The CSB has approved the draft recommendations in the DuPont incident last year at LaPorte, Texas that killed 4 employees. I observe many similar instances in batch processes in various manufacturing units in the pesticide industry during PSM audits. The CSB recommendations are given below:
"Pursuant to its authority under 42 U.S.C. §7412(r)(6)(C)(i) and (ii), and in the interest of promoting safer operations at US facilities handling chemicals and protecting workers and communities from hazards, the Board makes the following interim safety recommendations to the DuPont chemical manufacturing facility in La Porte, Texas and the International Chemical Workers Union Council of the United Food and Commercial Workers:
Inherently Safer Design Review
Prior to resuming Insecticide Business Unit (IBU) manufacturing operations, conduct a comprehensive engineering analysis of the manufacturing building and the discharge of pressure relief systems with toxic chemical scenarios to assess potential inherently safer design options. At a minimum, evaluate the use of an open building structure, and the direction of toxic chemical leaks and the discharge of pressure relief systems with toxic chemical scenarios to a destruction system. Implement inherently safer design principles to the greatest extent feasible and effectively apply the hierarchy of controls such that neither workers nor the public are harmed from potential highly toxic chemical releases. Detail the analysis, findings, and corrective actions in a written report and make this report available to DuPont La Porte employees, their representatives, and the CSB.
Ensure Manufacturing Building is Safe for Workers
Prior to resuming Insecticide Business Unit (IBU) manufacturing operations, conduct a robust engineering evaluation of the manufacturing building and the dilution air ventilation system that includes the implementation of corrective action(s) to the greatest extent feasible in order to ensure a safe environment for all workers. Develop a documented design basis for the manufacturing building and the air dilution ventilation system that identifies effective controls for highly toxic, asphyxiation, and flammability hazards and implement these controls to the greatest extent feasible. Address non routine operations and emergency response activities in the design basis. The design basis for the manufacturing building and the dilution air ventilation system must use the hierarchy of controls and inherently safer design principles to the greatest extent feasible.
Ensure Relief System Design is Safe for Workers and the Public
Prior to resuming manufacturing operations, ensure all Insecticides Business Unit (IBU) pressure relief systems are routed to a safe location and effectively apply the hierarchy of controls to protect workers and the public. Commission a pressure relief device analysis, consistent with API Standard 521 and the ASME Code, including a field review. Include an evaluation of relief system discharge location to ensure that relief systems are discharged to a safe location that will prevent toxic exposure, flammability, or asphyxiation hazards in order to ensure public and worker health and safety to the greatest extent feasible. Include an evaluation of relief scenarios consistent with API Standard 521.
Perform More Robust Process Hazard Analyses
Develop and implement an expedited schedule to perform more robust process hazard analyses (PHAs) consistent with R1, R2, and R3 for all units within the Insecticides Business Unit (IBU). At a minimum, the PHAs must effectively identify and control the hazards referenced in this document utilizing the hierarchy of controls. The PHA schedule must be prioritized based on anticipated risks to the public and workers in order to ensure that the highest risk areas receive priority consideration. At a minimum, the more robust PHAs must be consistent with the approach applied to post-incident reviews described above in paragraph 10.
Ensure Active Workforce Participation
Work together with the International Chemical Workers Union Council of the United Food and commercial Workers (ICWUC/UFCW) Local 900C and the ICWUC/UFCW staff (at the request of the local) to develop and implement a plan to ensure active participation of the workforce and their representatives in the implementation of Recommendations R1 through R4. In addition, provide a copy of DuPont’s integrated plan for restart to La Porte workers and their local union representatives.
Public Transparency and Accountability
Make publicly available (on a website) a summary of the DuPont November 15, 2014 incident investigation report, the integrated plan for restart, and actions to be taken for the implementation of Recommendations R1 through R5. This website must be periodically updated to accurately reflect the integrated plan for restart and implementation of Recommendations R1 through R5."
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