oEPA
United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(5104)
EPA 550-F-04-005
February 2005
vwvw.epa.gov/emergencies
                     MANAGING CHEMICAL REACTIVITY HAZARDS

                     The Environmental Protection Agency (EPA) is issuing this Alert as part of its ongoing effort
                     to protect human health and the environment. EPA is striving to learn the causes and
                     contributing factors associated with chemical accidents and to prevent their recurrence. Major
                     chemical accidents cannot be prevented solely through regulatory requirements, but by
                     understanding the fundamental root causes, widely disseminating the lessons learned, and
                     integrating these lessons learned into safe operations. EPA publishes Alerts to increase
                     awareness of possible hazards.  It is important that facilities, SERCs, LEPCs, emergency
                     responders and others review this information and take appropriate steps to minimize risk.
                     PROBLEM

                             Many materials used in
                             industrial facilities can pose
                             chemical reactivity hazards.
                     Conventional management systems
                     frequently do not adequately address
                     the unique behavior of materials that
                     may react to cause excessive
                     temperature or pressure excursions or
                     toxic or corrosive  emissions.

                     Incidents occur not only at chemical
                     manufacturing and processing plants,
                     but also at water treatment plants,
                     swimming pools and spas, metal
                     processing facilities, and mechanical
                     equipment manufacturing facilities.

                     PURPOSE

                           The purpose of this alert is to
                           introduce facilities to the
                           methodology for chemical
                     reactivity hazard management as
                     developed by the Center for Chemical
                     Process Safety (CCPS) and made
                     available in a book Essential
                     Practices for Managing Chemical
                     Reactivity Hazards. This alert is a
                     follow-on to the recent EPA alert
                     which discusses the CCPS method for
                     screening facilities for chemical
                     reactivity hazards. While the first
                     EPA alert focused on identifying
                                         chemical reactivity hazards, this alert
                                         focuses on the management of the
                                         hazards. This alert does not cover all
                                         ten essential management practices,
                                         but highlights some common
                                         management deficiencies.

                                         This alert assumes that the reader has
                                         determined that a chemical reactivity
                                         hazard exists at the facility and has:

                                         •  Explored opportunities, such as
                                            substituting inherently safer
                                            chemicals, to reduce or eliminate
                                            reactivity hazards;
                                         •  Gathered available information
                                            from available sources such as
                                            MSDS.
                                         •  Completed preliminary screening
                                            to identify chemical reactivity
                                            hazards (see the EPA companion
                                            alert Identifying Chemical
                                            Reactivity Hazards: Preliminary
                                            Screening Method for additional
                                            information);
                                         •  Developed a matrix indicating
                                            which chemicals react with each
                                            other, including the process or
                                            operating area where the chemicals
                                            are located;
                                         •  Gained management commitment
                                            to the safe operation of the facility;
                                         •  Ensured resources are available to
                                            ensure physical plant is designed
                                            or modified as necessary to
                                            mitigate chemical reactivity hazard
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   exposure;
•  Implemented a sound training program,
   operating procedures, and hazard
   communication program; and
•  Implemented an active safety audit program.

INCIDENT EXAMPLES

A       number of incidents involving reactive
       chemicals have resulted in accidental
       chemical releases, fire, and explosions.
The following section describes several recent
incidents.

September, 2004 - A transport vessel containing a
mixture of recovered monomer was observed to be
relieving pressure via the pressure relief valve. The
relief valve was lifting (relieving) as a result of the
pressure in the vessel exceeding the relief valve
setting.  The increased pressure was caused by an
increase in the temperature within the container.
This temperature increase was caused by a
polymerization reaction of the monomer mixture.
A water deluge was applied to cool the transport
vessel and minimize the vapor cloud dispersion.
The accident investigation revealed a blockage in
the injection feed line which obstructed the
addition of inhibitor into the monomer mixture.
The immediate term procedure modifications were
to manually control  the inhibitor injection and,
also, to  verify inhibitor concentration after loading
the transport vessel. The longer term modification
includes automatic inhibitor addition with post
loading verification of inhibitor concentration.

