Chemical Manufacturing Safety Manual

OSHA Chemical Manufacturing Requirements

Chemical manufacturing is primarily regulated under OSHA’s 29 CFR Part 1910 — General Industry standards.

Unlike industries with one comprehensive industry-specific OSHA standard, chemical manufacturing facilities may be subject to numerous standards according to the chemicals, processes, equipment, and hazards present.

Potentially applicable requirements may include:

• Hazard Communication.
• Process Safety Management.
• Personal Protective Equipment.
• Respiratory Protection.
• Air Contaminants.
• Flammable Liquids.
• Hazardous Materials.
• Emergency Response.
• Permit-Required Confined Spaces.
• Lockout/Tagout.
• Machine Guarding.
• Electrical Safety.
• Walking-Working Surfaces.
• Hearing Conservation.
• Specific toxic-substance standards.

The safety manual should be tailored to the facility rather than assuming every chemical-manufacturing requirement applies to every operation.

Types of Chemical Manufacturing Operations

Chemical manufacturing can include a wide range of processes and products.

Operations may include:

• Basic chemical manufacturing.
• Organic chemical production.
• Inorganic chemical production.
• Specialty chemicals.
• Industrial cleaning products.
• Coatings.
• Adhesives.
• Resins.
• Pigments.
• Dyes.
• Fertilizers.
• Soaps and detergents.
• Chemical blending.
• Chemical formulation.
• Chemical repackaging.
• Batch processing.
• Continuous processing.

The hazards and programs required can vary substantially among these operations.

What Should a Chemical Manufacturing Safety Manual Include?

Depending on operations, a Chemical Manufacturing Safety Manual may address:

• Chemical-manufacturing safety responsibilities.
• Hazard assessments.
• Job Safety Analysis.
• Process Safety Management.
• Process Hazard Analysis.
• Operating procedures.
• Management of Change.
• Pre-Startup Safety Review.
• Mechanical Integrity.
• Contractor safety.
• Chemical compatibility.
• Hazard Communication.
• Chemical labeling.
• Safety Data Sheets.
• Flammable and combustible liquids.
• Reactive chemicals.
• Corrosive materials.
• Toxic substances.
• Process vessels.
• Tanks and piping.
• Pressure systems.
• Confined spaces.
• Lockout/Tagout.
• Hot Work.
• Respiratory Protection.
• Personal Protective Equipment.
• Emergency response.
• Spill response.
• Fire prevention.
• Incident investigation.

Programs should be included according to actual processes and regulatory applicability.

Chemical Manufacturing Safety Program

An effective Chemical Manufacturing Safety Program establishes responsibilities and procedures for controlling chemical, process, equipment, fire, explosion, pressure, exposure, and other workplace hazards.

Management should provide:

• Safe process design.
• Appropriate engineering controls.
• Written procedures.
• Properly maintained equipment.
• Employee training.
• Appropriate PPE.
• Exposure controls.
• Emergency resources.
• Effective supervision.

Managers, supervisors, and designated safety personnel should:

• Identify and evaluate chemical and process hazards.
• Determine applicable OSHA requirements.
• Maintain required written programs.
• Establish operating procedures.
• Evaluate process changes.
• Maintain process equipment.
• Control hazardous energy.
• Provide appropriate PPE.
• Maintain emergency systems.
• Investigate incidents.
• Correct unsafe conditions.
• Provide employee training.
• Maintain required records.

Employees should follow established procedures, use required controls and PPE, understand chemical hazards, and promptly report leaks, releases, damaged equipment, abnormal process conditions, injuries, and other hazards.

Chemical Hazard Assessments

Chemical-manufacturing hazard assessments should consider both the inherent hazards of individual chemicals and the risks created by the processes in which those chemicals are used.

Potential hazards may include:

• Toxicity.
• Corrosivity.
• Flammability.
• Reactivity.
• Oxidizing properties.
• Sensitization.
• Carcinogenicity.
• Acute toxicity.
• Chronic toxicity.
• Combustible dust.
• Pressure.
• Temperature.
• Chemical incompatibility.

Assessments should consider the quantity, concentration, physical form, temperature, pressure, containment, process conditions, and potential routes of employee exposure.

Process Hazard Assessment

Chemical manufacturing requires evaluation beyond simply reading Safety Data Sheets.

Process hazards may result from:

• Chemical reactions.
• Heat generation.
• Pressure buildup.
• Loss of cooling.
• Contamination.
• Incorrect charging.
• Valve misalignment.
• Equipment failure.
• Utility loss.
• Overfilling.
• Incompatible mixing.
• Control-system failure.

Potential consequences should be considered before processes are operated or modified.

Job Safety Analysis (JSA/JHA)

A JSA/JHA may be used to evaluate higher-risk chemical-manufacturing activities.

Potential JSAs/JHAs may address:

• Chemical transfer.
• Drum handling.
• Tank loading.
• Reactor charging.
• Batch mixing.
• Sampling.
• Equipment cleaning.
• Line breaking.
• Confined-space entry.
• Hot Work.
• Maintenance.
• Spill response.
• Bulk unloading.
• Filter changes.

The analysis should identify job steps, hazards, controls, PPE, and employee responsibilities.

Process Safety Management — When Applicable

OSHA’s Process Safety Management of Highly Hazardous Chemicals standard, 29 CFR 1910.119, applies to covered processes containing specified highly hazardous chemicals or qualifying quantities of flammable gases or flammable liquids.

PSM should not automatically be assigned to every chemical manufacturer.

Applicability should be determined from:

• Chemical identity.
• Chemical quantity.
• Process configuration.
• OSHA threshold quantities.
• Applicable exclusions.

Where PSM applies, it becomes a major component of the facility’s safety-management system.

Process Safety Information

Covered PSM processes require appropriate process safety information.

Information may address:

• Chemical hazards.
• Toxicity.
• Permissible exposure limits.
• Physical properties.
• Reactivity.
• Corrosivity.
• Thermal and chemical stability.
• Hazardous effects of inadvertent mixing.
• Process technology.
• Process equipment.

Information should be accurate and available to personnel who need it.

Process Hazard Analysis

A Process Hazard Analysis, or PHA, is a systematic evaluation of what can go wrong in a covered process and the safeguards used to prevent or mitigate hazardous releases.

