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Safety Recommendation Details

Safety Recommendation R-85-071
Details
Synopsis: AT 3:45 A.M., ON JULY 30, 1983, VINYL CHLORIDE MONOMER (VCM) UNDER PRESSURE ESCAPED FROM A RAILROAD TANK CAR AT THE LOADING FACILITY WITHIN THE FORMOSA PLASTICS CORPORATION (FORMOSA) CHEMICAL MANUFACTURING PLANT AT BATON ROUGE, LOUISIANA. THE RELEASED VCM WAS IGNITED BY AN UNDETERMINED SOURCE, AND A LARGE BILLOWING FIRE ENSUED. AN ADJACENT TANK CAR CONTAINING VCM WAS INVOLVED IN THE FIRE BUT DID NOT RUPTURE VIOLENTLY. TWO PERSONS WERE INJURED SERIOUSLY, TWO TANK CARS WERE DESTROYED, THREE TANK CARS WERE DAMAGED MODERATELY, AND THE LOADING FACILITY WAS DAMAGED EXTENSIVE LY. DAMAGE WAS ESTIMATED TO BE $1 MILLION.
Recommendation: THE NTSB RECOMMENDS THAT THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION: EVALUATE ITS ABILITY TO CONDUCT INSPECTIONS OF PETROCHEMICAL PLANT LOADING FACILITIES AND ITS METHOD OF ESTABLISHING INSPECTION PRIORITIES FOR GENERAL SCHEDULE INSPECTIONS, AND MAKE NECESSARY CHANGES TO PROVIDE FOR REGULAR INSPECTIONS.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Alternate Action
Mode: Railroad
Location: Baton Rouge, LA, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA83AZ006
Accident Reports: Vinyl Chloride Monomer Release from a Railroad Tank Car and Fire, Formosa Plastics Corporation Plant
Report #: RAR-85-08
Accident Date: 7/30/1983
Issue Date: 6/17/1985
Date Closed: 9/24/1986
Addressee(s) and Addressee Status: United States Department of Labor, Occupational Safety and Health Administration (Closed - Acceptable Alternate Action)
Keyword(s): Tank Car Loading and Unloading, Hazmat

Safety Recommendation History
From: NTSB
To: United States Department of Labor, Occupational Safety and Health Administration
Date: 9/24/1986
Response: The Safety Board notes and appreciates Occupational Safety and Health Administration's (OSHA) further comments regarding its inspection priorities and the actions OSHA has taken to increase its inspection presence at chemical plants. The Board hopes that the chemicals emphasis program will filter down to some of the petrochemical unloading facilities. The Board notes also that OSHA's inspection staff will be instructed to be aware of any potential violations of FRA regulations/ While we remain concerned about the nature of the products handled at these petrochemical facilities and the potential effect of these products on the surrounding area, the Board can appreciate the fact that OSHA has limited inspection resources and must focus these resources on workplaces and hazards known to result in employee harm. Consequently, in view of OSHA's efforts to institute a program for the chemicals industry and recognizing OSHA's limited resource capabilities, the Safety Board has reclassified Safety Recommendations R-85-71 and -72 as "Closed-Acceptable Alternate Action." We would appreciate being informed of the results of the experimental inspection program for the chemicals industry.

From: United States Department of Labor, Occupational Safety and Health Administration
To: NTSB
Date: 4/23/1986
Response: It is OSHA's belief that its recently instituted program for the chemicals industry will result in increased safety and health awareness among employers in this sector. Although the program does not single out the petrochemical industry for special attention, the experimental program will be conducted in areas of the country with the greatest concentration of petrochemical plants. Based on the outcome of this experimental program, OSHA may decide that an emphasis program for petrochemical loading would be advisable. At this time, however, we do not have sufficient evidence to warrant the exact program NTSB has recommended. To ensure that the FRA is apprised of the results of the inspections conducted at chemical plants, I will instruct OSHA's inspection staff to be aware of any potential violations of FRA regulations they may come across as part of OSHA's investigations at loading areas. I will also urge the Administrator of FRA to have that Agency's investigators inform OSHA of any potential OSHA violations they may find as part of their inspection activities. This is not a new policy, but a reaffirmation of OSHA's existing requirements that its field staff maintain close contact with other Federal agencies with which OSHA shares authority for occupational safety and health.

From: NTSB
To: United States Department of Labor, Occupational Safety and Health Administration
Date: 3/25/1986
Response: While the Safety Board appreciates having received more information on the special emphasis program, it appears, based on Occupational Safety and Health Administration's (OSHA) discussion of the purpose of this program in its current response and on OSHA's previous indication that it will make no change in its priorities for general schedule inspection, that the type and frequency of inspections envisioned by Safety Recommendation R-85-71 will not be implemented. Consequently, the Board has placed Safety Recommendation R-85-71 in a "Closed-Unacceptable Action" status. Since the Board firmly believes that more frequent and regular inspections of petrochemical facilities are needed, we will continue to address this important safety issue in future pertinent accident investigations.

