Chemical Plant

The expert was asked to conduct a "basic ergonomic" evaluation of a formaldehyde production plant as part of a corporate review of the plant's safety program. This type of facility is a continuous flow processing plant using alcohol to form formaldehyde and has a significantly pipe and tank farm with both human and "computer controlled" monitoring. While the amount of chemical on site did not require it to comply with Process Safety Management (PSM) regulation, the quantity of chemical on site was near the threshold.

The plant had also had a safety inspection by the parent company that indicated the plant to be "in compliance with safety code". As the plant was near the PSM threshold, the expert chose to use a number of the elements in the PSM inspection protocols in conjunction with his ergonomics / human factors evaluation. The expert made a review of the "ergonomics" programs in place, the computerized control system and operator training, physical examination of all areas of the plant during normal operation and performed an extensive walkthrough of the tank farm, pipelines and loading areas. He also interviewed a number of "floor" personnel in different areas as well as supervisory and local management.

It was determined that : (1) The facility did not have in place most of the basic elements of a safety-health program for a processing facility; lacking clear piping, instrumentation and valve drawings; (2) Had no effective program for management of change or collection of operational knowledge; (3) Did not have a program for proactive evaluation of the many valves and sensors, with a number of the emergency and primary control valves having never been exercised since installed; (4) Commonly used valves were often installed in very awkward positions that forced operators to use very poor working postures. These poor postures and the difficulty of turning the valves increased the potential for musculoskeletal injury and was a source of complaint among the workers interviewed; (5) There was somewhat of a work until fail mentality on valves, pipes and instrumentation, this attitude being somewhat encouraged by the stable nature of the plant's processes and perceived hazards; (6) Emergency and critical (manual) response controls in the plant were often at improper locations being too high, too low or hard to get to; (7) Operator training was not clearly documented and tracked; (8) There were not up to date or realistic operating instructions, what was present was functional, but potentially outdated as had not been formally or rigorously reviewed since the plans were developed; (9) There were clear and serious safety hazards present in the trailer-tank loading docks that had not been identified in the standard safety inspection. Some of the hazards identified were of a "high death" category (high potential for an accident that will lead to death). The very poor housekeeping in some areas created significant potential for injury and product damage; (10) There were a number of ergonomics issues in bag handling and materials handling that presented elevated risks for back and musculoskeletal injury; (11) There was no significant coordination and cooperation with the local and regional emergency response and fire agencies; (12) There was poor physical security in the facility not only in terms of access but in terms of very poor illumination in the pipe and tank farms and pipe runs; (13) Evaluation of potential safety hazards during maintenance and other disturbed state operations indicated the potential for substantial safety hazards to be present.

For each of these areas the expert gave specific recommendations (based on cost, ease of implementation and effectiveness) and references to relevant code and design materials to help the company better understand and manage their overall safety, health and ergonomics program as well as meet OSHA codes and guidelines.

To see the resume of the expert associated with this case study, see the link below.