Open: 100% | Closed: 0%
Final Report Released On: May 27, 2026
2024-06-I-KY-1
Contract a third party to analyze the reactivity of the sugar ingredients in the caramel coloring product manufacturing process by, at a minimum:
a. Conducting calorimetry testing on at least one representative recipe for all caramel coloring product types to determine their temperature and pressure behavior upon heating.
b. Testing the composition of any produced non-condensable gases.
Maintain this information for use during future equipment design efforts and hazard analyses.
Status:
Open - Awaiting Response or Evaluation/Approval of Response
Open - Awaiting Response or Evaluation/Approval of Response (O - ARE/AR) - The recipient has not submitted a substantive response, or the evaluation by CSB staff of a response is pending, or the Board has not yet acted on staff recommendation of status.
Recommendation Status Change Summary
2024-06-I-KY-2
Contract a third party to conduct a hazard analysis of each caramel coloring facility. Require this analysis to address reactivity hazards and include a review of the reactivity data obtained from implementing CSB Recommendation 2024-06-I-KY-R1. Implement the recommendations issued by the third party as a result of the hazard analyses.
Status:
Open - Awaiting Response or Evaluation/Approval of Response
Open - Awaiting Response or Evaluation/Approval of Response (O - ARE/AR) - The recipient has not submitted a substantive response, or the evaluation by CSB staff of a response is pending, or the Board has not yet acted on staff recommendation of status.
Recommendation Status Change Summary
2024-06-I-KY-3
Contract a third party to develop a process safety management system to be used at each caramel coloring facility. This third party shall:
a. Ensure the process safety management system is in alignment with current industry guidance such as the CCPS’s Guidelines for Risk Based Process Safety.
b. Ensure that the process safety management system requires hazard reviews/analyses to be conducted at prescribed intervals and include:
(1) the review/incorporation of reactivity data from CSB Recommendation 2024-06-I-KY-R1 and any additional reactivity data obtained during the course of operating any caramel coloring facility,
(2) the review/analysis of any process changes that could affect relief system designs, and
(3) the review/updating of the facility siting study from CSB Recommendation 2024-06-I-KY-R7, as appropriate.
Status:
Open - Awaiting Response or Evaluation/Approval of Response
Open - Awaiting Response or Evaluation/Approval of Response (O - ARE/AR) - The recipient has not submitted a substantive response, or the evaluation by CSB staff of a response is pending, or the Board has not yet acted on staff recommendation of status.
Recommendation Status Change Summary
2024-06-I-KY-4
At each caramel coloring facility, hire a new or identify a current employee who is competent in process safety management concepts. Establish this employee’s job duties to specifically include overseeing the caramel coloring facility’s process safety management system established in 2024-06-I-KY-R3, its implementation, and personnel training on the system’s elements.
Status:
Open - Awaiting Response or Evaluation/Approval of Response
Open - Awaiting Response or Evaluation/Approval of Response (O - ARE/AR) - The recipient has not submitted a substantive response, or the evaluation by CSB staff of a response is pending, or the Board has not yet acted on staff recommendation of status.
Recommendation Status Change Summary
2024-06-I-KY-5
For each caramel coloring facility, contract a third party to design adequate emergency pressure relief systems for the vessels involved in caramel coloring manufacturing. Ensure the third party reviews/incorporates all reactivity data obtained from the testing required by CSB Recommendation 2024-06-I-KY-R1 when designing the emergency pressure relief systems. Document and maintain each vessel’s relief system design basis for the service life of the vessel.
Status:
Open - Awaiting Response or Evaluation/Approval of Response
Open - Awaiting Response or Evaluation/Approval of Response (O - ARE/AR) - The recipient has not submitted a substantive response, or the evaluation by CSB staff of a response is pending, or the Board has not yet acted on staff recommendation of status.
Recommendation Status Change Summary
2024-06-I-KY-6
For each caramel coloring facility, establish automatic alerts, such as alarms or control screen indications, to notify operators when a safe operating limit has been reached. Follow industry guidance, such as the guidance presented in the Center for Chemical Process Safety Book Guidelines for Engineering Design for Process Safety (2nd Edition), Chapter 5 General Design. Provide initial and refresher training for operations personnel on the established safe operating limits including the actions to take if these limits are exceeded.
Status:
Open - Awaiting Response or Evaluation/Approval of Response
Open - Awaiting Response or Evaluation/Approval of Response (O - ARE/AR) - The recipient has not submitted a substantive response, or the evaluation by CSB staff of a response is pending, or the Board has not yet acted on staff recommendation of status.
Recommendation Status Change Summary
2024-06-I-KY-7
Contract a third party to conduct a facility siting study before constructing caramel coloring facility(ies) to help protect facility occupants and critical equipment from hazards created by explosion, fire, or toxic material release, using published industry guidance, such as that in the Center for Chemical Process Safety book, Guidelines for Siting and Layout of Facilities.
Status:
Open - Awaiting Response or Evaluation/Approval of Response
Open - Awaiting Response or Evaluation/Approval of Response (O - ARE/AR) - The recipient has not submitted a substantive response, or the evaluation by CSB staff of a response is pending, or the Board has not yet acted on staff recommendation of status.
Recommendation Status Change Summary