PHA methods may include:

• What-If.
• Checklist.
• What-If/Checklist.
• Hazard and Operability Study.
• Failure Mode and Effects Analysis.
• Fault Tree Analysis.
• Other appropriate methodologies.

The selected method should be appropriate to the complexity of the process.

PHA Considerations

A Process Hazard Analysis should consider applicable:

• Process hazards.
• Previous incidents.
• Engineering controls.
• Administrative controls.
• Detection methods.
• Facility siting.
• Human factors.
• Consequences of control failure.

Recommendations should be resolved and documented.

Operating Procedures

Written operating procedures should describe how covered processes are operated safely.

Procedures may address:

• Initial startup.
• Normal operations.
• Temporary operations.
• Emergency shutdown.
• Emergency operations.
• Normal shutdown.
• Startup following turnaround or emergency shutdown.

Operating limits and consequences of deviation should be clearly addressed.

Safe Operating Limits

Employees should understand safe process limits involving factors such as:

• Temperature.
• Pressure.
• Flow.
• Level.
• Concentration.
• Mixing.
• Reaction time.

Procedures should identify actions required when limits are exceeded.

Emergency Shutdown

Employees assigned emergency-shutdown responsibilities should understand:

• Shutdown conditions.
• Required sequence.
• Isolation points.
• Communication.
• Emergency equipment.
• When evacuation is required.

Emergency shutdown should be performed only by personnel trained for the assignment.

Management of Change — When Applicable

Changes to covered processes should be evaluated before implementation.

Management of Change may apply to changes involving:

• Chemicals.
• Process technology.
• Equipment.
• Procedures.
• Facilities.

The review should consider:

• Technical basis.
• Safety and health effects.
• Procedure changes.
• Duration.
• Authorization.
• Employee training.

Affected safety information should be updated as required.

Pre-Startup Safety Review — When Applicable

A Pre-Startup Safety Review should be completed for applicable new or modified covered processes before introducing hazardous chemicals.

The review should confirm applicable:

• Construction.
• Equipment.
• Procedures.
• PHA recommendations.
• Training.
• Safety systems.

The process should not be started until required conditions have been satisfied.

Mechanical Integrity — When Applicable

Mechanical Integrity programs help ensure safety-critical process equipment remains suitable for service.

Covered equipment may include:

• Pressure vessels.
• Storage tanks.
• Piping systems.
• Relief devices.
• Vent systems.
• Emergency shutdown systems.
• Controls.
• Pumps.

Inspection and testing should follow appropriate procedures and recognized practices.

Preventive Maintenance

Preventive maintenance should address process and safety-critical equipment regardless of whether PSM applies.

Potential equipment includes:

• Pumps.
• Valves.
• Mixers.
• Agitators.
• Compressors.
• Ventilation systems.
• Sensors.
• Alarms.
• Emergency shutdown systems.
• Transfer systems.

Deficiencies should be corrected before equipment creates an unacceptable hazard.

Process Alarms

Process alarms may warn employees of conditions involving:

• High pressure.
• High temperature.
• High or low level.
• Gas detection.
• Ventilation failure.
• Loss of cooling.
• Fire.

Alarms should be maintained and employees should understand required responses.

Interlocks

Process interlocks may prevent or stop hazardous conditions.

Employees should not bypass or defeat interlocks except under controlled, authorized procedures.

Temporary bypasses should be carefully managed.

Emergency Shutdown Systems

Emergency shutdown systems should be maintained so they perform their intended safety function.

Testing and inspection should reflect equipment requirements and facility procedures.

Emergency shutdown does not necessarily substitute for Lockout/Tagout during servicing.

Batch Chemical Processing

Batch operations may involve repeated charging, mixing, heating, reaction, cooling, sampling, and transfer.

Hazards may arise from:

• Incorrect ingredients.
• Incorrect quantities.
• Wrong sequence.
• Contamination.
• Excessive reaction rate.
• Loss of cooling.
• Overpressure.

Batch procedures should clearly identify approved sequence and operating limits.

Reactor Safety

Chemical reactors can involve substantial:

• Pressure.
• Heat.
• Chemical reactivity.
• Agitation.
• Toxic materials.
• Flammable materials.

Operators should understand normal and abnormal reactor conditions.

Employees should not open, enter, or service reactors until applicable chemical, pressure, temperature, and energy hazards have been controlled.

Runaway Chemical Reactions

Certain reactions can accelerate rapidly and generate dangerous heat and pressure.

Prevention may require controls involving:

• Feed rate.
• Cooling.
• Agitation.
• Temperature monitoring.
• Pressure relief.
• Emergency quench.
• Chemical compatibility.

Potential runaway reactions should be evaluated during process design and hazard analysis.

Reaction Incompatibility

Materials should not be combined unless their compatibility and reaction hazards are understood.

Incompatible chemicals can cause:

• Fire.
• Explosion.
• Toxic gas.
• Violent reaction.
• Heat.
• Pressure.

Procedures should prevent incorrect charging and cross-contamination.

Mixing and Blending

Mixers and blenders may expose employees to:

• Moving parts.
• Chemical splash.
• Dust.
• Vapors.
• Hazardous energy.
• Unexpected reaction.

Equipment should be guarded and applicable ventilation and containment maintained.

Chemical Charging

Chemical charging procedures should identify:

• Correct material.
• Quantity.
• Sequence.
• Required PPE.
• Transfer method.
• Process conditions.
• Emergency response.

Employees should verify materials before adding them to a process.

Closed Transfer Systems

Closed transfer systems can reduce employee exposure and release potential.

Systems should be inspected for:

• Leaks.
• Damaged hoses.
• Failed seals.
• Incorrect connections.
• Valve problems.

Closed systems do not eliminate the need for appropriate emergency planning.

Manual Chemical Addition

Where chemicals are manually added, procedures should address:

• Splash.
• Dust.
• Vapor.
• Ergonomics.
• Container handling.
• Chemical incompatibility.

Mechanical or closed-transfer methods should be used where feasible and appropriate.

Tanks

Chemical-manufacturing facilities may use tanks for:

• Raw materials.
• Intermediates.
• Finished products.
• Waste.
• Solvents.
• Acids.
• Caustics.

