The CSB issues safety recommendations to prevent the recurrence or reduce the likelihood or consequences of similar incidents or hazards in the future. Recommendations are issued to a variety of parties, including government entities, safety organizations, trade unions, trade associations, corporations, emergency response organizations, educational institutions, and public interest groups. Recommendations are published in CSB reports and are closed only by vote of the Board. The CSB tracks all recommendations and communicates regularly with recommendations recipients to ensure that the recommended corrective actions are implemented. For more information, see Frequently Asked Questions about CSB recommendations.
2003-11-I-KY-7
Communicate to the owners of pressure vessels, mechanical contractors, engineering consulting companies, and insurance companies doing business in Kentucky that used pressure vessels are not exempt from registration and initial inspection before being placed in service in Kentucky. Status: Closed - Acceptable Action
Communicate to the owners of pressure vessels, mechanical contractors, engineering consulting companies, and insurance companies doing business in Kentucky that used pressure vessels are not exempt from registration and initial inspection before being placed in service in Kentucky.
2003-11-I-KY-1
Institute procedures to ensure that pressure vessels are designed, fabricated, and operated according to applicable codes and standards. Status: Closed - Acceptable Action
Institute procedures to ensure that pressure vessels are designed, fabricated, and operated according to applicable codes and standards.
2003-11-I-KY-2
Audit all vessels at all D. D. Williamson facilities and ensure that they are: Equipped with adequate overpressure protection, as warranted. Equipped with alarms or interlocks, as warranted. Status: Closed - Acceptable Action
Audit all vessels at all D. D. Williamson facilities and ensure that they are: Equipped with adequate overpressure protection, as warranted. Equipped with alarms or interlocks, as warranted.
2003-11-I-KY-3
Implement a program to review existing equipment when it is used for new purposes and when safety devices are removed or altered. Status: Closed - Acceptable Action
Implement a program to review existing equipment when it is used for new purposes and when safety devices are removed or altered.
2003-11-I-KY-4
Implement a hazard evaluation procedure to determine the potential for catastrophic incidents and necessary safeguards. Status: Closed - Acceptable Action
Implement a hazard evaluation procedure to determine the potential for catastrophic incidents and necessary safeguards.
2003-11-I-KY-5
Audit manual control of process conditions, such as temperature and pressure, and determine if safeguards are needed. Status: Closed - Acceptable Action
Audit manual control of process conditions, such as temperature and pressure, and determine if safeguards are needed.
2003-11-I-KY-6
Upgrade written operating procedures and train operators on the revised procedures. Status: Closed - Acceptable Action
Upgrade written operating procedures and train operators on the revised procedures.
2003-11-I-KY-8
Communicate to your members that used pressure vessels are not exempt from registration and initial inspection before being placed in service in Kentucky. Status: Closed - Acceptable Action
Communicate to your members that used pressure vessels are not exempt from registration and initial inspection before being placed in service in Kentucky.
2003-11-I-KY-10
Communicate the findings of this report to your membership. Status: Closed - Acceptable Action
Communicate the findings of this report to your membership.
2003-11-I-KY-9
2011-06-I-HI-12
Effectively participate in the National Fire Protection Association’s standard development process to develop guidance on the safe disposal of fireworks, as recommended under recommendation 2011-06-I-HI-R7. Status: Closed - Unacceptable Action/No Response Received
Effectively participate in the National Fire Protection Association’s standard development process to develop guidance on the safe disposal of fireworks, as recommended under recommendation 2011-06-I-HI-R7.
2011-06-I-HI-2
Establish formal policy requiring that: • Solicitations for contracts dealing with the storage, handling, and disposal of explosive hazardous materials, including fireworks, incorporate rigorous safety-related contractor selection provisions such as those provided in the DoD’s Contractor’s Safety Manual for Ammunition and Explosives, Section C1.5, “Pre-Award Safety Survey”; and • Contracts dealing with the storage, handling, and disposal of explosive hazardous materials, including fireworks, include a provision requiring that any subcontract (regardless of tier) for the storage, handling, and disposal of explosives (including fireworks) be selected based on rigorous safety-related contractor selection provisions such as those provided in the DOD's Contractor Safety Manual for Ammunition and Explosives, Section C1.5, "Pre-Award Safety Survey." Status: Closed - Acceptable Action
Establish formal policy requiring that: • Solicitations for contracts dealing with the storage, handling, and disposal of explosive hazardous materials, including fireworks, incorporate rigorous safety-related contractor selection provisions such as those provided in the DoD’s Contractor’s Safety Manual for Ammunition and Explosives, Section C1.5, “Pre-Award Safety Survey”; and • Contracts dealing with the storage, handling, and disposal of explosive hazardous materials, including fireworks, include a provision requiring that any subcontract (regardless of tier) for the storage, handling, and disposal of explosives (including fireworks) be selected based on rigorous safety-related contractor selection provisions such as those provided in the DOD's Contractor Safety Manual for Ammunition and Explosives, Section C1.5, "Pre-Award Safety Survey."
