Document 3roK4J3ZN6d6YJ76DbL5KLQn

ABD00318382 7^ OSHA HAZARD COMMUNICATION RULE LABELING REQUIREMENTS COMPLIANCE PROPOSAL By Jerald Uptain April 18, 1985 Revised: May 20, 1985 May 27, 1985 June 24, 1985 wJA ABD00318383 PURPOSE AND SCOPE Proposed herein is a means of compliance with the labeling requirements of the OSHA Hazard Communication rule as it applies to the Aberdeen plant. LABELING REQUIREMENTS The OSHA rule requires that employees be provided a method by which they may know the identity and hazards of materials with which they work. For more details, see the attached "OSHA HAZARD COMMUNICATIONS RULE A SUMMARY OF EMPLOYER RESPONSIBILITIES," dated February 12, 1985. CONTAINERS FROM HAZARDOUS MATERIAL SUPPLIERS 1. Insist that suppliers provide labeling on their containers which conforms to the requirements of the OSHA rule. 2. Keep hazardous materials in manufacturer-supplied containers whenever feasible. 3. Inspect all incoming shipments of chemicals at receiving to ensure supplier containers conform to the labeling requirements of the OSHA rule. PROCESS VESSELS AND PIPING 1. Vinyl Reactor Areas a. Replace the twelve regulated area signs in the two vinyl reactor areas with customized signs (35 1/2 inch x 35 1/2 inch "LXSIGN" with red lettering on a white background) available from Stonehouse Signs, Inc. at $57.46 each. These signs would preclude the need for labeling individual vessels within the units by referring to hazardous material reference books, wherein more explicit information may be found. b. Legend: VINYL CHLORIDE MONOMER USED IN MOST VESSELS AND PIPING IN AREA BOUNDED BY YELLOW LINE CANCER-SUSPECT AGENT AREA AUTHORIZED PERSONNEL ONLY OTHER HAZARDOUS MATERIALS IN USE SEE HAZARDOUS MATERIALS REFERENCE BOOK IN CONTROL ROOM FOR HAZARDS AND HANDLING SAFETY 2. VCM Tank Farm Area a. Install two customized signs (35 1/2 inch x 35 1/2 inch "LXSIGN" with red lettering on a white background) available from Stonehouse Signs, Inc. at $57.46 each (est.). ABD00318384 b. Locations: (1). Twenty feet south of no. 1 water well. (2). Thirty-three feet east of the railroad tracks and three feet south of the walkway leading from Entrance Road to the tank farm. c. Legend: VINYL CHLORIDE MONOMER USED IN MOST VESSELS AND PIPING IN THIS AREA CANCER-SUSPECT AGENT AREA AUTHORIZED PERSONNEL ONLY SEE HAZARDOUS MATERIALS REFERENCE BOOK IN CONTROL ROOM FOR HAZARDS AND HANDLING SAFETY 3. Compound, Dry Blend, and Plasticizer Areas a. Leave existing lead compliance signs in place. b. Install customized signs (14 inch x 20 inch "LXSIGN" having red lettering on a white background) available from Stonehouse Signs, Inc. at $18.16 each. c. Locations: (1). Southeast door of Line I. (2). Outside main door between Lab and Line I. (3). Outside door just northeast of Line I blenders. (4). Outside door just west of Line III mill. (5). Outside first-floor door just south of Line III and east of Dry Blend. (6). Outside first-floor door northeast of Line III. (7). Outside first-floor fire door northwest of Line III. (8). Outside the four exterior doors of the Plasticizer Building. (9). Outside the color weigh room door, c. Legend: HAZARDOUS MATERIALS USED IN THIS AREA SEE HAZARDOUS MATERIALS REFERENCE BOOK IN COMPOUND SUPERVISOR'S OFFICE FOR HAZARDS INTERMEDIATE STORAGE CONTAINERS 1. Except for process vessels, small containers used for immediate transfers, and Color Weigh Room weighups, all intermediate storage containers of hazardous materials must be marked with the same identities (chemical or common names) and hazardous warnings that appear on the manufacturer-supplied containers. Any method of marking is acceptable, provided it is legible. ABD00318385 2. Add the following legend to the "Compound Ticket" used with Compound Color weighups: CAUTION HAZARDOUS MATERIALS SEE HAZARDOUS MATERIALS REFERENCE BOOK IN COMPOUND SUPERVISOR'S OFFICE FOR HAZARDS AND HANDLING SAFETY ISOLATED