Implementation, chemical reactivity hazard

Figure 4.1. Flowchart for implementing chemical reactivity hazard management...

Identification. See Hazard(s) identification Implementation, chemical reactivity hazard management, 18... 

The purpose of this publication is to contribute to a continued reduction in the number and severity of incidents involving uncontrolled chemical reactions in the workplace. The obj ective of this publication is to convey the essentials of managing chemical reactivity hazards—those elements that are necessary, but not always sufficient, to avoid or mitigate chemical reactivity incidents. Implementing these elements should result in a management system that will, on an ongoing basis ... 

The keystone of managing chemical reactivity hazards is line responsibility. The "line" referred to here is the chain of command and authority that extends from the operator to the chief executive officer of the company. When all the advice and consultation is gathered relative to an issue, such as from relevant area experts and safety personnel, it is the business responsibility to provide leadership. It does so by communicating values, setting policy, making appropriate decisions, allocating the necessary resources, and following up to ensure implementation. 

Regular involvement, walk-around inspections, informal spot checks, and specific topical discussions by line management and staff can be used to ensure that chemical reactivity hazard management systems and procedures are actually being implemented and followed on a day to day basis. Questions should be raised if unexpected changes have been made or unusual circumstances are detected. 

In order to maximize the benefit of any identified improvement, administrative procedures should be created and implemented which define distribution or lines of communication for information related to chemical reactivity hazard management improvements. Examples of such lines include those from laboratories to pilot plants to production facilities. 

Through a survey of select small, medium, and large companies, information was gathered about good practices for reactive hazard management within the chemical industry. CSB also visited chemical industry facilities that have implemented programs for managing reactive hazards. 

Develop and implement a publicly available database for reactive hazard test information. Structure the system to encourage submission of data by individual companies and academic and government institutions that perform chemical testing. 

The CSB survey identified examples of modified or hybrid techniques to identify reactive hazard scenarios and ensure the implementation of adequate safeguards. For example, companies conducting reactions in batch chemical reactors often conduct HAZOP studies by evaluating deviations from... 

The concept of a safety case comes from the requirements of the European Union/European Community (EU/EC) Seveso Directive (82/501/EC) and, in particular, regulations that the United Kingdom and other member states used to implement that directive. United Kingdom regulations (Control of Industrial Major Accident Hazards [CIMAH], 1984 replaced by Control of Major Accident Hazards Involving Dangerous Substances [COMAH] in 1999) require that major hazardous facilities produce a safety report or safety case.64 The requirement for a safety case is initiated by a list of chemicals and a class of flammables. Like the hazard analysis approach (Section 8.1.2), experts identify the reactive hazards of the process if analysis shows that the proposed process is safe, it may be excluded from additional regulatory requirements. 

Site and Area Reactive Chemicals Implementation manuals. Reactive Chemicals/Process Hazard Analysis (RC/PHA) Introduction and Protocol, part of the RC/PHA Questionnaire tool, The Dow Chemical Company, Midland, MI, June 1997. 

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