March,  2004 - Operations personnel were
preparing to unload  a railcar of methyl chloride
when they discovered a product identification label
attached to the railcar dome reading "methylene
chloride." Because the label and placards were not
in agreement, personnel quarantined the railcar
until proper chemical verification could be made
with the supplier and the facility quality control
laboratory. The verification confirmed that the
railcar placarding for methyl chloride was correct.
Close attention to material identification used
triggered personnel to take steps to verify the
contends of the railcar, thereby reducing the
likelihood of a serious process safety incident.

March, 1997 - The facility provides an antimony
catalyst service. A 1000-pound horizontal
cylindrical container was in the process of having a
small sample drawn into an open container.
However, the handle of the quarter-turn valve
leading to the dip-leg had been removed by the
customer before returning the container of spent
catalyst. The employee opened the valve using a
vice-grip tool but was then unable to close the
valve. Escaping spent antimony catalyst was
believed to have reacted with moisture in the
atmosphere, to create hydrogen chloride. The
incident investigation led to a management-of-
change review, revised sampling  procedures and
training and a closed sampling system that
discharges to a scrubber system. This incident
illustrates the need for particular attention to
operations that involve removing material from the
enclosed system, such as when venting, draining or
sampling.

July, 1994 -  New steel saddles (internal saddle
shaped devices used to promote mixing) were
installed in the direct-contact chiller vessel ahead
of the chlorine compressor. The saddles should
have had no corrosion protection coating, but they
did have an undetected coating of mineral oil.
When the main stream of chlorine and the chilling
material, which was also chlorine, entered the
chiller vessel, there was  an intense exothermic
reaction between the chlorine and the mineral oil
which burned through the vessel wall, releasing
chlorine to the atmosphere. The subsequent
incident investigation, the management-of-change
review, and the operating procedure revision
focused on verification that mechanical equipment
that may  come into contact with chlorine is
confirmed to be free of any material with which
chlorine may react. This incident highlights the
need to consider not only process chemicals, but
other chemicals and contaminants as well.
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MANAGEMENT OF REACTIVE
HAZARDS

      The consequences of a reactive chemical
      incident can be severe. In a 2002 study, the
      U.S. Chemical Safety Board (CSB) collected
detailed information on 167 serious incidents that
occurred between 1980 and 2001. EPA reviewed
CSB's information and identified the most
commonly reported management deficiencies. In
order of frequency, the reported management
deficiencies are:

•  Operating Procedures, Safe Operating Limits
   and Training
•  Hazard Identification and Evaluation
•  Human Factors
•  Management of Change
•  Emergency Relief Equipment and Controls
•  Process Design
•  Process Knowledge
•  Incident Investigation
•  Process Hazard Analysis
•  Safety Auditing
•  Equipment Maintenance

In their Reactive Hazard Investigation report, CSB
points to the limited availability of accurate
reactive chemical incident data. In spite of these
limitations, we believe that this data set is useful in
identifying areas of management systems that need
to be strengthened in order to address the hazards
of reactive chemicals.

To assist facilities in managing these risks, the
Center for Chemical Process Safety (CCPS)
sponsored the concept book Essential Practices for
Managing Chemical Reactivity Hazards and with
the support of its government and industry partners
has made this book available free of charge from
the Internet. Chapter 4 of this book discusses ten
essential practices for managing chemical
reactivity hazards. This alert does not cover all ten
management practices but highlights some
common management deficiencies.

