Occupational Safety and Health Administration and the Chemical Reactivity Hazards Management Alliance

I. Alliance Background

Date Signed

March 30, 2004

Date Addendum Signed

January 5, 2005

An addendum adding the American Chemical Society to the Alliance agreement was signed January 5, 2006.

Evaluation Period

March 30, 2005 – March 29, 2006

Overview

Signatories of the Alliance:

• Environmental Protection Agency (EPA)
• American Chemical Society (ACS)
• American Chemistry Council (ACC)
• Center for Chemical Process Safety (CCPS) of the American Institute of Chemical Engineers (AIChE)
• Chlorine Institute (CI)
• Mary Kay O'Connor Process Safety Center
• National Association of Chemical Distributors (NACD)
• Synthetic Organic Chemical Manufactures Association (SOCMA)

Through the Alliance, OSHA and the signatories of the Chemical Reactivity Hazards Management Alliance are working together to provide their members, customers, contacts and others involved in the manufacture, distribution, use and storage of chemicals with information, guidance, and access to training resources that will help them protect communities and employees' health and safety through better identification and management of chemical reactivity hazards.

Implementation Team Members

Chemical Reactivity Hazards Management Non Governmental Organizations:

*Bob Curtis was a contributor from March 2004 to September 2005
Eric Clark was a contributor from March 2004 to December 2005
Dorothy Kellogg was a contributor from March 2004 to December 2005
Paul Murphy was a contributor from July 2004 to April 2005

II. Implementation Team Meetings

III. Results

1. Events and Products

   Training and Education Goal

   • Provide input and expertise to OSHA to deliver training addressing chemical reactivity hazards, to be delivered in conferences, meetings, OSHA Training Institute (OTI) Education Centers, or through distance learning.

   Products

   "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists," a Workshop

   The OSHA and Chemical Reactivity Hazards Management Alliance developed a workshop, "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists," for presentation throughout the chemical industry. The workshop is designed to help smaller businesses identify the reactive chemical hazards that may be present in their operations. The first workshop was presented in conjunction with the Chlorine Institute 2005 Fall National Meeting September 26, 2005 in Atlanta, Georgia. The workshop was presented again January 13, 2006 in Houston, Texas in conjunction with the CCPS's Technical Steering Committee Meeting.

   In addition, Alliance Program participants The Dow Chemical Company assisted in the development of the workshop and provided a speaker at September 2005 session. Further, the National Federation of Independent Business (NFIB) was sponsor of the workshop and promoted the seminar to their local members in the Atlanta, Georgia, and Houston, Texas areas.

   Outreach and Communication Goals

   • Develop and disseminate information through print and electronic media, including electronic assistance tools and links from OSHA's and the signatories' Web sites.
     • Make the CCPS publication, Essential Practices for Managing Chemical Reactivity Hazards, available in the open literature through Signatories' web sites and other means.
     • Disseminate and encourage the use of the CCPS publication, Essential Practices for Managing Chemical Reactivity Hazards, to ACC, ACS, CI, MKOPSC, NACD, and SOCMA members and their respective value chains.

   Products

   OSHA's Chemical Reactivity Hazards Safety and Health Topics Page

   Representatives from the OSHA and Chemical Reactivity Hazards Management Alliance continued to provide input for OSHA's Chemical Reactivity Hazards Safety and Health Topics page. This page was launched in December 2004 and is maintained as a product of the OSHA and Chemical Reactivity Hazards Management Alliance and the OSHA and The Dow Chemical Company Alliance. The following Alliance implementation team members serve on the page's editorial board:

   • Bill Almond, NACD; Arlington, VA
   • Scott Berger, CCPS; New York, NY
   • Art Dungan, CI; Arlington, VA
   • Sam Mannan, Mary Kay O'Connor Process Safety Center; College Station, TX
   • Vanessa Rodriguez, EPA; Washington, DC
   • Irv Rosenthal, Wharton Risk Management and Decision Processes Center; Philadelphia, PA
   • Greg Smith, SOCMA; Washington, DC

   OSHA and the Chemical Reactivity Hazards Management Alliance Web page

   The OSHA and Chemical Reactivity Hazards Management Alliance Web page on OSHA's Web site includes links to the Alliance agreement and related documents, activities and events, milestones and successes, and products of the Alliance such as OSHA's Chemical Reactivity Hazards Safety and Health Topics page. OSHA continues to update this Web page with new information on the Alliance activities such as exhibiting, speaking, and workshops. For more information on the number of visits to the OSHA and the Reactive Alliance Web page, please see the Alliance Program Reach table.

   CI Chemical Reactivity Hazards Management Alliance Web page

   In January 2006 the CI launched its Alliance Web page that includes links to OSHA and the Chemical Reactivity Hazards Management Alliance Web page and OSHA's Chemical Reactivity Hazards Safety and Health Topics page.