Tank hazards should be evaluated according to contents and operating conditions.

Tank Overfilling

Overfilling can result in:

• Chemical releases.
• Fire.
• Employee exposure.
• Environmental release.
• Dangerous reactions.

Appropriate level controls, alarms, procedures, or other safeguards should be maintained.

Tank Venting

Tanks should have ventilation or pressure-relief provisions appropriate to the material and process.

Blocked or inadequate vents can contribute to:

• Overpressure.
• Vacuum collapse.
• Vapor release.
• Fire and explosion.

Vent systems should be inspected and maintained.

Storage Tanks

Storage-tank procedures should consider:

• Chemical compatibility.
• Secondary containment.
• Temperature.
• Pressure.
• Venting.
• Ignition sources.
• Transfer operations.
• Emergency access.

Tank identification should remain clear.

Piping Systems

Piping may transport:

• Acids.
• Caustics.
• Solvents.
• Flammable liquids.
• Toxic chemicals.
• Gases.
• Steam.
• Process intermediates.

Piping systems should be designed, identified, inspected, and maintained according to the hazards involved.

Line Identification

Piping and valves should be sufficiently identified so employees can determine system contents and function where necessary for safe operation and maintenance.

Confusion between similar lines can cause serious chemical incidents.

Line Breaking

Opening process piping can expose employees to residual:

• Pressure.
• Temperature.
• Toxic chemicals.
• Corrosives.
• Flammable material.

Before line breaking:

• Isolate the system.
• Relieve pressure.
• Drain or purge as appropriate.
• Verify conditions.
• Use required PPE.

Employees should assume lines contain hazardous material until a safe condition has been established.

Double Block and Bleed — When Applicable

Certain systems may use double-block-and-bleed arrangements to isolate hazardous process material.

The method selected should provide protection appropriate to the process and maintenance activity.

Blanking and Blinding

Blanking or blinding may be necessary where valve closure alone does not provide adequate isolation.

Blinds should be appropriate for system pressure and chemical service.

Pumps

Chemical pumps can expose employees to leaks from:

• Seals.
• Flanges.
• Connections.
• Hoses.
• Mechanical failures.

Leakage should be promptly evaluated and corrected.

Employees should not perform maintenance until hazardous energy and chemical contents have been controlled.

Compressors

Compressors may create hazards involving:

• Pressure.
• Noise.
• Heat.
• Mechanical movement.
• Gas releases.

Equipment should be inspected and maintained.

Potential gas hazards should be considered when compressors handle hazardous materials.

Pressure Vessels

Pressure vessels can release large amounts of stored energy if they fail or are improperly opened.

Before servicing:

• Isolate the vessel.
• Relieve pressure.
• Control chemicals.
• Control temperature.
• Verify safe conditions.

Pressure-relief devices should be maintained.

Pressure Relief Systems

Relief systems may protect equipment from dangerous overpressure.

Systems should be evaluated for:

• Proper set pressure.
• Adequate capacity.
• Safe discharge location.
• Blockage.
• Corrosion.
• Maintenance.

Discharge from relief devices should not create unacceptable employee exposure.

Vacuum Systems

Vacuum vessels and systems can fail from:

• Collapse.
• Chemical carryover.
• Loss of containment.
• Incorrect isolation.

Equipment should be designed and maintained for the operating conditions.

Chemical Compatibility

Chemical storage and handling should be based on compatibility.

Potentially incompatible categories may include:

• Acids and bases.
• Oxidizers and fuels.
• Water-reactive chemicals and water.
• Cyanides and acids.
• Sulfides and acids.
• Reactive monomers.
• Peroxides and incompatible contaminants.

Compatibility should be evaluated from specific chemical information rather than broad assumptions alone.

Segregated Chemical Storage

Incompatible chemicals should be separated using methods appropriate to the hazard.

Controls may include:

• Separate cabinets.
• Separate rooms.
• Curbs.
• Secondary containment.
• Distance.
• Dedicated tanks.

Spills should not be able to combine and create a more severe hazard.

Corrosive Materials

Chemical facilities may handle strong acids and caustics capable of causing severe burns.

Controls may include:

• Closed transfer.
• Splash protection.
• Chemical-resistant PPE.
• Secondary containment.
• Eyewashes.
• Emergency showers.

Employees should receive training on specific corrosive materials used.

Acids

Acid handling should address:

• Chemical concentration.
• Heat of dilution.
• Incompatible materials.
• Splash.
• Vapors.
• Transfer equipment.

Water should never be added or mixed with concentrated acids contrary to established safe procedures.

Caustics

Caustic materials can cause severe skin and eye injury.

Employees should use appropriate:

• Gloves.
• Face protection.
• Eye protection.
• Protective clothing.

Leaks and spills should be controlled promptly.

Oxidizers

Oxidizing chemicals can intensify fires and react dangerously with incompatible materials.

Storage and handling should control:

• Contamination.
• Heat.
• Combustible materials.
• Reducing agents.
• Organic material.

Water-Reactive Chemicals — When Applicable

Some chemicals can react violently with water.

Procedures should address:

• Moisture control.
• Fire-response limitations.
• Spill response.
• Storage.
• Equipment cleaning.

Employees should understand where water must not be used.

Pyrophoric Materials — When Applicable

Pyrophoric materials may ignite spontaneously upon exposure to air.

Where present, procedures should address:

• Inerting.
• Transfer methods.
• Storage.
• Fire protection.
• Emergency response.

Only trained employees should handle these materials.

Peroxides and Peroxide-Forming Chemicals — When Applicable

Certain chemicals can form unstable peroxides during storage.

Controls may include:

• Dating.
• Storage limits.
• Inspection.
• Testing.
• Proper disposal.

Containers with suspected dangerous crystal formation or deterioration should not be disturbed without appropriate evaluation.

Flammable Liquids

Flammable-liquid operations should control:

• Vapor release.
• Ignition sources.
• Static electricity.
• Storage.
• Transfer.
• Spill hazards.
• Fire protection.

Equipment and procedures should reflect the liquid’s properties and quantities involved.