Recommendations for strengthening management
systems include:

Communicate and Train on Chemical
Reactivity Hazards

Training activities and materials should
incorporate the hazards of chemical reactivity and
provide information relevant to workers directing
and performing process operations. The following
are some suggestions for improving
communication and training about reactive hazards
within a facility:

•  State not only the steps required to correctly
   execute the operation, but also the
   consequences of deviation. Develop likely
   scenarios such as incorrect charging,
   contamination of the process, or operating the
   process in the wrong range.
•  Integrate information about chemical reactivity
   hazards into the operating procedures and
   instructions,  rather than separately appending it
   to the instructions.
•  Clearly state safe operating limits and the
   actions to be taken if operating deviations
   occur.
•  Because concepts concerning reactivity hazards
   may be unfamiliar to some operating staff, these
   concepts should be clearly and simply worded.
•  Chemical reactivity hazards information should
   be included in the facility's material safety data
   sheet (MSDS) and, if necessary, described in
   detail in instructions accompanying the MSDS.
•  Share training materials with all operating
   personnel, including contractors.
•  Facility management should ensure that training
   is understood by employees and contractors.

Identify Process Controls and Risk
Management Options

The materials receiving and transfer system should
be designed to guard against inadvertent mixing or
incorrect handling.

•  Material receipt - Is a procedure in place,
   possibly sampling, to check the material
   received to ensure that it  is the correct material?
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•  Connection points- Is the connection clearly
   marked and/or color coded to guard against
   delivering to the wrong point? Incompatible
   couplings may also have an application.
•  Have piping manifolds, including sampling
   lines, blow-down and venting or flaring systems
   been checked to guard against cross connections
   that can lead to inadvertent mixing?
•  If incompatible materials are not handled in
   dedicated systems, are there positive isolation
   methods (spectacle blinds, drop-out, double
   block and bleed valve stations) used to prevent
   inadvertent mixing?
•  Positive Materials Identification (PMI) - Has
   the material handling equipment been checked
   to ensure that it is suitable for the material to
   which it is exposed? In addition to the piping,
   vessels, pumps and valving, the internal trim,
   packing, and lubrication and sealant must be
   considered.

Appropriate safeguards should be considered to
minimize hazards related to storage of reactive
materials.

•  Can the material deteriorate and become
   unstable because of the ambient temperature
   being too high, or too low, or because of
   excessive shelf time?
•  If containment is breached, will materials
   become exposed to air or water to which they
   are reactive?
•  Are incompatible materials stored the proper
   distance apart, or otherwise isolated?
•  Can breached containers allow incompatible
   chemicals to mix and react?
•  Has equipment used in the storage area been
   evaluated to ensure that it will not act as a heat
   or ignition source or cause instability (example
   - fork-lift truck exhaust in a dusty
   environment)?
•  Are sensors and alarms located in the storage to
   alert personnel in the event of a release or slow
   leak?

Manage Process Knowledge

Technical information pertaining to fire protection,
safety, health and environmental protection should
be freely exchanged between organizations within
industry and by technical societies.

•  Does the facility management have at least one
   person designated to explore available
   information on chemical reactivity hazards that
   may pertain to their operations?
•  Is information gathered from the above sources
   distilled down into an understandable form and
   made available to persons that may be involved
   with or exposed to the hazards of reactive
   chemicals present at the operating facility?
•  Is every opportunity taken to upgrade operating
   procedures and instructions as new information
   becomes known?
•  Is facility management strongly encouraged to
   contribute its own new information, including
   lessons learned and near-misses to others within
   industry?

Conduct a Process Hazard Analysis (PHA)

Many methods of conducting a PHA are suitable
for assessing the hazards associated with operation
of facilities involving reactive materials or
mixtures.  Several methods, such as "hazard and
operability" and "what-if," rely on a base set  of
questions for identifying risks. These base sets of
questions should be expanded to include aspects
that may be unique to reactive chemicals.
Additionally, any process change that is made
should receive a management of change (MOC)
review.

Consider Abnormal Situations

The severity of many chemical accidents can  be
attributed to a reluctance to seriously consider all
scenarios and to develop an appropriate action
plans.  Identifying and evaluating deviations that
may occur and developing appropriate responses
must be thought out before the fact. Possible
abnormal situations must be documented and
incorporated into instructions and training for
operating personnel and for emergency responders.
Otherwise, there is likely to be no response or an
inadequate one.  Some questions that should be
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considered:

   •  What out-of-control conditions are possible?
     What remedial steps are authorized and by
     whom?
   •  What firefighting actions may be taken?
     What actions should be avoided?
   •  Is emergency response equipment
     appropriately located and accessible in all
     types of situations?
   •  Which neutralizing or mitigation initiatives
     may be taken?
   •  What secondary hazards may result from
     pressure relief or blow-down systems?
   •  What contaminants are likely to be
     encountered?

