Reactivity Hazard Management

Using lists of chemicals is an inadequate approach for regulatory coverage of reactive hazards. Improving reactive hazard management requires that both regulators and industry address the hazards from combinations of chemicals and process-specific conditions rather than focus exclusively on the inherent properties of individual chemicals. (CSB 2002b)1... 

Appendices contain case histories of chemical reactivity incidents, a sample inherently safer process checklist, and the Executive Summary of the CSB hazard investigation report on "Improving Reactive Hazard Management (CSB 2002b). 

Documentation of example chemical reactivity hazard management programs from CCPS sponsor companies that practice intentional chemistry. 

Table 4.1, Gap Analysis Chemical Reactivity Hazard Management System, and Table 4.2, Basic Chemical Reactivity Data to Collect. 

Full text of the U.S. Chemical Safety and Hazard Investigation Board report, "Improving Reactive Hazard Management" (CSB 2002b). 

The remainder of this publication, and the many references cited at the end of this publication, will go into great depth on the detail necessary to formulate and execute a chemical reactivity hazard management system. 

Shutting down a process, either for an indefinite period of time or permanently, can introduce chemical reactivity hazard management considerations. For example, one facility wanted to dismantle some equipment for a process for which an ether was a feedstock. A review of facility records did not conclusively reveal whether the equipment had been thoroughly decontaminated after the process was shut down years before. This left open the possibility that the equipment might contain explosive peroxides that could have formed over time by peroxidation of the ether. In another example, an unstable byproduct exploded when piping removed from a process unit was being cut into smaller pieces for disposal. 

Chemical Reactivity Hazard Management CCPS Elements OSHAPSM Standard and EPA RMP Rule Seveso II... 

Develop System to Manage Chemical Reactivity Hazards Management Systems Management System Safety Management System... 

Documentation of the chemical reactivity hazard management system will need to include how it relates to other regulatory elements. 

Chemical Reactivity Hazard Management Elements Not Explicitly Addressed ... 

If your product can pose a chemical reactivity hazard by itself or in combination with other materials, good product stewardship includes providing safety-related information to customers and users. Other aspects of product stewardship, some of which are also applicable to chemical reactivity hazard management, are outlined in the American Chemistry Council s Product Stewardship Responsible Care Code (ACC 2001). 

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

Table 4.1 lists essential ingredients of a management system for successfully managing chemical reactivity hazards. An honest comparison of a company s current practice with the items in this list can be used to point out the gaps that need to be filled. If you are just getting started with chemical reactivity hazard management, this shows what is needed to develop a successful management system. 

Gap Analysis Chemical Reactivity Hazard Management System... 

Case histories of chemical reactivity incidents, such as those in Appendix A-l, are useful in getting needed attention and priority for a chemical reactivity hazard management system. Other companies programs, such as the ones shared on the CD-ROM accompanying this publication, can be... 

This section provides guidance for creating the element of a chemical reactivity hazard management system that will ensure the capture and retention of safety-related process knowledge and documentation. The components of this element are ... 

Several channels of training and communication should be opened to various recipients under the chemical reactivity hazard management system. Training and communication involve combinations of various media, including ... 

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. 

Companies with strong chemical reactivity hazard management programs should strive to benefit from the latest advances in process safety technology, and keep abreast of technological advances through active participation in professional and trade associations. 

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. 

This report, Hazard Investigation Improving Reactive Hazard Management, by the U.S. Chemical Safety and Hazard Investigation Board (CSB), examines chemical process safety in the United States—specifically, hazardous chemical reactivity. Its objectives are to ... 

Surveyed current reactive hazard management practices in industry. 

Visited companies to observe reactive hazard management practices. 

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. 

Several voluntary industry initiatives, such as ACC s Responsible Care and NACD s Responsible Distribution Process (RDP), provide guidance on process safety management for chemical manufacturers and distributors. However, no voluntary industry initiatives list specific codes or requirements for reactive hazard management. 

Publish comprehensive guidance on model reactive hazard management systems. At a minimum, ensure that these guidelines cover ... 

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. 

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