2005-6-I-LA-1

Expand the scope of DOT regulatory coverage to include chlorine railcar unloading operations. Ensure the regulations specifically require remotely operated emergency isolation devices that will quickly isolate a leak in any of the flexible hoses (or piping components) used to unload a chlorine railcar. The shutdown system must be capable of stopping a chlorine release from both the railcar and the facility chlorine receiving equipment. Require the emergency isolation system be periodically maintained and operationally tested to ensure it will function in the event of an unloading system chlorine leak.
Status: O-ARAR

2003-13-I-LA-1

Revise inspection and testing procedures to include effective methods for detecting and preventing leaks in coolers that use chlorine. These procedures should include the use of appropriate NDT methods.
Status: C-AA

2003-13-I-LA-2

Analyze layers of protection installed to prevent possible consequences of failure of heat exchangers that use chlorine, and implement corrective actions as appropriate. Examples of additional measures include installing monitors on the coolant stream to detect the presence of chlorine, and determining the feasibility of operating the coolant stream at a pressure high enough to prevent the entry of chlorine in the event of a leak.
Status: C-AA

2003-13-I-LA-3

To address ongoing issues regarding layers of protection and leaks in heat exchangers, revise procedures for performing process hazard analyses for equipment that contains hazardous materials such as chlorine to, at a minimum: - Require an evaluation of the effects of leaks in heat exchangers.
Status: O-ARE/AR

2003-13-I-LA-4

To address ongoing issues regarding layers of protection and leaks in heat exchangers, revise procedures for performing process hazard analyses for equipment that contains hazardous materials such as chlorine to, at a minimum: - Consider the layers of protection necessary to prevent a catastrophic incident and require recommendations to be implemented when existing protection is inadequate.
Status: O-ARE/AR

2003-13-I-LA-5

Revise the incident investigation procedure to ensure that odors inside positive pressure control rooms are investigated, the causes identified, and the appropriate corrective actions implemented. Address causes of the releases as well as entry of the material into the building.
Status: C-AA

2003-13-I-LA-6

Survey units that handle chlorine, and evaluate the effectiveness of shutdown systems for detecting and preventing the release of chlorine. At a minimum, ensure that shutdown systems and procedures are integrated to stop all potential sources of chlorine.
Status: C-AA

2003-13-I-LA-7

Conduct training to emphasize that MOC evaluations must consider whether emergency shutdown procedures need to be changed when there are changes in material inventory.
Status: O-ARE/AR

2003-13-I-LA-8

Conduct a hazard analysis (such as a job safety analysis) in the ton-cylinder area, incorporate appropriate findings into unit operating procedures, and train personnel accordingly.
Status: C-AA

2003-13-I-LA-9

Revise plant procedures on receiving cylinders to require that weights be recorded on incoming materials and suspicious materials be isolated so that hazardous materials are handled appropriately.
Status: C-AA

2003-13-I-LA-10

Revise the personal protective equipment matrix to include requirements for specific activities, such as draining HF equipment. Refer to the HFIPI guidelines as appropriate.
Status: O-ARE/AR

2003-13-I-LA-11

Develop and implement a program for the identification and management of hazards in nonroutine situations. Ensure that this program covers the following: - Situations where employees are unable to follow standard operating procedures, such as properly purging equipment.
Status: C-AA

2003-13-I-LA-12

Develop and implement a program for the identification and management of hazards in nonroutine situations. Ensure that this program covers the following: - Circumstances where there is no specific formal procedure for handling a highly hazardous chemical.
Status: C-AA

2003-13-I-LA-13

Develop and implement a program for the identification and management of hazards in nonroutine situations. Ensure that this program covers the following: - Operations following an emergency shutdown.
Status: O-ARE/AR

2003-13-I-LA-14

Develop and implement corporate standards to ensure positive pressure control rooms, including the HVAC systems, are designed and maintained to prevent the short-term entry of hazardous materials. Implement corporate standard changes at the Baton Rouge facility, and other Honeywell facilities as appropriate.
Status: C-AA

2003-13-I-LA-15

Develop and implement procedures for positively identifying material rejected by contractors such as C&MI so that hazardous materials are handled appropriately.
Status: O-ARE/AR

2003-13-I-LA-16

Develop and implement corporate standards for safely handling hydrogen fluoride.
Status: O-ARE/AR

2003-13-I-LA-17

In light of the findings of this investigation report, conduct a comprehensive audit of fluorine-based manufacturing facilities in your Specialty Materials group facilities. Ensure that the audit addresses: Thoroughness of hazard analysis and adequacy of safeguards.
Status: C-AA

2003-13-I-LA-18

In light of the findings of this investigation report, conduct a comprehensive audit of fluorine-based manufacturing facilities in your Specialty Materials group facilities. Ensure that the audit addresses: Recognition and management of nonroutine situations.
Status: C-AA

2003-13-I-LA-19

In light of the findings of this investigation report, conduct a comprehensive audit of fluorine-based manufacturing facilities in your Specialty Materials group facilities. Ensure that the audit addresses: Adherence to standard operating procedures.
Status: C-AA

2003-13-I-LA-20

In light of the findings of this investigation report, conduct a comprehensive audit of fluorine-based manufacturing facilities in your Specialty Materials group facilities. Implement the recommendations from the audit and communicate the findings to the work force.
Status: C-AA

2003-13-I-LA-21

Communicate the findings and recommendations of this report to your employees at fluorine-based manufacturing facilities in your Specialty Materials group.
Status: C-AA

2003-13-I-LA-22

Develop guidance on the effective design and maintenance of HVAC systems and other necessary control room components designed to protect employees and equipment in the event of a release of hazardous materials.
Status: O-ARE/AR

2009-13-I-LA-23

Evaluate and update as necessary community notification procedures to include timely notification of residents in the event of a chemical release. Conduct periodic refresher training with staff on the requirements in the procedures.
Status: C-AA

2003-13-I-LA-24

Conduct an awareness campaign to educate residents on the proper response during a chemical release. Include instructions on the way residents (including those outside the affected area) can obtain information during an emergency.
Status: C-AA

2003-13-I-LA-25

Conduct a survey of members to determine best industry practices for HF handling activities, such as draining equipment, use of open systems, and nonroutine work. Develop best practices guidance as appropriate and communicate it to your members.
Status: O-ARAR

2003-13-I-LA-26

Communicate the findings and recommendations from the August 13 incident to your membership.
Status: C-AA

2003-13-I-LA-27

Develop formal procedures for disposition of nonconforming materials received from customers. Ensure that procedures include positive identification prior to shipment.
Status: C-AA

2003-13-I-LA-28

Communicate the findings and recommendations from the July 20 incident to your membership. Emphasize the need to evaluate test methods for appropriateness in the given equipment.
Status: C-AA

2003-13-I-LA-29

Work with Honeywell to communicate the findings and recommendations of this report to your members employed at the Honeywell Baton Rouge Facility.
Status: O-ARE/AR