• MFG did not understand or anticipate the reactive chemistry hazards. They did not make use of readily available literature on the hazards of reactive chemistry, or conduct a comprehensive literature search of the reactive chemistry specifically involved in manufacturing the product, which would have alerted them to the hazards involved in manufacturing TAC.
• MFG did not perform a comprehensive process design and hazard review of the laboratory scale-up to full production before attempting the first production run.
• MFG did not prepare and implement an adequate emergency response plan. They did not train or equip employees to conduct emergency mitigation actions.
• MFG did not implement the EPA Risk Management Program or the OSHA Process Safety Management program prior to receiving the allyl alcohol. The regulations require comprehensive engineering analyses of the process, emergency planning, a pre-startup safety review, and coordination with the local community before receiving the covered chemical at the site and introducing the covered chemical into the process.