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B. Hydrogen Sulfide Poisoning C. Nickel Carbonyl Formation

D. Precautions for Entering Any Contaminated or Inert Atmosphere E. Preparations for Vessel Entry

F. MSDS Sheets

The information and recommendations contained in this manual have been compiled from sources believed to be reliable and to represent the best opinion on the subject as of 1989. However, no warranty, guarantee or representation, expressed or implied, is made by UOP as to the correctness or sufficiency of this information or to the results to be obtained from the use thereof. Each refiner should determine the suitability of the following material for his purposes before adopting them.

Since the use of UOP products by others is beyond UOP control, no guarantee, expressed or implied, is made and no responsibility assumed for the use of this material or the results obtained therefrom. Moreover, the recommendations contained in this manual are not to be construed as a license to operate under, or a requirement to infringe, any existing patents, nor should they be confused with state, municipal or insurance requirements, or with national safety codes.

A. OSHA HAZARD COMMUNICATION STANDARD

All references to environmental, occupational safety and material transport laws are based on U.S.A. federal, state and local laws which are applicable only within the U.S.A. and its territories. It cannot be assumed that all necessary warnings and precautionary measures are contained in this manual, or that any additional warning and or measures may not be required or desirable because of particular exceptional conditions or circumstances, or because of applicable federal, state or local law.

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As of May 25, 1986, all U.S. employers covered under the Specific Industrial Classification (SIC) Codes 20-39 must be in compliance with the Occupational Safety and Health Standard, Subpart Z - Toxic and Hazardous Substances Hazard Communications, Section 1910.1200 of the Federal Regulations. This standard is commonly referred to as the “Right-to-Know Law.”

The OSHA standard is a U.S. Federal regulation requiring chemical manufacturers, importers and distributors to evaluate the hazards of their chemical products and convey hazard information through labels and material safety data sheets to its employees and customers which fall within SIC Codes 20-39. The customers in turn must pass the hazard information on to its employees and contractors which come on the premises. In this context, UOP employees who are working in or visiting a refinery are considered contractors to the refiner.

It is the responsibility of all refiners in the United States to inform all contractors of the hazardous chemicals the contractor’s employees may be exposed to while performing their work, and to provide any suggestions for appropriate protection measures. It is then the responsibility of UOP to provide the information to its employees about the hazardous chemicals to which they could be exposed by means of 1) a written hazard communications program, 2) training and information, 3) labels and other forms of warning, and 4) material safety data sheets.

1. Written Hazard Communications Program

The OSHA standard requires that U.S. employers make available to their employees the company’s written Hazard Communication Program. This document is intended to describe how the company will implement the OSHA standard. The program explains the company’s labeling system, material safety data sheets (MSDS), and employee information and training. The latter includes a listing of hazardous chemicals known to be present in the work place, and methods the company will use to inform its employees and contractors of the hazardous chemicals.

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2. Training and Information

All UOP employees receive classroom training in compliance with the OSHA standard. This includes an overview of the standard, an explanation on how to interpret and use the information on a MSDS, the location and availability of UOP’s file of MSDS’s, labeling requirements and their meaning, and an introduction to toxicology.

UOP employees working in or visiting U.S. refiners are considered contractor employees of that refinery. The OSHA standard states that contractors performing work in these facilities are required to train their people before they enter the refinery. However, it is the responsibility of U.S. refiners to inform UOP of the specific hazardous chemicals to which UOP’s employees may be exposed. UOP complies with the OSHA standard by making available to its employees this list of hazardous chemicals and by appraising them of the hazards they will be exposed, relevant symptoms and appropriate emergency treatment and proper conditions and precautions of safe use or exposure.

3. Labels and Other Forms of Warning

The OSHA standard states that all portable containers of hazardous chemicals must have a large, readable label or tag which has on it:

a. The name and address of the manufacturer b. The name of the chemical

c. A numerical hazard warning or other appropriate warnings supplied by the manufacturer

For the latter, the National Fire Protection Association (NFPA) Diamond is commonly used. An explanation of the NFPA Diamond may be found in Figure XIV-1 and Table XIV-1.

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Orange Carcinogen Hazard (i.e.: Benzene)

Red Chemical Burn Hazard (i.e.: Acids, Bases) Yellow Toxic Vapor Hazard (i.e.: H2S)

White All Others

Contractor employees must label all containers of hazardous materials which they bring into the refinery. This applies to UOP employees who are visiting or working in refineries.

4. Material Safety Data Sheet (MSDS)

The MSDS requirement falls primarily on chemical manufacturer, importers and distributors. The OSHA standard requires them to develop and provide a MSDS for each hazardous chemical they produce or handle. These manufacturers, importers and distributors are required to provide the MSDS to the purchasers of the hazardous chemical. MSDS sheets for the following UOP hydrotreating catalysts are included at the end of this section: S-120, N-108, N-204 and HC-K. For MSDS sheets on other UOP hydrotreating catalysts, please contact UOP.

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