From: United States Department of Labor, Occupational Safety and Health Administration
To: NTSB
Date: 2/5/1986
Response: OSHA LTR: OSHA RESPONDED THAT WE DO NOT PLAN ANY MAJOR CHANGE IN OUR PRIORITIES FOR GENERAL SCHEDULE INSPECTIONS. PETROCHEMICAL PLANTS WILL BE INCLUDED, HOWEVER, IN OSHA'S SPECIAL EMPHASIS PROGRAM IN THE CHEMICAL INDUSTRY, WHICH BECAME EFFECTIVE NOVEMBER 4, 1985. THIS SPECIAL EMPHASIS PROGRAM WILL INCLUDE 80 FIRMS IN FOUR OSHA REGIONS (NEW YORK, PHILADELPHIA, CHICAGO, AND DALLAS). TARGETING IS BASED ON THE HAZARDOUSNESS OF CHEMICALS KNOWN TO BE MANU FACTURED AT PARTICULAR SITES. PETROCHEMICAL PLANTS ARE INCLUDED, BUT THEY ARE NOT THE EXCLUSIVE FOCUS OF THIS PROGRAM. TRAINING FOR OSHA'S COMPLIANCE OFFICERS WHO WILL BE CONDUCTING THESE INSPECTIONS INCLUDED INSTRUCTION ON ELECTRICAL AND EXPLOSIVE HAZARDS. SINCE THIS IS A LIMITED PROGRAM WITH AN EXPERIMENTAL PURPOSE, IT SHOULD NOT BE UNDERSTOOD TO COMMIT OSHA TO CONTINUING INSPECTIONS OF THIS TYPE IN PETROCHEMICAL PLANTS GENERALLY. OUR PRESENT AIM IS TO DEVELOP MORE EFFECTIVE APPROACHES TO DISASTER PREVEN TION IN CHEMICAL PLANTS, AND TO IMPROVE THE EFFICIENCY OF OUR USE OF INSPECTION RESOURCES IN THE INDUSTRY. THE DEMONSTRATION PROJECT WILL GIVE US INFORMATION ABOUT THE KINDS OF HAZARDS ASSOCIATED WITH TYPICAL CHEMICAL INDUSTRY CONDITIONS AND PROCESSES. WE WILL BE PARTICULARLY CONCERN ED WITH IMPROVING OUR ABILITY TO ASSESS THE QUALITY OF HAZARD PREVENTION AND ABATEMENT PROGRAMS DEVELOPED BY EMPLOYERS.

From: NTSB
To: United States Department of Labor, Occupational Safety and Health Administration
Date: 1/14/1986
Response: The Board notes the Occupational Safety and Health Administration's (OSHA) statement that it plans no major change in its priorities for general schedule inspections. The Board notes further, however, that OSHA indicates that it is developing a pilot program to emphasize inspections in the chemical industry with appropriate emphasis on petrochemical plant inspections, including loading facilities. It in unclear from this response if OSHA indeed plans to conduct more frequent and regular inspections of petrochemical plant loading facilities, as outlined in the Board's recommendation. The Board would appreciate receiving more specific information regarding the pilot program and a statement as to whether this program will result in regular inspections of petrochemical plant loading facilities. Pending further response to the Board's concern, Safety Recommendation R-85-71 will be held in an "Open-Acceptable Action" status.

From: United States Department of Labor, Occupational Safety and Health Administration
To: NTSB
Date: 8/21/1985
Response: AS TO YOUR FIRST RECOMMENDATION, OSHA PLANS NO MAJOR CHANGE IN ITS PRIORITIES FOR GENERAL SCHEDULE INSPECTIONS. WE WILL CONTINUE TO TARGET OUR INSPECTION RESOURCES SO AS TO FOCUS ON THE MOST HAZARDOUS WORKPLACES. OSHA IS DEVELOPING, HOWEVER, A PILOT PROGRAM TO EMPHASIZE INSPECTIONS IN THE CHEMICAL INDUSTRY, DRAWING UPON THE AGENCY'S EXPERIENCE IN INVESTIGATING CHEMICAL PLANT HAZARDS FOLLOWING THE DECEMBER 1984 DISASTER AT A UNION CARBIDE PLANT IN BHOPAL, INDIA. THE TRAINING PROGRAM FOR OUR COMPLIANCE STAFF IN THIS EFFORT WILL INCLUDE APPROPRIATE EMPHASIS ON PETROCHEMICAL PLANT INSPECTIONS, INCLUDING LOADING FACILITIES.