2011-06-I-HI-3
Establish a formal policy requiring that contracts and subcontracts dealing with the storage, handling, and disposal of explosive hazardous materials, including fireworks, incorporate rigorous safety-related contractor oversight provisions such as those provided in the DoD’s Contractor’s Safety Manual for Ammunition and Explosives, Section C1.6, “Pre-Operational Safety Survey” and C1.7, “Post-Award Contractor Responsibilities” to provide effective oversight of subcontractors handling and disposing of explosives and hazardous materials. Status: Closed - Acceptable Action
Establish a formal policy requiring that contracts and subcontracts dealing with the storage, handling, and disposal of explosive hazardous materials, including fireworks, incorporate rigorous safety-related contractor oversight provisions such as those provided in the DoD’s Contractor’s Safety Manual for Ammunition and Explosives, Section C1.6, “Pre-Operational Safety Survey” and C1.7, “Post-Award Contractor Responsibilities” to provide effective oversight of subcontractors handling and disposing of explosives and hazardous materials.
2011-06-I-HI-4
When the NFPA guidance developed by the National Fire Protection Association for the safe disposal of fireworks as recommended under recommendation 2011-06-I-HI-R7 is completed, incorporate this document by reference into the formal policies established by 2011-06-I-HI-R2 and 2011-06-I-HI-R3. Status: Open - Acceptable Response or Alternate Response
When the NFPA guidance developed by the National Fire Protection Association for the safe disposal of fireworks as recommended under recommendation 2011-06-I-HI-R7 is completed, incorporate this document by reference into the formal policies established by 2011-06-I-HI-R2 and 2011-06-I-HI-R3.
2011-06-I-HI-9
Revise the Resource Conservation and Recovery Act (RCRA) Subtitle C regulations to require a permitting process with rigorous safety reviews to replace the use of emergency permits under 40 CFR §270.61 for the disposal of explosive hazardous materials, including fireworks. At a minimum, the new process should require the use of best available technology, safe disposal methodologies, as well as safety management practices, such as those required by OSHA’s Process Safety Management Standard (PSM), 29 CFR §1910.119 (e.g., hazard analysis and control, management of change). Status: Closed - Unacceptable Action/No Response Received
Revise the Resource Conservation and Recovery Act (RCRA) Subtitle C regulations to require a permitting process with rigorous safety reviews to replace the use of emergency permits under 40 CFR §270.61 for the disposal of explosive hazardous materials, including fireworks. At a minimum, the new process should require the use of best available technology, safe disposal methodologies, as well as safety management practices, such as those required by OSHA’s Process Safety Management Standard (PSM), 29 CFR §1910.119 (e.g., hazard analysis and control, management of change).
2011-06-I-HI-10
Until recommendation 2011-06-I-HI-R9 can be implemented, develop and issue a policy guidance document to provide a regulatory process with rigorous safety reviews to replace the use of emergency permits under 40 CFR §270.61 for the disposal of explosive hazardous materials, including fireworks. At a minimum, the new process should require the use of best available technology, safe disposal methodologies, as well as safety management practices, such as those required by OSHA’s Process Safety Management Standard (PSM), 29 CFR §1910.119 (e.g., hazard analysis and control, management of change). Ensure its effective communication to all EPA regional administrators, state environmental agencies, and organizations within the fireworks industry Status: Closed - No Longer Applicable
Until recommendation 2011-06-I-HI-R9 can be implemented, develop and issue a policy guidance document to provide a regulatory process with rigorous safety reviews to replace the use of emergency permits under 40 CFR §270.61 for the disposal of explosive hazardous materials, including fireworks. At a minimum, the new process should require the use of best available technology, safe disposal methodologies, as well as safety management practices, such as those required by OSHA’s Process Safety Management Standard (PSM), 29 CFR §1910.119 (e.g., hazard analysis and control, management of change). Ensure its effective communication to all EPA regional administrators, state environmental agencies, and organizations within the fireworks industry
2011-06-I-HI-11
Effectively participate in the National Fire Protection Association’s standard development process to develop guidance on the safe and environmentally sound disposal of fireworks, as recommended under recommendation 2011-06-I-HI-R7. Status Status: Closed - Acceptable Action
Effectively participate in the National Fire Protection Association’s standard development process to develop guidance on the safe and environmentally sound disposal of fireworks, as recommended under recommendation 2011-06-I-HI-R7. Status
2011-06-I-HI-1
Establish an additional contractor responsibility determination requirement under Subpart 9.104-1 of the Federal Acquisition Regulation (FAR) addressing contractor safety performance. The analysis under this requirement should focus on incident prevention, and environmental and system safety. At a minimum, the language should specifically require the review of a prospective contractor’s: • Environmental and safety programs; • Safety record and incident history; • Ability to use safe methods for any work involving hazardous materials (including explosives); and • Suitable training and qualifications for the personnel involved in the work including prior relevant safety experience. Status: Closed - Unacceptable Action/No Response Received
Establish an additional contractor responsibility determination requirement under Subpart 9.104-1 of the Federal Acquisition Regulation (FAR) addressing contractor safety performance. The analysis under this requirement should focus on incident prevention, and environmental and system safety. At a minimum, the language should specifically require the review of a prospective contractor’s: • Environmental and safety programs; • Safety record and incident history; • Ability to use safe methods for any work involving hazardous materials (including explosives); and • Suitable training and qualifications for the personnel involved in the work including prior relevant safety experience.