STORAGE VESSELS AND CONTAINERS Because of their remoteness from the plant areas marked with boundary signs as detailed above, certain vessels and containers require their own labeling as follows: 1. Phthallic Anhydride Storage Tanks and Unloading Station a. Install customized signs (14 inch x 20 inch "LXSIGN" having red letteriing on a white background) available from Stonehouse Signs, Inc. at $27.88 each b. Locations: (1). On column just west of storage tanks. (2). On column just east of storage tanks. (3). On southwest column of loading rack. c. Legend: CAUTION PHTHALIC ANHYDRIDE BURN HAZARD TOXIC 2. Propane Tank Farm a. Use Carlton Industries, Inc. 8 inch x 10 inch propane gas warning sign (cat. no. 8412 - $6.63 each). b. Locations: (1). Post-mount west of propane tanks. (2). Post-mount south of propane tanks. 3. Small Propane Storage Tanks a. Use Carlton Industries, Inc. 3 1/2 inch x 4 1/2 inch propane gas press-on warning label (cat. no. 8410 - $20.75 per package of 10). ABD00318386 b. Locations: (1). Side of tank east of no. three treatment lagoon. (2). End of tank at fire training ground. 4. Gasoline Tanks a. Use Carlton Industries, Inc. gasoline warning label (cat. no. 815PV - $1.65 each). b. Locations: (1). Gasoline tank at fire training ground. (2). Gasoline tank at plasticizer tank farm. 5. Diesel Fuel Tanks a. Use Carlton Industries, Inc. 3 1/2 inch x 4 1/2 inch press-on fuel warning label (cat no. 821PV - $1.65 each). b. Locations: (1). Fuel tank at fire training ground. (2). The four, fire pump engine fuel tanks. (3). Diesal tank next to plasticizer tank farm. (4). The emergency generator fuel tanks. 6. Sulphuric Acid Storage Tank a. Use Carlton Industries, Inc. 3 1/2 inch x 4 1/2 inch press-on sulfuric acid label (cat no. 8410 - $20.75 per pkg. of ten). b. Locations: (1). East end of tank. (2). South side of tank. (3). West end of tank. 7. Ammonia Storage Tank a. Use Carlton Industries, Inc. 3 1/2 inch x 4 1/2 inch press-on ammonia warning label (cat no. 8410 - $20.75 per pkg. of ten). b. Locations: (1). East end of tank. (2). North side of tank. (3). West end of tank. (4). South side of tank. 8. Chlorine Storage Tanks a. Use Carlton Industries, Inc. 8 inch x 10 inch chlorine warning signs (cat. no. 8410 - $6.65 each). ABD00318387 b. Locations: (1). East side of chlorine shed (2). West side of chlorine shed. (3). South side of chlorine shed. 9. Caustic Storage Tank a. Use Carlton Industries, Inc. 8 inch x 8 inch caustic warning sign (cat. no. 8410 - $6.65 each). b. Location: North side of Tank 101. 10. Caustic Unloading Station a. Use Carlton Industries, Inc. 8 inch x 8 inch caustic warning sign (cat. no. 8410 - $6.65 each). b. Locations: (1). On column south of unloading spot. (2). On column north of unloading spot. 11. Acid Pump House a. Use Carlton Industries, Inc. 3 1/2 inch x 4 1/2 inch press-on labels (cat no. 8410 - $20.75 per pkg. of ten) for sulfuric acid, ammonia, and phosphoric acid. b. Location: Outside acid pump house door. 12. Water Treatment Chemicals Betz Laboratories, Inc. has agreed to provide warning labels for in-plant bulk containers of their hazardous materials. ABD00318388 SUMMARY OF LABELING COSTS 1. Vinyl Reactor area signs 2. VCM Tank Farm area signs 3. Compound, Dry Blend, Plasticizer area boundary signs 4. Phthalic Anhydride warning signs 5. Propane gas warning signs 6. Propane gas warning labels 7. Gasoline warning labels S. Fuel warning labels 9. Sulfuric acid warning labels 10. Ammonia warning labels 11. Chlorine warning signs 12. Caustic warning signs 13. Phosphoric acid warning labels 14. Signpost construction (Item 2 above) No. Unit Req'd. Cost 12 $57.46 2 57.46 Tot. Cost $689.52 114.92 11 3 2 1 pkg. 2 2 1 pkg. 1 pkg. 3 3 1 pkg. LSI.6 199.76 27.88 83.64 6.65 13.30 20.75/pkg. 20.75 6.65 13.30 6.65 13.30 20.75/pkg. 20.75 20.75/pkg. 20.75 6.65 19.95 6.65 19.95 20.75/pkg. 20.75 2 $50.00 100.00 Total Cost: $1400.64