A plastics plant experienced a release of approximately 15,825 pounds of styrene vapor from a railcar on 9/1/2020. The railcar had been on the property since May 2020 (4 months). The styrene began its reaction inside the railcar once the inhibitor had been consumed, leading to the release and evacuations ensued for those located around the facility.
The state’s EPA issued a notice of violation stating:
“The load of styrene monomer was not stored and monitored in accordance with XXXXXXX SOPs and the Styrene Safety Data Sheet”
OSHA issued only three (3) citations, but it was #3 that caught my attention. Apparently, this incident was impacted by the COVID shutdowns and this appears to have led to the styrene being left in this railcar longer than normal (e.g. against the advice on the SDS and in SOPs) so OSHA took issue with:
NOTE: the fatal styrene release in India on May 7, 2020 claimed the lives of 11 citizens after a storage tank went unmanaged over a 6-week period of time and it too began its reaction and vented styrene vapors. SAFTENG members can read the final report for this accident.
Citation 1 Item 1
Type of Violation: Serious; $13,653
29 CFR 1910.119(e)(1): The process hazard analysis did not identify, evaluate, and address the control of the hazards involved in the process:
(a) HIPS Feed Prep Unit: On or prior to 9/1/20, the process hazard analysis (PHA) did not identify, evaluate and address the control of the hazards of the process. The PHA did not adequately address the prevention or mitigation of a runaway reaction hazard associated with uncontrolled polymerization of styrene monomer occurring in bulk storage, exposing employees to toxic, fire, and/or explosion hazards.
(b) HIPS Feed Prep Unit: On or prior to 9/1/20, the process hazard analysis did not adequately identify, evaluate, and address the control of hazards associated with onsite movement and storage of railcar(s) containing styrene monomer, including runaway reaction hazards associated with uncontrolled polymerization, exposing employees to toxic, fire, and/or explosion hazards.
(c) HIPS Feed Prep Unit: On or prior to 9/1/20, the process hazard analysis did not adequately identify, evaluate, and address the control of hazards associated with extended or long term bulk storage of styrene monomer, including runaway reaction hazards associated with uncontrolled polymerization, exposing employees to toxic, fire, and/or explosion hazards.
Citation 1 Item 2
Type of Violation: Serious; $13,653
29 CFR 1910.119(f)(1): The employer did not develop and implement written operating procedures that provided clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and which addressed the elements listed in 29 CFR 1910.119(f)(1)(i) through (f)(1)(v):
(a) HIPS Feed Prep Process: On or prior to 9/1/20, the employer did not develop written operating procedures with clear instructions for movement and storage of styrene monomer railcars, which included procedures to minimize risk of uncontrolled polymerization of styrene monomer, exposing employees to toxic, fire, and explosion hazards.
Citation 1 Item 3
Type of Violation: Serious; $13,653
29 CFR 1910.119(l)(1): The employer did not implement procedures to manage changes to process chemicals, technology, equipment, and procedures, and changes to facilities that affect a covered process.
(a) HIPS process, railyard operations: On or prior to 9/1/20, the employer did not implement management of change (MOC) procedures to manage changes associated with extended onsite storage period(s) for railcars containing styrene monomer, which resulted from a production shut-down and delayed contract maintenance issues related to the COVID-19 pandemic, exposing employees to toxic, fire, and/or explosion hazards.
CLICK HERE for the citations