2011-06-I-HI-7
Develop a new standard, or incorporate within an existing standard, best practices for the safe disposal of waste fireworks that are consistent with environmental requirements. At a minimum this guidance or standard should: • Discourage the disassembly of waste fireworks as a step in the disposal process; • Minimize the accumulation of waste explosive materials, and encourage practices that reduce, recycle, reuse,or repurpose fireworks; and • Incorporate input from ATF, EPA, and other agencies, experts, and available resources on fireworks disposal methodologies. Status: Open - Acceptable Response or Alternate Response
Develop a new standard, or incorporate within an existing standard, best practices for the safe disposal of waste fireworks that are consistent with environmental requirements. At a minimum this guidance or standard should: • Discourage the disassembly of waste fireworks as a step in the disposal process; • Minimize the accumulation of waste explosive materials, and encourage practices that reduce, recycle, reuse,or repurpose fireworks; and • Incorporate input from ATF, EPA, and other agencies, experts, and available resources on fireworks disposal methodologies.
2011-06-I-HI-8
Once fireworks disposal best practices under recommendation 2011-06-I-HI-R7 is completed, develop and implement an outreach plan to promptly communicate the new NFPA practices to relevant government agencies and private entities that dispose of waste fireworks Status: Open - Awaiting Response or Evaluation/Approval of Response
Once fireworks disposal best practices under recommendation 2011-06-I-HI-R7 is completed, develop and implement an outreach plan to promptly communicate the new NFPA practices to relevant government agencies and private entities that dispose of waste fireworks
2011-06-I-HI-5
Require additional provisions within the TEOAF seized property management contract, such as a contract line item number (CLIN), that provide for the prime contractor to use expert(s) to assist the prime contractor’s personnel in the selection and oversight of subcontractors who handle, store, or dispose of explosive hazardous materials, including fireworks, pursuant to the main contract. Status: Closed - Acceptable Action
Require additional provisions within the TEOAF seized property management contract, such as a contract line item number (CLIN), that provide for the prime contractor to use expert(s) to assist the prime contractor’s personnel in the selection and oversight of subcontractors who handle, store, or dispose of explosive hazardous materials, including fireworks, pursuant to the main contract.
2011-06-I-HI-6
Use experts to: • Assist VSE procurement in selecting vendors to properly handle, store, and dispose of explosive hazardous materials, including fireworks, pursuant to prime contract requirements; and, • Assist VSE personnel in overseeing the work to ensure it is being conducted safely. Status: Status: Closed - Acceptable Action
Use experts to: • Assist VSE procurement in selecting vendors to properly handle, store, and dispose of explosive hazardous materials, including fireworks, pursuant to prime contract requirements; and, • Assist VSE personnel in overseeing the work to ensure it is being conducted safely. Status:
2002-04-I-MO-17
Work with State and local agencies to address concerns about the long-term health effects of the chlorine release in Festus, Missouri, and communicate your findings to the community. Status: Closed - No Longer Applicable
Work with State and local agencies to address concerns about the long-term health effects of the chlorine release in Festus, Missouri, and communicate your findings to the community.
2002-04-I-MO-11
Implement a materials verification procedure to improve quality assurance during chlorine transfer hose fabrication and shipment, such that hoses shipped to customers are readily identifiable and meet required specifications. Status: Closed - Acceptable Action
Implement a materials verification procedure to improve quality assurance during chlorine transfer hose fabrication and shipment, such that hoses shipped to customers are readily identifiable and meet required specifications.
2002-04-I-MO-18
Work with the Association of Hose and Accessories Distributors (NAHAD) and chlorine hose manufacturers, such as Crane-Resistoflex, to develop and implement a recommended practice requiring continuous positive identification (e.g., coding, stenciling, stamping) throughout the supply chain, from manufacturing to the end user of the product. Status: Closed - Acceptable Action
Work with the Association of Hose and Accessories Distributors (NAHAD) and chlorine hose manufacturers, such as Crane-Resistoflex, to develop and implement a recommended practice requiring continuous positive identification (e.g., coding, stenciling, stamping) throughout the supply chain, from manufacturing to the end user of the product.