   CCPS Chemical Reactivity Hazards Management Alliance Web page

   In January 2006 the CCPS launched its Alliance Web page that includes links to the free electronic CCPS book "Essential Practices for Managing Chemical Reactivity Hazards," OSHA and the Chemical Reactivity Hazards Management Alliance Web page and OSHA's Chemical Reactivity Hazards Safety and Health Topics page.

   Publications and Newsletters

   Information and news releases on the OSHA and Chemical Reactivity Hazards Management Alliance addendum signing and the activities of the Alliance have appeared in a number of publications produced by OSHA and the Chemical Reactivity Hazards Management Alliance signatories. In addition, information on the OSHA and Chemical Reactivity Hazards Management Alliance has been published in a number of safety and health publications such as RubberWorld Today's News and the Chemical & Engineering News publications. Please see the chart in this report under "Alliance Program Reach" for additional information.

   Essential Practices for Managing Chemical Reactivity Hazards Manual

   CCPS developed Essential Practices for Managing Chemical Reactivity Hazards and published the manual in 2003. The OSHA and Chemical Reactivity Hazards Management Alliance is continuing to promote the availability of the manual. Free on-line access is also available through OSHA's Chemical Reactive Hazards Safety and Health Topics page. The manual focuses on preventing workplace incidents and addresses the following topics:

   • • Identify, address, and manage chemical reactivity hazards;
     • Analyze the potential for chemical reactivity accidents;
     • Prevent reaction runaways, fires, explosions, toxic chemical releases, and
     • chemical spills; and
     • Apply this knowledge and tool set to processes of any scale.
   • Speak, exhibit, or appear at appropriate OSHA, EPA or other signatory conferences, local meetings, or other such events as:
     • ACC Responsible Care® Regional Meetings,
     • AIChE Loss Prevention Symposium
     • AIChE local section meetings
     • Annual CCPS International Conference
     • CCPS Technical Steering Committee meetings
     • SACHE Workshops (process safety train-the-trainer for engineering professors)
     • NACD's Operations Seminar & Trade Show
     • SOCMA annual and regional meetings
     • Chlorine Institute Annual and fall meetings
     • MKOPSC Annual Symposium and Short Courses
     • MKOPSC engineering seminars and course work
     • PhD dissertations research on chemical reactivity hazards

   Events

   Mary Kay O'Connor Process Safety Center 2005 Symposium, College Station, TX, October 25 – 26, 2005

   During the Mary Kay O'Connor Process Safety Center 2005 Symposium, October 25 – 26, 2005 in College Station, TX, Mark Briggs, Compliance Assistance Specialist, Region VI, Houston South Area Office, USDOL-OSHA, and James Shelton, Compliance Assistance Specialist, Region VI, Houston North Area Office, USDOL-OSHA, staffed an Alliance exhibit booth where they answered questions and distributed safety and health related materials.

   EPA Region III Hazardous Materials Spills Conference, Baltimore, MD, December 5, 2005

   During the EPA Region III Hazardous Materials Spills Conference, Baltimore, MD, December 5, 2005, Jim Belke presented information about the Alliance and provided materials developed through the Alliance developed workshop, "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists."

   SOCMA Responsible Care Regional Networking Meetings

   Through the OSHA and Chemical Reactivity Hazards Management Alliance, SOCMA invited OSHA and State Plan State representatives to speak at their Responsible Care® Regional Networking meetings at various locations across the nation. As a result, OSHA spoke at the following meetings about the Agency's priorities, initiatives and compliance assistance resources:

   • • April 5, 2005: SOCMA – Atlantic Coast Region Responsible Care® Regional Networking Meeting. David Copeland, OSHA Compliance Manager, South Carolina, OSHA Enforcement, gave a presentation to the group about South Carolina's priorities, initiatives and compliance assistance resources at OMNOVA Solutions Inc. in Chester, South Carolina.
     • April 7, 2005: SOCMA - South Region Responsible Care® Regional Networking Meeting. Marilyn Velez, Compliance Assistance Specialist, Region IV, Atlanta-West, Georgia Area Office, USDOL-OSHA, gave a presentation to the group about the Agency's priorities, initiatives and compliance assistance resources at MFG Chemical, Inc. in Dalton, Georgia.
     • August 18, 2005: SOCMA – Web Conference. Lisa Ramber, Office of Outreach Services and Alliances, Team Leader, USDOL-OSHA, gave a presentation to the conference about the Alliance, the Chemical Reactivity Hazards Safety and Health Topics page, and the "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists."
   • Collaborate with other Alliances on specific issues and projects on the identification and management of chemical reactivity hazards that are addressed and developed through the Alliance Program.

