Document R2dwLo76KjkYxX0G3ygwO34LV

FILE NAME: Hercules Chemical (HERC) DATE: 1978 Aug 29 DOC#: HERC021 DOCUMENT DESCRIPTION: Memo RE Plant Tour by Hercules Safety Dept Noting that an OSHA Inspector Would Have Shut down Operations, Imposed Large Fines & that the Co. Would be Vulnerable to Lawsuits TO: ( FROM: SUBJECT MAVIS UUMUnwu. IIAYEG INDUSTRIES. INC 900 Crvrnltank Rua<i ' WILMINGTON. DELAWARE 19808 H . Dudley B arton Edw ard C. Painter P lant Tour by M r. L. W est from H ercules Safety D epartm ent DATE A u g u st 29, 1978 M. O. C O. PROJECT NO. On A ugust 24, 1978, M r. L. W est, fro m H ercules Safety D epartm ent, and I to u red the H aveg-M arshallton plant. tio n . T h is to u r w as of a low -key n atu re and m o re of an in tro d u cto ry type of in sp ec G enerally, th 'im pression M r. W est received w as that Haveg has im proved. He did notice th at one of our fo rk lift L P fuel bottles w as b arely attached to the unit causing a potentially dangerous condition. A lso, that the stacked H600 foam stripping in Building 40 w as a p o ssib le fuel source for gen eratin g a v ery hot fire . H otter than our sp rin k ler sy stem could handle. To elim inate th is h a z a rd , he recom m ends that we sto re the foam outside o f the building if a t a ll p o ssib le . In the sam e locality th ere a re asb esto s p ap er ro ils b are and w ithout p la stic bag coverage a s m andatory fo r asbestos item s. W ith the exception of asb esto s tre a tin g , the drying room , and the solvent storage a re a , I appreciate the housekeeping effo rt put out by each departm ent. : M r. W est rem ark ed th at he certainly noticed a g reat im provem ent at Haveg. I hope that this a re a housekeeping habit keeps up and th a t the old w ays of not caring a re J gone. ^ It is u n fortunate that sim ila r com plim ents .certain ly cannot be paid to the . asbestos treating a re a s. j M r. W e st re m a rk e d th a t if an OSHA in s p e c to r a t th is v e ry m o m en t showed up, H aveg would be in stan tly closed down and cited for w illfully contam inating the en v iro n m en t w ith a s b e s to s . OSHA w ould a ls o im p o se , on H aveg, high p en a ltie s in fin es and, in tu rn , th is would m ake us w ide open fo r m ultim illion d o llars liable su its brought on by the p erso n n el for being crim in ally exposed. Such d ep lo rab le conditions in these lo c a litie s is not of a f ir s t tim e happening. M r. Good, m y p re d e c e ss o r, as w ell a s I, have co n stan tly brought up the m a tter but som ehow the se rio u sn e ss of the n atu re does not se e m to be acknow ledged. A s im ila r o c c u rre n c e , although not related to housekeeping, w as w hen M r. A . Sim pson, D elaw are A ir D ivision, v isited us on A ugust 23, 1978. H is visiting tim e and the PROPRIETARY MAVIS INBUSTWES. INC (m ore) Exhibit 34 r N A V E9 IW U tttH U fc * . *m v 2 sp ecific eq u ip m en t he w as to m o n ito r w as w ell announced and in plenty of fo re tim e but the a sb e sto s d rie r, one of the re q u isite s, was not o perating. Half an hour la te r when the d rie r w as in operation and stabilized enough for m onitoring the effectiv en ess of the com plem enting dust co llecto r, the a ir blow er on the ro o f w as sc a tte rin g asb esto s fib e rs into the atm osphere, rig h t before the eyes of our v is ito r. T h is could have been avoided had the d rie r been in operation and the blow er outlet inspected that m orning. I A nother a re a of concern, in the safety-inspection to u r, although this tim e th e subject does not deal w ith asb e sto s, is the housekeeping in the solvent a re a alongside Building 3?, R esin P lan t. It w as found to be d isa stro u s w ith unm arked d ru m s, ungrounded acetone, etc ., dispensing d ru m s, generally untidy, and u n su p erv ised . The condition of that lo catio n w as well-know n to m e and w as brought to the attention of the su p e rv iso r. A ctually, a le tte r w ent out on June 6, 1978 on the v ery subject of req u ire d bonding of flam m able-liquid co n tain ers. M aintenance did rectify the condition in th at a re a but supervision stopped th e re . No follow -up could have been m ade. Such occu rren ces cannot be ignored, the w ag e-ro ll em ployees are generally the culprits because they a re the u se r of the solvents in th e ir operations but if no supervision is p re se n t and constant su rv eillan ce is not m ade, they stand b lam eless. Not w anting to sound like a C assan d ra, I m ust still say that I cannot o v e r em phasize the se v e rity of th ese in fractio n s and at m y am azem en t of the ob serv ed lack of concern o r an understanding of the gravity of such problem s by the su p e r v is o r. E C P/gf PROPRIETARY HAVES mOV^THtESt WG>