2002-04-I-MO-19
Develop recommended practices to address moisture in dry chlorine piping systems. Include information on suggested material specifications, prevention and corrective measures, and adverse consequences (particularly for emergency shutdown [ESD] systems). Status: Closed - Acceptable Action
Develop recommended practices to address moisture in dry chlorine piping systems. Include information on suggested material specifications, prevention and corrective measures, and adverse consequences (particularly for emergency shutdown [ESD] systems).
2002-04-I-MO-20
Develop recommended practices for testing, inspection, and preventative maintenance of ESD systems for bulk transfer of chlorine. Status: Closed - Acceptable Action
Develop recommended practices for testing, inspection, and preventative maintenance of ESD systems for bulk transfer of chlorine.
2002-04-I-MO-21
Communicate the findings and recommendations of this report to your membership. Status: Closed - Acceptable Action
Communicate the findings and recommendations of this report to your membership.
2002-04-I-MO-1
Revise the mechanical integrity program: Develop and implement a quality assurance management system, such as positive materials identification, to confirm that chlorine transfer hoses (CTH) are of the appropriate materials of construction. Status: Closed - Acceptable Action
Revise the mechanical integrity program: Develop and implement a quality assurance management system, such as positive materials identification, to confirm that chlorine transfer hoses (CTH) are of the appropriate materials of construction.
2002-04-I-MO-2
Revise the mechanical integrity program: Implement procedures and practices to ensure the emergency shutdown (ESD) system operates properly. Include procedures to verify that the ESD valves will close to shut down the flow of chlorine. Status: Closed - Acceptable Action
Revise the mechanical integrity program: Implement procedures and practices to ensure the emergency shutdown (ESD) system operates properly. Include procedures to verify that the ESD valves will close to shut down the flow of chlorine.
2002-04-I-MO-3
Revise the mechanical integrity program: Revise the preventive maintenance and inspection program for the chlorine transfer system to address moisture-related corrosion. Evaluate and correct any problems associated with corrosion that could potentially lead to chlorine transfer and safety system failure. Status: Closed - Acceptable Action
Revise the mechanical integrity program: Revise the preventive maintenance and inspection program for the chlorine transfer system to address moisture-related corrosion. Evaluate and correct any problems associated with corrosion that could potentially lead to chlorine transfer and safety system failure.
2004-04-I-MO-4
Revise the mechanical integrity program: Require periodic inspection of the above critical safety systems by the operations or facility manager. Status: Closed - Acceptable Action
Revise the mechanical integrity program: Require periodic inspection of the above critical safety systems by the operations or facility manager.
2002-04-I-MO-5
Revise the Emergency Response Plan: Develop procedures to clearly designate the roles and responsibilities of facility emergency response personnel, including post-incident remediation. Status: Closed - Acceptable Action
Revise the Emergency Response Plan: Develop procedures to clearly designate the roles and responsibilities of facility emergency response personnel, including post-incident remediation.
2002-04-I-MO-6
Revise the Emergency Response Plan: Develop and implement a timetable for drills to test emergency response personnel on various levels of response, including a large uncontrolled release that could affect the public. Coordinate these drills with local emergency response authorities. Provide a copy of the revised Emergency Response Plan to the local emergency planning committee, and review the plan with the committee and the local fire department. Work with these authorities to implement an improved community emergency notification system. Status: Closed - Acceptable Action
Revise the Emergency Response Plan: Develop and implement a timetable for drills to test emergency response personnel on various levels of response, including a large uncontrolled release that could affect the public. Coordinate these drills with local emergency response authorities. Provide a copy of the revised Emergency Response Plan to the local emergency planning committee, and review the plan with the committee and the local fire department. Work with these authorities to implement an improved community emergency notification system.
2002-04-I-MO-7
Revise the Emergency Response Plan: Improve accessibility of equipment required for emergency response, considering likely response scenarios. Status: Closed - Acceptable Action
Revise the Emergency Response Plan: Improve accessibility of equipment required for emergency response, considering likely response scenarios.
2002-04-I-MO-8
In light of the findings of this report, conduct periodic audits of the safety management systems involved in this incident, such as mechanical integrity, emergency response, and material quality assurance. Ensure that the audit recommendations are tracked and implemented. Share findings and recommendations with the work force at your repackaging facilities. Status: Closed - Acceptable Action
In light of the findings of this report, conduct periodic audits of the safety management systems involved in this incident, such as mechanical integrity, emergency response, and material quality assurance. Ensure that the audit recommendations are tracked and implemented. Share findings and recommendations with the work force at your repackaging facilities.
