United States Environmental
Protection Agency
Office of Solid Waste and
Emergency Response
(5104A)
EPA 550-F-04-004
May 2004
www.epa.gov/ceppo
Identifying Chemical Reactivity Hazards:
Preliminary Screening Method
The Environmental Protection Agency (EPA) is issuing this Alert as part of its ongoing effort to protect
human health and the environment by preventing chemical accidents. EPAis 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. Rather, understanding
the fundamental root causes, widely disseminating the lessons learned, and integrating these lessons
learned into safe operations are also required. EPA publishes Alerts to increase awareness of possible
hazards. It is important that facilities, SERCs, LEPCs, emergency responders, and others review this
information and consider whether additional action is needed to address the hazards.
Problem
Lack of awareness of the reactive
chemical hazards in a facility results in
a higher risk of hazardous uncontrolled
chemical reactions.
The current industry consensus defines
chemical reactivity hazard as a situation
where an uncontrolled chemical
reaction could result directly or indirectly in
serious harm to people, property, or the
environment.
Many materials used in industrial facilities can
pose chemical reactivity hazards. Reactivity
hazards may not be as easy to identify as other
hazards such as toxicity or corrosivity. Your
facility is at a higher risk of having an
uncontrolled release if you don't identify all
the existing chemical reactivity hazards.
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), Essential Practices for
Managing Chemical Reactivity Hazards, to
screen facilities for chemical reactivity
hazards. The CCPS preliminary screening
method is a tool to help you identify where
chemical reactivity hazards are likely to occur
in your facility and may be applicable to a
wide range of activities including
warehousing, repackaging, blending, mixing,
and processing.
Understanding the
Hazard
The first step in managing chemical
reactivity hazards is identifying those
facility operations and chemicals that
represent a potential chemical reactivity
hazard.
The preliminary screening method is based on
a series of twelve "yes-or-no" questions to
help you determine if there are chemical
reactivity hazards in your facility. These
questions may be answered by one person, but
you may be able to do a more thorough
screening by setting up a team composed of
people with diverse expertise. Whenever
possible, include people representing
technical, production, health and safety,
and the purchasing perspectives. In any
case, if you or your team are not certain about
the right answer to any question, you should
seek expert advice.
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IDENTIFYING CHEMICAL REACTIVITY HAZARDS: PRELIMINARY SCREENING METHOD
MAY 2004
If you answer questions 1 to 4 with a definite NO, then
you are not likely to have chemical reactivity hazards at
your facility.
Ql. Is intentional chemistry performed at your
facility?
Intentional chemistry means the processing of
substances such that an intended chemical reaction
takes place.
""*-+Yes? -> Go to Question 5
-> Answer Question 2
Q2. Is there any mixing or combining of different
substances?
Consider a wide range of activities, from large scale
formulations to individual procedures when answering
this question.
"*>Yes? -> Go to Question 6
'"*4No? -> Answer Question 3
Q3. Does any other physical processing of
substances occur at your facility?
Physical processing means any modification that
results in a product that is physically, but not
chemically, different from the original material.
""*-+Yes? -> Go to Question 6
""*•+ No? -> Answer Question 4
Q4. Are there any hazardous substances stored or
handled at your facility?
Hazardous substances include materials for which
material safety data sheets are required as well as
chemical intermediates and by-products.
'"'»>Yes?
Go to Question 7
You are not likely to have any chemical
reactivity hazards at your facility!
With the exception of question 5, a positive answer to
any of the following questions means that chemical
reactivity hazards do exist at your facility and you have
to address them.
Q5. Is combustion with air the only chemistry
intended at your facility?
Burning of ordinary flammable and combustible material
is not considered a chemical reactivity hazard.
'"*4Yes? -> Go back to Question 2
'"*4 No? -> Chemical Reactivity is expected to occur
Q6. Is any heat generated during the mixing or physical
processing of substances?
Heat can be generated by heat of solution, heat of
absorption, mechanical energy, or other physical heat
effects.
"*4Yes? -> Address Reactive Chemical Hazard!
'"*4 No? -> Go to next Question
If your facility stores, handles, repackages, produces or uses
any hazardous materials, you should give special
consideration to the following set of questions.
Q7. Is any substance identified as spontaneously
combustible?
"Spontaneously combustible" refers to substances that will
readily react with the oxygen in the atmosphere, igniting
and burning even without an ignition source.
"*4Yes? -> Address Reactive Chemical Hazard!
'"*4 No? -> Go to next Question
Q8. Is any substance identified as peroxide forming?
"Peroxide forming" refers to substances that will react with
the oxygen in the atmosphere to form unstable peroxides,
which might decompose and explode if concentrated.
"*4Yes? -> Address Reactive Chemical Hazard!
'"*4 No? -> Go to next Question
Q9. Is any substance identified as water reactive?
"Water reactive" refers to substances that will chemically
react with water, particularly at normal ambient conditions.
"*4Yes? -> Address Reactive Chemical Hazard!