Flammable Liquid Storage

Storage areas should meet applicable requirements for:

• Containers.
• Cabinets.
• Storage rooms.
• Bulk tanks.
• Separation.
• Ventilation.
• Ignition control.

Quantities should be managed according to applicable requirements.

Bonding and Grounding

Transfer of flammable liquids may generate static electricity.

Where required, equipment should be bonded or grounded to reduce ignition risk.

Connections should be maintained and inspected.

Flammable Vapor Control

Flammable vapors should be controlled using appropriate:

• Closed systems.
• Ventilation.
• Process containment.
• Ignition control.
• Detection.

Employees should recognize that vapors can travel to distant ignition sources.

Toxic Chemicals

Chemical manufacturers may handle substances capable of causing acute or chronic health effects.

Exposure should be evaluated through:

• Process review.
• Safety Data Sheets.
• Exposure monitoring.
• Industrial hygiene assessment.

Controls should reflect routes of exposure and applicable occupational exposure limits.

OSHA Substance-Specific Standards

Certain chemicals are regulated by specific OSHA standards.

Depending on operations, these may include substances such as:

• Benzene.
• Formaldehyde.
• Ethylene Oxide.
• Lead.
• Cadmium.
• Chromium (VI).
• Vinyl Chloride.
• Inorganic Arsenic.
• Methylene Chloride.
• Other regulated substances.

Applicability should be evaluated based on chemicals and employee exposure.

Air Contaminants

Chemical processes can release:

• Vapors.
• Gases.
• Mists.
• Fumes.
• Dust.

Employee exposure should be controlled to applicable limits.

Engineering controls should be used where feasible and required.

Exposure Monitoring

Exposure monitoring may be necessary to determine employee exposure to hazardous substances.

Monitoring programs should consider:

• Chemical.
• Task.
• Duration.
• Process conditions.
• Employee location.
• Existing controls.

Results should be communicated and retained as required.

Local Exhaust Ventilation

Local exhaust ventilation can capture contaminants near their source.

Systems should be designed for the specific process and contaminant.

Employees should report:

• Failed fans.
• Damaged ducts.
• Reduced airflow.
• Broken hoods.

Ventilation systems should be maintained.

General Ventilation

General ventilation may supplement source controls.

Ventilation should not spread hazardous contaminants into occupied work areas.

Airflow should reflect process and chemical hazards.

Respiratory Protection

Where respirators are necessary, the employer should maintain a Respiratory Protection Program meeting applicable requirements.

Elements may include:

• Hazard evaluation.
• Respirator selection.
• Medical evaluation.
• Fit testing.
• Training.
• Inspection.
• Maintenance.
• Program evaluation.

Respirators should be selected for the specific chemical and concentration.

Immediately Dangerous Atmospheres

Emergency or highly hazardous atmospheres may require respiratory protection suitable for IDLH conditions.

Employees should not enter unknown or IDLH atmospheres without appropriate equipment, training, backup, and rescue capability.

Personal Protective Equipment

PPE should be selected through a documented hazard assessment.

Potential PPE may include:

• Chemical goggles.
• Safety glasses.
• Face shields.
• Chemical-resistant gloves.
• Protective suits.
• Aprons.
• Chemical-resistant footwear.
• Hard hats.
• Hearing protection.
• Respirators.
• Fall protection.

PPE selection should account for specific chemical compatibility.

Chemical-Resistant Gloves

No single glove material protects against every chemical.

Selection should consider:

• Chemical.
• Concentration.
• Permeation.
• Breakthrough time.
• Degradation.
• Task duration.

Employees should replace contaminated or damaged gloves as appropriate.

Eye and Face Protection

Chemical splash hazards may require both chemical goggles and face protection.

A face shield should not automatically be treated as a substitute for required primary eye protection.

Chemical Protective Clothing

Protective clothing should be selected according to the expected exposure.

Contaminated clothing should be removed and handled so employees are not exposed during removal, laundering, disposal, or reuse.

Emergency Eyewashes

Emergency eyewash equipment should be provided where employees may be exposed to injurious corrosive materials as required.

Equipment should be:

• Accessible.
• Maintained.
• Unobstructed.
• Suitable for immediate emergency use.

Emergency Showers

Emergency showers should be available where body exposure to corrosive materials may occur and applicable requirements make them necessary.

Employees should know their locations.

Hazard Communication

Hazard Communication is particularly important in chemical manufacturing because chemical manufacturers have responsibilities both to their own employees and to downstream users of hazardous chemicals they produce.

The program should address:

• Hazard classification.
• Chemical inventory.
• Labels.
• Safety Data Sheets.
• Employee information and training.
• Workplace containers.
• Non-routine tasks.

Hazard information should remain accurate and understandable.

Hazard Classification

Chemical manufacturers and importers must evaluate the hazards of chemicals they produce or import and classify those hazards as required.

Classification should reflect available scientific information concerning applicable:

• Physical hazards.
• Health hazards.

Mixtures should be evaluated according to applicable criteria.

Product Labels

Required labels should communicate applicable:

• Product identifier.
• Signal word.
• Hazard statements.
• Pictograms.
• Precautionary statements.
• Supplier information.

Product labels should reflect the required hazard classification.

Safety Data Sheets

Chemical manufacturers and importers must prepare required Safety Data Sheets for hazardous chemicals they produce or import.

SDS information should be reviewed and updated as required when significant new hazard or protection information becomes known.

Downstream Hazard Communication

Chemical manufacturers must transmit appropriate hazard information to downstream employers and users.

Accurate labels and Safety Data Sheets are therefore not merely internal workplace documents.

Workplace Labeling

Process containers, secondary containers, and portable containers should be labeled as required.

Employees should not transfer chemicals into unidentified containers.

Chemical Sampling

Sampling can expose employees to concentrated chemicals, pressure, heat, or process vapors.

Sampling procedures should address:

• Sample point design.
• Pressure.
• Temperature.
• Purging.
• Ventilation.
• PPE.
• Container compatibility.

Closed-loop sampling should be used where appropriate.

Laboratory Operations — When Applicable

Chemical manufacturers may maintain quality-control, research, or process laboratories.

Laboratory operations may require additional procedures for:

• Chemical Hygiene.
• Fume hoods.
• Laboratory PPE.
• Chemical storage.
• Compressed gases.
• Laboratory waste.
• Emergency response.