2002-04-I-MO-9
To improve supervision of day-to-day operations, revise your corporate safety management training program on chlorine repackaging operations. Emphasize safety critical systems, including verification of safety system performance. Status: Closed - Acceptable Action
To improve supervision of day-to-day operations, revise your corporate safety management training program on chlorine repackaging operations. Emphasize safety critical systems, including verification of safety system performance.
2002-04-I-MO-10
Communicate the findings and recommendations of this report to all DPC facilities. Status: Closed - Acceptable Action
Communicate the findings and recommendations of this report to all DPC facilities.
2002-04-I-MO-12
Work with DPC to implement a community notification system that will immediately alert neighboring residents and businesses of a chemical release. Status: Closed - Acceptable Action
Work with DPC to implement a community notification system that will immediately alert neighboring residents and businesses of a chemical release.
2002-04-I-MO-13
Work with DPC, local emergency planning and response authorities in Jefferson and adjacent counties, the City of Festus, and Crystal City to improve overall response and mitigation time. Status: Closed - Acceptable Action
Work with DPC, local emergency planning and response authorities in Jefferson and adjacent counties, the City of Festus, and Crystal City to improve overall response and mitigation time.
2002-04-I-MO-14
2002-04-I-MO-16
In collaboration with appropriate agencies, hold a community meeting in Festus, Missouri, to hear concerns raised by local citizens affected by the DPC incident and to respond to issues raised by the community. Status: Closed - No Longer Applicable
In collaboration with appropriate agencies, hold a community meeting in Festus, Missouri, to hear concerns raised by local citizens affected by the DPC incident and to respond to issues raised by the community.
2009-04-I-MO-15
Communicate the findings and recommendations of this report to local emergency planning committees (LEPC), emergency management agencies (EMA), and local fire departments. Status: Closed - Acceptable Action
Communicate the findings and recommendations of this report to local emergency planning committees (LEPC), emergency management agencies (EMA), and local fire departments.
2009-04-I-MO-24
2002-04-I-MO-22
Work with The Chlorine Institute and chlorine hose manufacturers, such as Crane-Resistoflex, to develop and implement a recommended practice requiring continuous positive identification (e.g.,coding, stenciling, stamping) throughout the supply chain, from manufacturing to the end user of the product. Status: Closed - Acceptable Action
Work with The Chlorine Institute and chlorine hose manufacturers, such as Crane-Resistoflex, to develop and implement a recommended practice requiring continuous positive identification (e.g.,coding, stenciling, stamping) throughout the supply chain, from manufacturing to the end user of the product.
2009-04-I-MO-23
2004-2-I-AZ-14
Clarify the chemistry involved in over-chlorination incidents so that "Chlorine Scrubbing Systems, Pamphlet 89," and other pertinent publications: -Ensure that the recommended practices and safeguards prevent, mitigate, and control hazardous releases due to bleach decomposition. -Provide sufficient detail on the safety and environmental consequences of over-chlorination to enable companies to provide emergency responders with information on the potential characteristics of over-chlorination events, and on the best means of mitigating the bleach decomposition reaction following a release. Status: Closed - Acceptable Action
Clarify the chemistry involved in over-chlorination incidents so that "Chlorine Scrubbing Systems, Pamphlet 89," and other pertinent publications: -Ensure that the recommended practices and safeguards prevent, mitigate, and control hazardous releases due to bleach decomposition. -Provide sufficient detail on the safety and environmental consequences of over-chlorination to enable companies to provide emergency responders with information on the potential characteristics of over-chlorination events, and on the best means of mitigating the bleach decomposition reaction following a release.
2004-2-I-AZ-1
Establish and implement DPC corporate engineering standards that include adequate layers of protection on chlorine scrubbers at DPC facilities, including: -additional interlocks and shutdowns, such as automatically stopping chlorine flow to the scrubber upon oxidation-reduction potential alarm; -mitigation measures, such as systems to automatically add caustic to over-chlorinated scrubbers, or back-up scrubbing capability to treat emissions from over-chlorinated scrubbers; -increases in the final caustic concentration in the scrubbers to eight percent or higher to provide a substantial safety margin against over-chlorination; and -use of the site's continuous bleach manufacturing system to convert scrubber solution to saleable bleach. Status: Closed - Acceptable Action
Establish and implement DPC corporate engineering standards that include adequate layers of protection on chlorine scrubbers at DPC facilities, including: -additional interlocks and shutdowns, such as automatically stopping chlorine flow to the scrubber upon oxidation-reduction potential alarm; -mitigation measures, such as systems to automatically add caustic to over-chlorinated scrubbers, or back-up scrubbing capability to treat emissions from over-chlorinated scrubbers; -increases in the final caustic concentration in the scrubbers to eight percent or higher to provide a substantial safety margin against over-chlorination; and -use of the site's continuous bleach manufacturing system to convert scrubber solution to saleable bleach.