   Products

   "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists," a Workshop

   The OSHA and Chemical Reactivity Hazards Management Alliance developed a workshop, "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists," for presentation throughout the chemical industry. The first workshop was presented in conjunction with the Chlorine Institute 2005 Fall National Meeting September 26, 2005 in Atlanta, Georgia. The workshop was presented again January 13, 2006 in Houston, Texas in conjunction with the CCPS's Technical Steering Committee Meeting.

   In addition, Alliance Program participants The Dow Chemical Company assisted in the development of the workshop and provided a speaker at September 2005 session. Further, the National Federation of Independent Business (NFIB) was sponsor of the workshop and promoted the seminar to their local members in the Atlanta, Georgia, and Houston, Texas areas.

   Promoting the National Dialogue on Workplace Safety and Health Goals

   • Convene or participate in forums, round table discussions, or stakeholder meetings on chemical reactivity hazards to help forge innovative solutions in the workplace or to provide input on safety and health issues.

   Events

   Alliance Program's Promoting the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Work Group Meeting, Washington, DC, August 1, 2005

   Through the Alliance Program, OSHA held the Alliance Program's Promoting the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Workgroup meeting August 1, 2005 in Washington, DC as a follow up to the Alliance Program Hazard Communication Roundtable held February 15, 2005. The Workgroup, with representatives from 12 Alliance Program participants, identified potential compliance assistance products and resources to support OSHA's plans to adopt the GHS as part of its Hazard Communication Standard. Alison Clark, from SOCMA participated on behalf of the OSHA and Chemical Reactivity Hazards Management Alliance.

   In addition, Mr. Arthur E. Dungan, President of the Chlorine Institute, is participating on the Hazard Communication Awareness and Training Workgroup which was established at the February 2005 Roundtable.

2. Executive Summary

   Through the Alliance, OSHA and the chemical industry signatories have developed an excellent working relationship and are producing a number of programs and products for the chemical industry. These products are designed to produce information and guidance and increase access to training resources to protect communities and employees' health and safety through better identification and management of chemical reactivity hazards.

   The American Chemical Society joined the OSHA and Chemical Reactivity Hazards Management Alliance on January 5, 2006. Articles about the OSHA and Chemical Reactivity Hazards Management Alliance addendum signing appeared in a number of publications including; RubberWorld, and Chemical and Engineering News.

   During the Alliance's second year to meet the agreement's training and education goals, implementation team members developed a one day workshop "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists," to assist the chemical industry with identifying reactive chemical hazards during manufacturing, blending, and storage of chemicals. The Workshop is designed to assist small and medium size businesses to make them aware of the basics and provide strategies and tools for identifying and preventing reactivity incidents at those facilities. Other Alliance Program participants The Dow Chemical Company assisted in the development of the workshop and provided a speaker while the NFIB was a sponsor of the workshop and promoted the event to their local members. The Alliance is working to make the materials developed for the workshop available to the chemical industry as a Web conference or developed into a slide presentation or a slide presentation that is available on-line.

   In support of the agreements outreach and communications goals, the OSHA and Chemical Reactivity Hazards Management Alliance has allowed the Agency and chemical industry signatories to speak about OSHA's compliance assistance materials and the Alliance Program at a number of events including:

   • Atlantic Coast Region Responsible Care Regional Networking Meeting for SOCMA, Chester, South Carolina, April 5, 2005
   • South Region Responsible Care Regional Networking Meeting SOCMA, Dalton, Georgia, April 7, 2005
   • SOCMA Web Conference, August 18, 2005

   Further, OSHA Region VI staff manned an exhibit booth at the Mary Kay O'Connor Process Safety Center 2005 Symposium, College Station, Texas, October 25-26, 2005.

   In addition, OSHA and Chemical Reactivity Hazards Management Alliance implementation team members continued to update OSHA's Safety and Health Topics page, Chemical Reactivity Hazards and serve on the Topics page's editorial board.

   Finally, through the Alliance, Alison Clark with SOCMA participated in the Alliance Program Globally Harmonized System of Classification and Labeling of Chemicals (GHS) Workgroup meeting August 1, 2005 in Washington, DC. In addition, Mr. Arthur E. Dungan, President of the Chlorine Institute, is a member of the Hazard Communication Awareness and Training Workgroup.

   Due to their continued interest in the Alliance's work, the U.S. Chemical Safety Board attends implementation team meetings as an observer to the OSHA and Chemical Reactivity Hazards Management Alliance.

