical Distribution Industry
Challenge to
Chemical Distribution Industry

17. 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.”

18. Responsible DistributionSM Addresses Reactive Hazards Management
How
Responsible DistributionSM Addresses
Reactive Hazards Management

19. 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.

20. 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.

21. 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.

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

23. 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.

24. 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.

25. 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.

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

27. 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.

28. 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

29. 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.