2004-2-I-AZ-2
Revise scrubber SOPs to include: -clearly described operating limits and warnings about the consequences of exceeding those limits, and -the safety and environmental hazards associated with scrubber over-chlorination. Status: Closed - Acceptable Action
Revise scrubber SOPs to include: -clearly described operating limits and warnings about the consequences of exceeding those limits, and -the safety and environmental hazards associated with scrubber over-chlorination.
2004-2-I-AZ-3
Train employees on the revised SOPs and include a test to verify understanding. Periodically review operator understanding of and conformance to the scrubber SOPs. Status: Closed - Acceptable Action
Train employees on the revised SOPs and include a test to verify understanding. Periodically review operator understanding of and conformance to the scrubber SOPs.
2004-2-I-AZ-4
Include scrubber operation in facility PHAs. Ensure that they: -include lessons learned from this incident and other DPC scrubber incidents, as well as industry experience with over-chlorination, and -consider off-site consequences when evaluating the adequacy of existing safeguards. Status: Closed - Acceptable Action
Include scrubber operation in facility PHAs. Ensure that they: -include lessons learned from this incident and other DPC scrubber incidents, as well as industry experience with over-chlorination, and -consider off-site consequences when evaluating the adequacy of existing safeguards.
2004-2-I-AZ-5
Use a qualified, independent auditor to evaluate DPC's PSM and RMP programs against best practices. Implement audit recommendations in a timely manner at all DPC chlorine repackaging sites. Status: Closed - Acceptable Action
Use a qualified, independent auditor to evaluate DPC's PSM and RMP programs against best practices. Implement audit recommendations in a timely manner at all DPC chlorine repackaging sites.
2004-2-I-AZ-6
Implement a recognized safety management system, including third party verification and certification, to achieve documented continuous improvement in safety performance at Glendale and the other DPC chlorine repackaging sites. Status: Closed - Acceptable Action
Implement a recognized safety management system, including third party verification and certification, to achieve documented continuous improvement in safety performance at Glendale and the other DPC chlorine repackaging sites.
2004-2-I-AZ-7
Work with the Glendale Police Department to integrate them into the incident command structure during hazardous material incidents, and address communications issues, such as radio interoperability, to ensure the timely transmission of critical safety information to responding officers. Status: Closed - Acceptable Action
Work with the Glendale Police Department to integrate them into the incident command structure during hazardous material incidents, and address communications issues, such as radio interoperability, to ensure the timely transmission of critical safety information to responding officers.
2004-2-I-AZ-8
Conduct hazardous materials exercises with the Glendale Police Department to identify and resolve police/fire integration issues. Coordinate exercise planning with the Arizona Division of Emergency Management Exercise Officer and with the Maricopa County LEPC. Schedule periodic hazardous materials incident drills to ensure safe and effective responses to future hazardous materials incidents. Status: Closed - Acceptable Action
Conduct hazardous materials exercises with the Glendale Police Department to identify and resolve police/fire integration issues. Coordinate exercise planning with the Arizona Division of Emergency Management Exercise Officer and with the Maricopa County LEPC. Schedule periodic hazardous materials incident drills to ensure safe and effective responses to future hazardous materials incidents.
2004-2-I-AZ-9
Work with the Glendale Fire Department to integrate the Glendale Police Department into the command structure during hazardous material incidents, and address communications issues, such as radio interoperability, to ensure the timely transmission of critical safety information to responding officers. Status: Closed - Acceptable Action
Work with the Glendale Fire Department to integrate the Glendale Police Department into the command structure during hazardous material incidents, and address communications issues, such as radio interoperability, to ensure the timely transmission of critical safety information to responding officers.
2004-2-I-AZ-10
Ensure that police officers responding to hazardous material incidents are briefed on specific incident conditions, and are equipped with and trained on the proper use, capabilities, and limitations of appropriate protective equipment. Status: Closed - Acceptable Action
Ensure that police officers responding to hazardous material incidents are briefed on specific incident conditions, and are equipped with and trained on the proper use, capabilities, and limitations of appropriate protective equipment.
2004-2-I-AZ-11
Ensure that police officers receive hazardous materials - operations level training, and annual hazardous materials and air purifying respirator (APR) refresher training. Status: Closed - Acceptable Action
Ensure that police officers receive hazardous materials - operations level training, and annual hazardous materials and air purifying respirator (APR) refresher training.
2004-2-I-AZ-12
Conduct exercises with the Glendale Fire Department to identify and resolve police/fire integration issues. Coordinate exercise planning with the Arizona Division of Emergency Management Exercise Officer and with the Maricopa County LEPC. Schedule periodic hazardous materials incident drills to ensure safe and effective responses to future hazardous materials incidents. Status: Closed - Acceptable Action
Conduct exercises with the Glendale Fire Department to identify and resolve police/fire integration issues. Coordinate exercise planning with the Arizona Division of Emergency Management Exercise Officer and with the Maricopa County LEPC. Schedule periodic hazardous materials incident drills to ensure safe and effective responses to future hazardous materials incidents.