""*•+ No? -> Go to next Question
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IDENTIFYING CHEMICAL REACTIVITY HAZARDS: PRELIMINARY SCREENING METHOD
MAY 2004
Q10. Is any substance identified as an oxidizer?
'Oxidizers' are materials that readily react to promote
or initiate combustion of combustible material.
"*4Yes? -> Address Reactive Chemical Hazard!
""*•+ No? -> Go to next Question
Q11. Is any substance identified as self-reactive?
"Self-reactive" refers to substances that self react (e.g.,
polymerize, decompose, or rearrange), often with
accelerated or explosive rapidity.
"*4Yes? -> Address Reactive Chemical Hazard!
No? -> Go to next Question
Is intentional
chemistry performed
at your facility?
s combustion
with air the only
chemistry intended a
our facility'
Is there any
mixing or combining of
different substances?
oes any other
physical processing o
substances occur at
our facility?
Is any
at genera
during the mixing or
hysical processing o
substances?
Is any
substance identified
as spontaneously
combustible?
Are there any
zardous substances
stored or handled at
our facility?
Is any
substance identified
as peroxide forming?
Expect chemical reactivity
hazara(s) to be present
Is any
substance identified
as water reactive?
-STOP-
Cnemical reactivity haz
not likely to be prese
Is any
substance identified
as an oxidizer?
Is any
substance identified
as self-reactive?
Polymerizing
Decomposing
Rearranging
12
incompatible
materials coming into
contact cause undesired
consequences?
Figure 1. Summary flowchart for preliminary screening for chemical reactivity hazards
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IDENTIFYING CHEMICAL REACTIVITY HAZARDS: PRELIMINARY SCREENING METHO
MAY 2004
Q12. Can incompatible materials coming into
contact with each other cause undesired
consequences?
'Incompatible materials' are materials that when
accidentally mixed or brought into contact with each
other will result in an uncontrolled chemical reaction.
-> Address Reactive Chemical Hazard!
-> Chemical reactivity hazards are unlikely
to be present. You completed the
Preliminary screening method.
No?
Figure 1, reproduced from Essential Practices for
Managing Chemical Reactivity Hazards, shows a
graphic presentation of the preliminary screening
method [Copyright 2003 by the American Institute of
Chemical Engineers, and reproduced by permission of
AIChE].
Controlling the Hazard
Chemical reactivity hazards can be controlled by
incorporating control techniques into the facility's
hazard management system.
If you identified chemical reactivity hazards in your
facility, a hazard management system can properly
address them. Most likely you already have a hazard
management system in place to address other hazards
and can incorporate reactive chemical hazards into the
existing programs. Regulatory process safety and risk
management systems such as the Occupational Safety
and Health Administration (OSHA) Process Safety
Management Standard, and EPA's Risk Management
Program (RMP) incorporate elements that are
applicable to the management of reactive chemicals
and can be used as a basis.
Note that EPA's Chemical Accident Prevention
regulations at 40 CFR part 68 do not cover reactive
chemicals as a group. Those regulations apply only to
facilities having more than a threshold quantity of a
chemical listed at 68.130 of the regulations. However,
EPA believes that facilities have a general duty to
address significant reactive chemical hazards under the
general duty clause of section 112(r)(l) of the Clean
Air Act.
Information Resources
Partnership To Provide Information
As mentioned above, this alert is intended to help facilities
identify chemical reactivity hazards and become familiar
with the preliminary screening method developed by
CCPS. You can find a detailed explanation of this method
and related management practices in CCPS' book
Essential Practices for Managing Chemical Reactivity
Hazards.
In order to make this valuable tool accessible to all
facilities, EPA, OSHA, CCPS, the American Chemistry
Council (ACC), the Synthetic Organic Chemical
Manufacturers Association (SOCMA) and Knovel
Corporation have contributed resources to make CCPS'
Essential Practices for Managing Chemical Reactivity
Hazards available for free downloading at the following
web page: http://knovel.com.
Chemical Safety Resources
For additional information on CCPS, please visit their
website at: http://www.aiche.org/ccps/
The U.S. Chemical Safety and Hazard Investigation Board
(CSB) is an independent federal agency whose mission is
to prevent industrial chemical accidents and save lives.
For more information on the CSB, visit their website at:
http: //www .chemsafetv. gov/
For additional information on OSHA, visit their website at:
http://www.osha.gov
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IDENTIFYING CHEMICAL REACTIVITY HAZARDS: PRELIMINARY SCREENING METHOD
MAY 2004
For More Information:
Contact EPA's Emergency Planning and
Community Right-to-Know Hotline
(800) 424-9346 or (703) 412-9810
TDD (800) 553-7672
Monday-Friday, 9 AM to 6 PM, Eastern Time
Visit the Emergency Prevention, Preparedness, and
Response website:
http://www.epa.gov/emergencies
NOTICE:
The statements in this document are intended solely as guidance. This document does not substitute for or change any applicable statutory
provisions or regulations, nor is it a regulation itself. The guidance it provides may not be appropriate for every situation.
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