Conduct Frequent Audits

Safety, health and environmental (SHE) audits can
serve a number of invaluable functions, including
verification that the concepts of reactive chemical
hazards are understood by operating personnel and
have been built into the operation.  The SHE audit
may be the last line of defense against an accident.
In verifying that the management system is
reliable, the SHE audits can also serve  as an
excellent training activity for key personnel and for
"guest"  audit participants. Audits provide an
opportunity for input from individuals in all levels
of the organizations. Audit teams must also
include at least one person with a good
understanding of the methods for identifying
chemical reactivity hazards. Team members
should be familiar with the different elements of a
sound management system and be able to
determine if each element is functioning as
intended.  The effectiveness of the training
programs and the operating procedures should be a
focal point of the audit program.
RECOMMENDED READING

Essential Practices for Managing Chemical
Reactivity Hazards - 2003, 194 pages, - Chemical
Center for Process Safety (CCPS).

CCPS has teamed with US OSHA, US EPA, the
American Chemistry Council, the Synthetic
Chemical Manufacturers Association, and Knovel
corporation to make this important new CCPS
concept book available for free on the Internet.
"Essential Practices" identifies a simple process to
determine if your operation may be at risk of a
chemical reactivity incident, and then guides you
to resources to manage that risk.  Persons wishing
free online access to this book will need to follow
a one-time sign-up procedure through Knovel,
CCPS's on-line book distributor,  prior to gaining
access to the document.
http: //info. knovel. com/ccp s/

Chemical Safety Alert: Identifying Chemical
Reactivity Hazards Preliminary Screening
Method- 2004, 5 pages - US EPA.

The purpose of this alert is to introduce small- and
medium-sized facilities to a simple method
developed by the Center for Chemical Process
Safety (CCPS), published in Essential Practices
for  Managing Chemical Reactivity Hazards, to
screen facilities for chemical reactivity hazards.
http ://yosemite. epa. gov/oswer/ceppoweb .nsf/vwRe
sourcesByFilename/flowchart.pdf/SFile/flowchart.
rjdf

A Checklist for Inherently Safer Chemical
Reaction Process Design and Operation What
You Need to Know - 2004, 8 pages - Chemical
Center for Process Safety (CCPS).

CCPS has developed this free pamphlet as a
summary of basic principles for safe operation of
chemical reaction processes.
http://www.aiche.org/ccps/pdf/CCPSAlertChecklis
t.pdf

Reactive Material Hazards What You Need to
Know - 2001, 11 pages - Chemical Center for
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Process Safety (CCPS).

CCPS has developed this free pamphlet to help
safety managers, chemists, and engineers
determine whether a process could have a chemical
reactivity hazard and what they should do to
prevent potential hazards.
http://www.aiche.org/ccps/pdf/reactmat.pdf
SOME USEFUL WEBSITES

OSHA Reactives Alliance
http://www.osha.gov/dcsp/alliances/reactives/react
ives.html

OSHA Chemical Reactivity Safety
http ://www. osha. gov/dep/reactivechemicals/

Mary Kay O'Connor Process Safety Center-
Reactive Chemical Research
http://process-safety.tamu.edu/research/reactiveche
m_l ab/RC_home. htm

National Oceanic and Atmospheric
Administration (NOAA) Chemical Reactivity
Worksheet
http://response.restoration.noaa.gov/chemaids/react
.html
        FOR MORE INFORMATION...
   Contact the RCRA, Superfund & EPCRA
                Call Center at:

        (800) 424-9346 or (703) 412-9810
              TDD (800)553-7672

              Monday -Friday
          9 AM to 5 PM, Eastern Time
         Visit the OEM Home Page at:
        http://www.epa.gov/emergencies
    Office of Emergency Management

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