2004-2-I-AZ-13
Revise DPC's permitted operating conditions to specify a minimum scrubber caustic concentration of 8 percent or more, as determined by laboratory measurement, with measurements taken daily and upon completion of each scrubber batch. Status: Closed - Acceptable Action
Revise DPC's permitted operating conditions to specify a minimum scrubber caustic concentration of 8 percent or more, as determined by laboratory measurement, with measurements taken daily and upon completion of each scrubber batch.
2010-06-I-WV-11
Revise the Phosgene Safe Practice Guidelines Manual to Advise against the use of hoses for phosgene transfer that are constructed of permeable cores and materials subject to chlorides corrosion. Include guidance for the immediate reporting and prompt investigation of all potential (near-miss) phosgene releases. Status: Closed - Acceptable Action
Revise the Phosgene Safe Practice Guidelines Manual to
2010-06-I-WV-9
Revise CGA P-1, Safe Handling of Compressed Gases in Containers, to include specific requirements for storing and handling highly toxic compressed gas, including enclosure ventilation and alarm requirements at least as protective as Section 7.9, Toxic and Highly Toxic Gases and NFPA 55, Compressed Gases and Cryogenics Fluids Code. Status: Closed - Acceptable Action
Revise CGA P-1, Safe Handling of Compressed Gases in Containers, to include specific requirements for storing and handling highly toxic compressed gas, including enclosure ventilation and alarm requirements at least as protective as Section 7.9, Toxic and Highly Toxic Gases and NFPA 55, Compressed Gases and Cryogenics Fluids Code.
2010-06-I-WV-10
Revise CGA P-1, Safe Handling of Compressed Gases in Containers, to incorporate by reference CGA E-9, Standard for Flexible, PTFE-lined Pigtails for Compressed Gas Service. Status: Closed - Acceptable Action
Revise CGA P-1, Safe Handling of Compressed Gases in Containers, to incorporate by reference CGA E-9, Standard for Flexible, PTFE-lined Pigtails for Compressed Gas Service.
2010-06-I-WV-3
Improve the existing maintenance management by Supplementing the computerized system with sufficient redundancy to ensure tracking and timely scheduling of preventive maintenance for all PSM-critical equipment. Conducting Management-of-Change (MOC) reviews for all changes to preventive maintenance orders for all PSM-critical equipment in the computerized maintenance management system. Status: Closed - Acceptable Action
Improve the existing maintenance management by
2010-06-I-WV-4
Revise the facility emergency response protocol to require that a responsible and accountable DuPont employee always be available (all shifts, all days) to provide timely and accurate information to the Kanawha County Emergency Ambulance Authority (KCEAA) and Metro 9-1-1 dispatchers. Status: Closed - Acceptable Action
Revise the facility emergency response protocol to require that a responsible and accountable DuPont employee always be available (all shifts, all days) to provide timely and accurate information to the Kanawha County Emergency Ambulance Authority (KCEAA) and Metro 9-1-1 dispatchers.
2010-06-I-WV-5
Revise the near-miss reporting and investigation policy and implement a program that includes the following at a minimum: Ensures employee participation in reporting, investigating, analyzing, and recommending corrective actions as appropriate for all near-misses and disruptions of normal operations. Develops and encourages use of an anonymous electronic and/or hard copy near-miss reporting process for all DuPont Belle site employees. Establishes roles and responsibilities for ownership, management, execution, and resolution of recommendations from incident or near-miss investigations at the DuPont Belle facility. Ensures that the near-miss investigation program requires prompt investigations, as appropriate, and that results are promptly circulated to well-suited recipients throughout the DuPont Corp. Ensures that this program is operational at all times (e.g. nights, weekends, and holiday shifts). Status: Closed - Acceptable Action
Revise the near-miss reporting and investigation policy and implement a program that includes the following at a minimum:
2010-06-I-WV-6
Revise safeguards for phosgene handling at all DuPont facilities by Requiring that all indoor phosgene production and storage areas, as defined in NFPA 55, have secondary enclosures, mechanical ventilation systems, emergency phosgene scrubbers, and automated audible alarms, which are, at a minimum, consistent with the standards of NFPA 55 for highly toxic gases. Prohibiting the use of hoses with permeable cores and materials susceptible to chlorides corrosion for phosgene transfer. Conducting annual phosgene hazard awareness training for all employees who handle phosgene, including the hazards associated with thermal expansion of entrapped liquid phosgene in piping and equipment. Status: Closed - Acceptable Action
Revise safeguards for phosgene handling at all DuPont facilities by
2010-06-I-WV-7
Review all DuPont units that produce and handle phosgene that, at a minimum, observe and document site-specific practices for engineering controls, construction materials, PPE, procedures, maintenance, emergency response, and release detection and alarms, and use information from external sources to develop and implement consistent company-wide policies for the safe production and handling of phosgene. Status: Closed - Acceptable Action
Review all DuPont units that produce and handle phosgene that, at a minimum, observe and document site-specific practices for engineering controls, construction materials, PPE, procedures, maintenance, emergency response, and release detection and alarms, and use information from external sources to develop and implement consistent company-wide policies for the safe production and handling of phosgene.