3. Alliance Program Reach

   Type of Activity (Conference, Training, Print and Electronic Distribution, etc.)	Number of Individuals Reached or Trained
   OSHA and the Reactive Chemical Alliance Web page on OSHA's Web site	4,563
   Chemical Reactivity Hazards Safety and Health Topics page	19,227
   CRHM representatives serve on OSHA's Safety and Health Topics page's editorial board for: Chemical Reactivity Hazards	TBD
   September 26, 2005: "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists," Chlorine Institute's 2005, Fall Meeting, Atlanta, Georgia	20
   October 25-26, 2005, Mary Kay O'Connor Process Safety Center 2005 Symposium, College Station, Texas Alliance Exhibit Booth Mark Briggs, OSHA Region VI Jim Shelton, OSHA Region VI	50
   December 2005: "Chemical Reactivity Hazards Workshop a Tutorial on Hazards Recognition, Possible Safety," Alliance Quarterly Review	300
   January 2006: CCPS and OSHA Alliance Web page	TBD
   January 2006: CI and OSHA Alliance Web page	TBD
   January 5, 2006: "ACS Added to OSHA and Chemical Reactivity Hazards Management Alliance," OSHA News Release	75 News Sources
   January 5, 2006: "ACS Added to OSHA and Chemical Reactivity Hazards Management Alliance," U.S. Newswire	TBD
   January 5, 2006: "ACS Added to OSHA and Chemical Reactivity Hazards Management Alliance," ArriveNet Politics	TBD
   January 6, 2006: "ACS Added to OSHA and Chemical Reactivity Hazards Management Alliance," Chemical Online	TBD
   January 9, 2006: "ACS Added to OSHA and Chemical Reactivity Hazards Management Alliance," RubberWorld Today's News	TBD
   January 9, 2006: "ACS Adds to OSHA and Chemical Reactivity Hazards Management Alliance," BayCare	TBD
   January 12, 2006: "ACS Joins Chemical Hazards Alliance, Society Joins OSHA, Industry Groups in Effort to Prevent Chemical Reactivity Accidents," Chemical & Engineering News	TBD
   January 12, 2006: "ACS Added to OSHA and Chemical Group Alliance," Industry News	TBD
   January 13, 2006: "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists," CCPS's Technical Steering Committee Meeting, Houston, Texas	16
   January 15, 2006: "ACS Added to OSHA and Chemical Reactivity Hazards Management Alliance," OSHA QuickTakes	55,000
   January 30, 2006: "ACS Added to OSHA and Chemical Reactivity Hazards Management Alliance," News for OSC	TBD
   TOTAL	78,881

IV. Upcoming Milestones

In the upcoming year, the OSHA and Chemical Reactivity Hazards Management Alliance will continue to work together to identify opportunities to assist the chemical industry in creating a safer working environment for the community and their workers.

The members of the Alliance implementation team are considering presenting the "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists," at the Chlorine Institute 2006 Fall Meeting, September 27, 2006 in Clear Point, AL. In addition, the Alliance has been approached to present the workshop by the Chemical Council in New Jersey and by the Metropolitan Water District in Southern California. Other venues for presenting the workshop at are currently under discussion. The Alliance is also considering developing the workshop information and materials into a presentation for a Web conference and a slide presentation that could be available on-line.

The Alliance team is also evaluating helping the Reactivity Management Roundtable's with the conversion of the CCPS Flow Chart that is used to screen facilities for chemical reactivity hazards into an electronic eTool. This eTool would be made available to the downstream customers of chemical manufacturers through various electronic and media outlets.

Representatives from the OSHA and Chemical Reactivity Hazards Management Alliance, including Alison Clark and Art Dungan, will continue to be involved with OSHA's Hazard Communication Roundtable follow-up activities. For example, implementation team member, Mr. Dungan, will continue to participate on the Alliance Program's Hazard Communication Roundtable Promoting the GHS Workgroup. The Alliance Program will schedule additional Promoting the GHS Workgroup meetings when OSHA publishes the advanced notice of proposed rulemaking for revising the Hazard Communication Standard to adopt the GHS.

In addition, the Alliance team members will be speaking or exhibiting at a number of events during the upcoming year, including:

• CCPS 2nd Global Congress on Process Safety Expo, April 23-26, 2006, Disney's Dolphin Hotel, Orlando, Florida
• CCPS Technical Steering Committee Meeting, April 27, 2006, Orlando, Florida

Through the Alliance, OSHA is also working to develop links to CCPS's Process Safety Beacons that have chemical reactivity information from OSHA's Chemical Reactivity Hazards Safety and Health Topics page.

Further, OSHA and Chemical Reactivity Hazards Management Alliance implementation team members will continue to serve on the editorial board and provide updates for OSHA's Chemical Reactive Hazards Safety and Health Topics page. In addition to the two signatories who have created Alliance Web pages on their organizations' Web site to promote the Alliance and chemical reactivity issues on their organizations Web pages other signatories are developing or evaluating creating their own Alliance Web pages.

Finally, the group will discuss the possibility of renewing the Alliance agreement in 2007.

Report prepared by: Bill Willson, Program Analyst, Office of Outreach Services and Alliances, July 6, 2006