Laboratory requirements should be coordinated with plant-wide chemical safety programs.

Drum Handling

Chemical drums may be:

• Heavy.
• Pressurized.
• Corroded.
• Damaged.
• Contaminated.

Mechanical handling equipment should be used where appropriate.

Employees should not stand in hazardous positions when opening or moving drums.

Opening Drums

Before opening a drum, employees should identify:

• Contents.
• Pressure potential.
• Chemical hazards.
• Required PPE.

Bulging, damaged, leaking, or unknown drums should receive special evaluation.

Intermediate Bulk Containers

IBCs should be inspected for:

• Damage.
• Leaks.
• Valve condition.
• Compatibility.
• Labeling.

Stacking and movement should follow container and equipment limitations.

Bulk Chemical Unloading

Bulk deliveries may involve:

• Tank trucks.
• Railcars.
• Hose connections.
• Pumps.
• Compressed gases.
• Hazardous chemicals.

Procedures should address:

• Chemical verification.
• Correct connection.
• Vehicle securement.
• Transfer monitoring.
• Emergency shutdown.
• Spill response.

Chemical Verification Before Transfer

Before transfer begins, employees should verify:

• Correct chemical.
• Correct receiving tank.
• Available capacity.
• Correct connection.
• Valve alignment.

Incorrect chemical transfer can create catastrophic reactions.

Hose Connections

Transfer hoses should be:

• Compatible with the chemical.
• Properly rated.
• Inspected.
• Correctly connected.
• Protected from damage.

Employees should remain clear of pressurized hoses where possible.

Tank Truck Operations

Bulk unloading areas should control:

• Vehicle movement.
• Ignition sources.
• Hose hazards.
• Chemical releases.
• Employee access.

Vehicles should be secured against unintended movement during transfer.

Railcar Chemical Transfer — When Applicable

Chemical railcar unloading should address:

• Railcar securement.
• Track protection.
• Valve identification.
• Hose connections.
• Pressure.
• Emergency shutdown.
• Employee position.

Only trained employees should perform transfer operations.

Loading Finished Products

Finished chemical products may be loaded into:

• Drums.
• Totes.
• Tank trucks.
• Railcars.
• Bags.
• Other containers.

Loading procedures should prevent:

• Overfill.
• Spill.
• Incorrect product transfer.
• Employee exposure.
• Mixing of incompatible materials.

Powder Handling — When Applicable

Chemical manufacturing may involve powders capable of creating:

• Inhalation exposure.
• Dust accumulation.
• Static electricity.
• Combustible dust hazards.

Powder processes should be evaluated according to the material’s properties.

Combustible Dust — When Applicable

Certain chemical products and raw materials may be combustible when present as fine dust.

Potential materials may include certain:

• Plastics.
• Resins.
• Dyes.
• Pharmaceuticals.
• Pesticides.
• Organic powders.
• Metals.

Facilities should evaluate actual dust explosibility rather than assume every powder presents the same hazard.

Dust Collection Systems

Dust collection should prevent unnecessary release and accumulation.

Systems should be evaluated for:

• Fire.
• Explosion.
• Static electricity.
• Isolation.
• Venting.
• Suppression.
• Housekeeping.

Where combustible dust exists, collector location and protection require careful evaluation.

Inerting — When Applicable

Some chemical processes may use nitrogen or other inert gases to reduce oxygen concentrations.

While inerting can reduce fire and explosion potential, it can create severe oxygen-deficiency hazards.

Employees should understand where inert gases are used.

Nitrogen Hazards

Nitrogen is colorless and odorless and can displace oxygen without warning.

Potential controls may include:

• Ventilation.
• Oxygen monitoring.
• Restricted access.
• Confined-space procedures.
• Warning signs.

Employees should not enter potentially oxygen-deficient areas without appropriate evaluation.

Confined Spaces

Chemical plants may contain numerous confined spaces, including:

• Tanks.
• Reactors.
• Vessels.
• Pits.
• Silos.
• Mixers.
• Boilers.
• Process equipment.

Spaces should be evaluated according to OSHA’s Permit-Required Confined Space requirements.

Permit-Required Confined Spaces

Potential permit-space hazards may include:

• Toxic chemicals.
• Oxygen deficiency.
• Flammable atmospheres.
• Engulfment.
• Mechanical equipment.
• Process entry.

Procedures should address entry authorization, testing, isolation, ventilation, attendant duties, rescue, and termination.

Vessel Entry

Before entering process vessels:

• Isolate chemicals.
• Control hazardous energy.
• Relieve pressure.
• Drain or clean as appropriate.
• Test atmosphere.
• Control process lines.

Entry should not begin until safe conditions have been established.

Confined Space Rescue

Rescue planning should be completed before permit entry begins.

Rescue resources should be capable of responding to the specific space and hazards.

Employees should not make uncontrolled rescue entries.

Lockout/Tagout

Chemical-process equipment can contain multiple energy sources.

Lockout/Tagout procedures may be required during covered:

• Maintenance.
• Cleaning.
• Repair.
• Inspection.
• Adjustment.
• Equipment entry.
• Line work.

Potential energy sources include:

• Electrical.
• Mechanical.
• Hydraulic.
• Pneumatic.
• Pressure.
• Steam.
• Gravity.
• Chemical energy.
• Thermal energy.

Chemical Energy Isolation

Hazardous-energy control in a chemical plant may require more than electrical lockout.

Chemical flow should be controlled through appropriate:

• Valves.
• Blinds.
• Disconnects.
• Drains.
• Purges.
• Blocks.

Isolation should reflect potential consequences of leakage.

Group Lockout/Tagout

Major maintenance or shutdowns may involve multiple crafts, departments, and contractors.

Group procedures should provide each authorized employee with required protection.

Coordination should be maintained across shifts.

Hot Work

Chemical manufacturing facilities require careful control of welding, cutting, brazing, grinding, and other ignition-producing work.

Hot Work procedures should address:

• Flammable liquids.
• Combustible vapors.
• Reactive chemicals.
• Process equipment.
• Combustible dust.
• Nearby drains.
• Adjacent equipment.

Work should not begin until applicable hazards have been controlled.