2010-06-I-WV-8
For each DuPont facility that uses, but does not manufacture, phosgene onsite: Conduct a risk assessment of manufacturing phosgene onsite against the current configuration. Communicate the findings of each assessment to compile recommendations applicable to all DuPont phosgene delivery systems. Implement these recommendations. Status: Closed - Acceptable Action
For each DuPont facility that uses, but does not manufacture, phosgene onsite:
2010-06-I-WV-12
Commission an audit in consultation with operations personnel to establish and identify the conditions that cause nuisance alarms at all DuPont facilities. Establish and implement a corporate alarm management program as part of the DuPont PSM Program, including measures to prevent nuisance alarms and other malfunctions in those systems. Include initial and refresher training as an integral part of this effort. Status: Closed - Acceptable Action
Commission an audit in consultation with operations personnel to establish and identify the conditions that cause nuisance alarms at all DuPont facilities. Establish and implement a corporate alarm management program as part of the DuPont PSM Program, including measures to prevent nuisance alarms and other malfunctions in those systems. Include initial and refresher training as an integral part of this effort.
2010-06-I-WV-13
Revise the DuPont PSM standard to require confirmation that all safety alarms/interlocks are in proper working order (e.g., not in an active alarm state) prior to the start-up of all Higher-Hazard Process facilities. Status: Closed - Acceptable Action
Revise the DuPont PSM standard to require confirmation that all safety alarms/interlocks are in proper working order (e.g., not in an active alarm state) prior to the start-up of all Higher-Hazard Process facilities.
2010-06-I-WV-14
Reevaluate and clarify the DuPont corporate MOC policies to ensure that staff can properly identify and use the distinctions between subtle and full changes and train appropriate personnel how to properly apply the distinctions on any changes in the policy. Status: Closed - Acceptable Action
Reevaluate and clarify the DuPont corporate MOC policies to ensure that staff can properly identify and use the distinctions between subtle and full changes and train appropriate personnel how to properly apply the distinctions on any changes in the policy.
2010-06-I-WV-1
Revise OSHA 29 CFR 1910.101, General Industry Standard for Compressed Gases, to require facilities that handle toxic and highly toxic materials in compressed gas cylinders to incorporate provisions that are at least as effective as the 2010 edition of Section 7.9, Toxic and Highly Toxic Gases, in National Fire Protection Association (NFPA) 55, Compressed Gases and Cryogenic Fluids Code, including enclosures, ventilation and treatment systems, interlocked fail-safe shutdown valves, gas detection and alarm systems, piping system components, and similarly relevant layers of protection. Status: Closed - Reconsidered/Superseded
Revise OSHA 29 CFR 1910.101, General Industry Standard for Compressed Gases, to require facilities that handle toxic and highly toxic materials in compressed gas cylinders to incorporate provisions that are at least as effective as the 2010 edition of Section 7.9, Toxic and Highly Toxic Gases, in National Fire Protection Association (NFPA) 55, Compressed Gases and Cryogenic Fluids Code, including enclosures, ventilation and treatment systems, interlocked fail-safe shutdown valves, gas detection and alarm systems, piping system components, and similarly relevant layers of protection.
2010-06-I-WV-2
Take sustained measures to minimize the exposure of hazards to workers handling highly toxic gases from cylinders and associated regulators, gages, hoses, and appliances. Ensure that OSHA managers, compliance officers, equivalent state OSHA plan personnel, and regulated parties conform, under the Process Safety Management Standard (29 CFR 1910.119) Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) provisions, to industry practices at least as effective as the following: NFPA 55 - Compressed Gases and Cryogenic Fluids Code (2010) CGA P-1 Safe Handling of Compressed Gases in Containers (2008) CGA E-9 Standard for Flexible, PTFE-lined Pigtails for Compressed Gas Service (2010) ASME B31.3 Process Piping (2008) Status: Open - Acceptable Response or Alternate Response
Take sustained measures to minimize the exposure of hazards to workers handling highly toxic gases from cylinders and associated regulators, gages, hoses, and appliances. Ensure that OSHA managers, compliance officers, equivalent state OSHA plan personnel, and regulated parties conform, under the Process Safety Management Standard (29 CFR 1910.119) Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) provisions, to industry practices at least as effective as the following: