The U.S. Chemical Safety & Hazard Investigation Board has concluded, after studying 167 serious incidents involving uncontrolled chemical reactivity from January 1980 to June 2001, that reactive incidents are a significant chemical safety problem.
OSHA's process safety management standard (PSM) has significant gaps in coverage of reactive hazards because it is based on a limited list of individual chemicals with inherently reactive properties, according to the board.
Given the impact and diversity of reactive hazards, "optimum progress in the prevention of reactive incidents requires both enhanced regulatory and nonregulatory programs," according to the board's report.
Forty-eight of these incidents resulted in a total of 108 fatalities. The data include an average of six injury-related incidents per year, resulting in an average of five fatalities annually. Nearly 50 of the 167 incidents affected the public, and more than 50 percent involved chemicals not covered by existing OSHA or EPA process safety regulations.
NFPA instability ratings are insufficient as the sole basis for determining coverage of reactive hazards in the OSHA PSM Standard.
The EPA Chemical Accident Prevention Requirements (40 CFR 68) have significant gaps in coverage of reactive hazards.
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.
Reactive incidents are not unique to the chemical manufacturing industry. They also occur in many other industries where chemicals are stored, handled or used.
Neither the OSHA PSM Standard nor the EPA Risk Management Program regulation explicitly require specific hazards, such as reactive hazards, to be examined when performing a process hazard analysis.
Given that reactive incidents are often caused by inadequate recognition and evaluation of reactive hazards, improving reactive hazard management involves defining and requiring relevant factors (e.g., rate and quantity of heat and gas generated) to be examined within a process hazard analysis.