Hot Work Permits

Hot Work permit systems may be used to document:

• Work location.
• Fire hazards.
• Atmospheric testing.
• Equipment isolation.
• Fire protection.
• Fire-watch requirements.
• Authorization.

Where PSM applies, Hot Work permits have specific regulatory significance for work on or near covered processes.

Fire Watch

Fire watches should be assigned where required.

Fire-watch personnel should:

• Remain alert.
• Have suitable extinguishing equipment.
• Understand alarm procedures.
• Stop work when unsafe conditions arise.

Fire Prevention

Chemical facilities should control both fuel and ignition sources.

Potential fire hazards may include:

• Flammable liquids.
• Flammable gases.
• Combustible solids.
• Static electricity.
• Hot surfaces.
• Electrical equipment.
• Hot Work.

Fire-prevention procedures should reflect the chemicals and processes present.

Explosion Hazards

Explosion hazards may arise from:

• Flammable vapor.
• Gas.
• Dust.
• Reactive chemicals.
• Overpressure.
• Runaway reactions.

Controls should address both prevention and mitigation.

Ignition Source Control

Potential ignition sources may include:

• Open flames.
• Smoking.
• Static discharge.
• Electrical arcs.
• Hot surfaces.
• Vehicles.
• Welding.
• Grinding.

Ignition-source controls should reflect hazardous-area conditions.

Static Electricity

Static electricity can ignite flammable atmospheres or combustible dust.

Controls may include:

• Bonding.
• Grounding.
• Conductive equipment.
• Humidity control.
• Appropriate transfer rates.

Controls should be based on the process and material.

Electrical Classification — When Applicable

Locations where flammable gases, vapors, or combustible dust may be present can require appropriately classified electrical equipment.

Electrical installations should match the hazardous location classification.

Electrical Safety

Chemical manufacturing electrical systems may include:

• Motors.
• Pumps.
• Process controls.
• Instrumentation.
• Heating systems.
• Distribution equipment.

Qualified personnel should perform electrical work.

Damaged equipment should be removed from service or repaired.

Emergency Response

Chemical releases can require emergency actions beyond ordinary spill cleanup.

The employer should clearly determine employee roles.

Employees may be assigned to:

• Evacuate.
• Shut down equipment.
• Perform incidental spill cleanup.
• Participate in emergency response.

Employees should not perform emergency duties beyond their training and equipment.

HAZWOPER Emergency Response — When Applicable

Emergency response to uncontrolled releases of hazardous substances may trigger OSHA HAZWOPER emergency-response requirements.

Applicability depends on the nature of the release and employee response activities.

Facilities should distinguish between:

• Incidental releases.
• Emergency releases.

Incidental Releases

Small releases that do not pose significant safety or health hazards and can be safely controlled by employees in the immediate area may be handled under appropriate workplace procedures.

Employees should understand when a release exceeds incidental response capability.

Emergency Chemical Releases

Employees should evacuate and initiate established emergency procedures when a release presents hazards beyond their training or equipment.

Potential signs may include:

• Large release.
• Unknown substance.
• Toxic atmosphere.
• Fire.
• Explosion potential.
• Uncontrolled reaction.

Spill Prevention

Facilities should use appropriate controls to reduce the likelihood and consequences of spills.

Potential controls include:

• Secondary containment.
• Transfer procedures.
• Tank monitoring.
• Hose inspections.
• Vehicle barriers.
• Preventive maintenance.

Spill Response

Spill procedures should address the particular chemical.

Response may involve:

• Isolation.
• Evacuation.
• PPE.
• Ventilation.
• Containment.
• Cleanup.
• Waste handling.

Employees should not use generic spill methods on chemicals that may react dangerously with absorbents or water.

Emergency Action Plan

Emergency procedures should reflect the facility’s hazards.

Potential emergencies may include:

• Fire.
• Explosion.
• Toxic release.
• Reactive chemical incident.
• Major spill.
• Process upset.
• Severe weather.
• Medical emergency.

Employees should understand alarm systems, evacuation routes, assembly areas, and reporting procedures.

Shelter-in-Place — When Applicable

Certain toxic-release scenarios may make shelter-in-place more protective than immediate outdoor evacuation.

Where shelter-in-place is part of the emergency plan, procedures should identify:

• Alarm methods.
• Shelter areas.
• Ventilation controls.
• Accountability.
• Communication.

Emergency Equipment

Emergency equipment may include:

• Eyewashes.
• Showers.
• Spill kits.
• Fire extinguishers.
• Respiratory protection.
• Gas detectors.
• Rescue equipment.

Equipment should be accessible, inspected, and maintained.

Gas Detection

Facilities may use fixed or portable gas detection for:

• Toxic gases.
• Flammable gases.
• Oxygen deficiency.
• Specific process chemicals.

Detectors should be selected for the anticipated hazard.

Alarm levels and required employee actions should be established.

Medical Surveillance — When Applicable

Some OSHA substance-specific standards and respiratory-protection requirements may require medical surveillance or medical evaluation.

Applicability should be determined from the chemical and exposure.

Occupational Health

Chemical-manufacturing occupational health programs may address:

• Respiratory exposure.
• Skin exposure.
• Noise.
• Heat.
• Chemical sensitization.
• Reproductive hazards.
• Carcinogens.
• Ergonomics.

Industrial hygiene evaluations should reflect actual exposures.

Hearing Conservation

Noise may result from:

• Compressors.
• Pumps.
• Blowers.
• Mixers.
• Packaging machinery.
• Utility systems.

Employee noise exposure should be evaluated.

A Hearing Conservation Program should be implemented when applicable requirements are met.

Heat Stress

Chemical manufacturing may expose employees to heat from:

• Reactors.
• Steam.
• Furnaces.
• Boilers.
• Outdoor work.
• Protective clothing.

Heat-illness prevention should consider workload, environmental conditions, acclimatization, hydration, rest, and PPE.

Cold Stress — When Applicable

Outdoor operations, refrigerated processes, or cryogenic systems may expose employees to cold.

Appropriate clothing, work practices, and exposure controls should be provided.

Cryogenic Materials — When Applicable

Certain facilities may manufacture or use cryogenic liquids.

Potential hazards include:

• Extreme cold.
• Frostbite.
• Oxygen displacement.
• Pressure buildup.
• Oxygen enrichment.

Equipment and PPE should reflect cryogenic hazards.

Compressed Gases

Compressed gases may include:

• Nitrogen.
• Oxygen.
• Hydrogen.
• Chlorine.
• Hydrogen chloride.
• Ammonia.
• Other process gases.

Cylinder and bulk-gas systems should be designed and maintained for their specific service.

Gas Cylinder Safety

Cylinders should be:

• Properly secured.
• Protected from damage.
• Correctly identified.
• Stored appropriately.

Valves and regulators should be protected from contamination and damage.

Toxic Gas Systems — When Applicable

Highly toxic gases require particularly robust controls.

Potential controls may include:

• Closed systems.
• Gas cabinets.
• Scrubbers.
• Detectors.
• Automatic shutdown.
• Emergency ventilation.
• Respiratory protection.

Controls should reflect chemical-specific hazards.

Chlorine — When Applicable

Facilities manufacturing or using chlorine should address its acute toxicity, corrosivity, and oxidizing properties.

Controls may include:

• Leak detection.
• Ventilation.
• Isolation.
• Respiratory protection.
• Emergency response.

Chlorine should not be assumed to be present at all chemical plants.

Ammonia — When Applicable

Anhydrous ammonia can create significant inhalation, chemical-burn, pressure, and release hazards.

Systems should be inspected and maintained.

Emergency procedures should reflect the potential release scenarios.

Hydrogen — When Applicable

Hydrogen presents significant flammability concerns and can ignite over a wide range of concentrations.

Controls may include:

• Ventilation.
• Leak prevention.
• Ignition control.
• Gas detection.
• Appropriate electrical equipment.

Hydrogen Sulfide — When Applicable

Hydrogen sulfide may be present or generated in certain processes.

Potential controls include:

• Monitoring.
• Ventilation.
• Alarms.
• Respiratory protection.
• Emergency procedures.

Loading and Unloading

Shipping and receiving may involve:

• Trucks.
• Tank trucks.
• Railcars.
• Forklifts.
• Bulk containers.
• Pallets.

Traffic, chemical transfer, and material-handling hazards should be coordinated.

Powered Industrial Trucks

Forklifts may be used to move:

• Drums.
• Totes.
• Pallets.
• Raw materials.
• Finished products.

Only trained and authorized employees should operate applicable equipment.

Forklift Traffic

Facilities should separate pedestrians from powered equipment where practical.

Controls may include:

• Marked aisles.
• Barriers.
• Mirrors.
• Signs.
• Restricted areas.
• Speed limits.

Drum and Tote Storage

Drums and IBCs should be stored to prevent:

• Falling.
• Damage.
• Incompatible chemical contact.
• Vehicle impact.

Leaking containers should be isolated and addressed promptly.

Warehouse Chemical Storage

Chemical warehouses should address:

• Compatibility.
• Fire protection.
• Spill containment.
• Rack condition.
• Vehicle traffic.
• Labeling.
• Emergency access.

Chemicals should not be stored solely according to alphabetical order when incompatibilities exist.

Machine Guarding

Chemical manufacturing facilities may contain:

• Mixers.
• Blenders.
• Conveyors.
• Packaging machines.
• Pumps.
• Granulators.
• Mills.

Moving machinery should be guarded according to applicable requirements.

Packaging Equipment

Filling, capping, labeling, and packaging equipment can create:

• Pinch points.
• Crush points.
• Repetitive motion.
• Chemical exposure.
• Jam-clearing hazards.

Employees should follow machine-specific procedures.

Conveyor Safety

Conveyors may move raw materials, containers, or packaged products.

Required guards should protect employees from:

• Nip points.
• Rollers.
• Chains.
• Sprockets.
• Unexpected movement.

Applicable hazardous-energy controls should be used during servicing.

Housekeeping

Chemical manufacturing housekeeping should address:

• Spills.
• Chemical residue.
• Dust.
• Containers.
• Hoses.
• Packaging.
• Waste.

Aisles and emergency equipment should remain accessible.

Walking-Working Surfaces

Facilities may contain:

• Platforms.
• Tank access.
• Pipe racks.
• Catwalks.
• Loading racks.
• Elevated equipment.

Walking-working surfaces should be maintained and protected according to applicable requirements.

Fall Protection

Employees may require fall protection while working around:

• Tanks.
• Reactors.
• Loading racks.
• Platforms.
• Roofs.
• Elevated process equipment.

Hazards should be evaluated according to work location.

Ladder Safety

Ladders should be appropriate for the task and maintained in safe condition.

Employees should not use process piping or equipment as improvised access.

Contractor Safety

Chemical plants frequently use contractors for:

• Maintenance.
• Turnarounds.
• Electrical work.
• Construction.
• Cleaning.
• Tank entry.
• Specialized process work.

Contractors should receive information about hazards relevant to their work.

Where PSM applies, contractor responsibilities should meet applicable PSM requirements.

Plant Turnarounds

Major shutdowns and turnarounds may involve large numbers of employees and contractors.

Planning should address:

• Lockout/Tagout.
• Confined spaces.
• Hot Work.
• Line breaking.
• Chemical isolation.
• Cranes and rigging.
• Electrical work.
• Contractor coordination.

Multiple simultaneous activities require careful coordination.

Startup After Maintenance

Before restarting process equipment after maintenance, the facility should verify:

• Equipment is complete.
• Guards are installed.
• Tools are removed.
• Personnel are clear.
• Isolation devices are properly removed.
• Process lines are configured correctly.

Additional pre-startup requirements may apply to covered PSM processes.

Incident Reporting

Employees should promptly report:

• Chemical releases.
• Process upsets.
• Fires.
• Explosions.
• Near misses.
• Equipment failures.
• Exposure incidents.
• Injuries.
• Unsafe conditions.

Near misses involving chemical or process hazards can provide important warning information.

Incident Investigation

Significant incidents should be investigated to identify:

• Immediate causes.
• Contributing factors.
• Root causes.
• Corrective actions.

Investigations may consider:

• Process design.
• Operating procedures.
• Training.
• Mechanical integrity.
• Maintenance.
• Management of Change.
• Human factors.
• Emergency response.

Covered PSM processes have specific incident-investigation requirements.

Root Cause Analysis

Root Cause Analysis may identify underlying issues involving:

• Process design.
• Equipment selection.
• Procedures.
• Maintenance.
• Training.
• Supervision.
• Staffing.
• Process controls.
• Management systems.
• Corrective-action follow-through.

Corrective actions should address identified causes rather than merely assigning blame.

Chemical Manufacturing Safety Inspections

Periodic safety inspections should evaluate applicable:

• Chemical storage.
• Process equipment.
• Tanks.
• Piping.
• Pumps.
• Valves.
• Ventilation.
• Fire protection.
• Emergency equipment.
• PPE.
• Walking surfaces.
• Forklifts.
• Machine guards.

Identified deficiencies should be corrected according to risk and applicable requirements.

Chemical Manufacturing Safety Training

Employee training should reflect assigned duties and hazards.

Depending on responsibilities, training may address:

• Hazard Communication.
• Chemical-specific hazards.
• Process operations.
• PSM.
• Lockout/Tagout.
• Confined spaces.
• Respiratory Protection.
• PPE.
• Emergency response.
• Spill procedures.
• Powered Industrial Trucks.

Employees should not independently perform specialized work until they have received appropriate training.

Operator Training

Process operators should understand:

• Process purpose.
• Normal operating conditions.
• Operating limits.
• Alarms.
• Emergency shutdown.
• Chemical hazards.
• Required PPE.

Training should reflect the equipment and processes assigned.

New Employee Orientation

New employees should receive safety orientation before independently performing assigned work.

Orientation may address:

• Chemical hazards.
• Alarms.
• Emergency routes.
• PPE.
• Restricted areas.
• Incident reporting.
• Hazard Communication.

Refresher Training

Refresher or remedial training may be appropriate following:

• Process changes.
• Procedure changes.
• Equipment changes.
• Incidents.
• Near misses.
• Unsafe work practices.
• Identified knowledge gaps.

Specific regulatory standards may establish mandatory retraining or refresher frequencies.

Safety Meetings

Periodic safety meetings may reinforce topics such as:

• Chemical compatibility.
• Line breaking.
• Lockout/Tagout.
• Process alarms.
• Spill response.
• PPE.
• Hot Work.
• Recent incidents.

Recordkeeping

Chemical manufacturers should maintain safety and health records required for their operations.

Records may include:

• Employee training.
• Injury and illness records.
• Chemical inventories.
• Safety Data Sheets.
• Exposure monitoring.
• Medical surveillance.
• Respiratory Protection records.
• Lockout/Tagout inspections.
• PSM records.
• Equipment inspections.
• Incident investigations.

Records should be retained according to applicable requirements.

Additional Safety Programs

Depending on the facility’s chemicals, processes, and employee exposures, additional programs may be necessary for:

• Chemical Manufacturing Safety.
• Process Safety Management.
• Process Hazard Analysis.
• Management of Change.
• Mechanical Integrity.
• Pre-Startup Safety Review.
• Chemical Process Safety.
• Hazard Communication.
• Chemical Compatibility.
• Flammable Liquids.
• Corrosive Chemicals.
• Reactive Chemicals.
• Toxic Chemicals.
• Compressed Gases.
• Toxic Gas Systems.
• Combustible Dust.
• Respiratory Protection.
• Personal Protective Equipment.
• Exposure Monitoring.
• Confined Space.
• Lockout/Tagout.
• Line Breaking.
• Hot Work.
• Fire Prevention.
• Spill Prevention & Response.
• Emergency Response.
• HAZWOPER.
• Electrical Safety.
• Machine Guarding.
• Conveyor Safety.
• Powered Industrial Trucks.
• Loading & Unloading.
• Railcar Safety.
• Fall Protection.
• Walking-Working Surfaces.
• Hearing Conservation.
• Heat Stress Prevention.
• Emergency Action Plan.
• Contractor Safety.
• Incident Reporting & Investigation.
• Root Cause Analysis.

Programs should be included when the facility’s operations and regulatory applicability make them necessary.

Building a Chemical Manufacturing Safety Manual

A useful Chemical Manufacturing Safety Manual should be built around the actual chemicals and processes at the facility.

A batch chemical plant may require extensive procedures for chemical charging, reaction control, mixing, sampling, transfer, cleaning, batch sequencing, chemical compatibility, and operator response to abnormal conditions.

A continuous-process chemical facility may require greater emphasis on process controls, alarms, interlocks, pressure systems, mechanical integrity, Management of Change, startup and shutdown procedures, and emergency isolation.

A specialty chemical manufacturer may handle relatively small batches but use a wide variety of toxic, corrosive, flammable, reactive, or sensitizing materials requiring extensive Hazard Communication, chemical compatibility, ventilation, PPE, and exposure-control procedures.

A facility with covered quantities of highly hazardous chemicals may require a comprehensive Process Safety Management system involving Process Safety Information, PHA, operating procedures, training, Mechanical Integrity, Management of Change, Pre-Startup Safety Review, contractor controls, Hot Work, emergency planning, incident investigation, and compliance audits.

A blending or formulation facility may have fewer chemical reactions but significant hazards involving bulk unloading, mixing, flammable liquids, powders, chemical transfer, drum handling, packaging, and forklift operations.

The safety manual should therefore reflect actual hazards rather than automatically assigning every chemical-industry program to every manufacturer.

Customized Chemical Manufacturing Safety Manuals

A Chemical Manufacturing Safety Manual can be developed around the facility’s chemicals, processes, reactors, tanks, piping, pressure systems, flammable materials, toxic substances, bulk transfer operations, maintenance activities, employees, and other occupational hazards.

The finished manual may incorporate applicable programs for Process Safety Management, Hazard Communication, Chemical Compatibility, Flammable Liquids, Respiratory Protection, Confined Space, Lockout/Tagout, Hot Work, Spill Response, Emergency Response, Mechanical Integrity, Contractor Safety, Incident Investigation, and other hazards associated with chemical manufacturing.

This provides chemical manufacturers, chemical plants, blending facilities, formulation operations, and specialty chemical manufacturers with a practical safety manual organized around the work their employees actually perform.