Carter-Wallace, Inc. (Cranbury) - Executive Summary |
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BACKGROUND Carter-Wallace, Inc. is engaged in the manufacture and sale of a diversified line of Consumer and Health Care products. Carter-Wallace began its operations at the Cranbury site in 1959. Today, the facility consists of administrative offices, research and development and manufacturing within three buildings on approximately 520 acres. The facility is staffed 24 hours per day and presently employs approximately 850 people. FACILITY DESCRIPTION Manufacturing operations affected by the risk management plan (RMP) involve the production of aerosol antiperspirant products. That process includes the receipt and storage of aerosol propellant, aerosol can filling, quality control, and product storage. Propellants include various hydrocarbons which are received either by rail car or tank truck and are stored onsite. The filling station includes transfer lines and two filling rooms. Each filled aerosol can is tested for container integrity, packaged and temporarily stored for distribution. The Cranbury site handles materials as defined by both the US Environmental Protection Agency (USEPA) and the New Jersey Department of Environmental Protection (NJDEP) as hazardous materials. The NJDEP and USEPA enforce regulations designed to minimize the potential for an accidental release associated with handling hazardous materials. Additionally, the US Occupational Safety and Health Administration (OSHA) enforces accident prevention regulations to protect employees. The aerosol propellants used at the Cranbury site are listed as hazardous due to flammability. FIVE YEAR ACCIDENT HISTORY Aerosol antiperspirant production consists of two process operations: the propellant handling system and aerosol product storage. The major hazard associated with handling the propellant is the unanticipated loss of containment of the material. Such a release could present a potential fire or explosion hazard. These operations have not had any significant releases of regula ted material or accidents within the five year review period. A significant release would inlcude an incident resulting in offsite injuries, environmental impact, or offsite evacuation, or onsite injuries or significant property damage. HAZARD ASSESSMENT NJDEP and USEPA accident prevention regulations require companies to analyze what is defined as a worst case and alternative case release scenarios. The worst case release scenario would be the sudden loss of containment of material in the largest tank or vessel. The worst case scenario assumes the sudden release of propellant from a catastrophic storage tank failure, or the sudden release of aerosol from consumer packaged aerosol products in storage. This worst case scenario assumes that several highly unlikely events occur simultaneously such as: 7 Catastrophic failure of a vessel; 7 Failure of all automated safety and alarm systems; 7 Failure of our trained and experienced operators to respond appropriately; and 7 The event oc curs during least likely stagnant meteorological conditions. The alternative release scenario is intended to describe a potential release that has a higher likelohood of occurring but a less severe impact. The alternative release scenario considered a leak of propellant from a transfer line while unloading a rail car. Modeling analysis of the potential effect on the surrounding community shows that there would be no impact to the surrounding community from either the worst case or alternative case release scenario. These results classify the Cranbury site as a USEPA defined Program 1 facility which present minimal risk to the community. Other Program levels include Program 2 and Program 3. Program 3 includes those facilities that may present some risk to the community and / or includes facilities subject to OSHA's Process Safety Management (PSM) program. The PSM program regulates the use of hazardous materials by identifying and managing the potential release of hazardous mate rials in order to protect employees. However, the NJDEP RMP program does not include Program 1 requirements within its regulations, despite the fact that the worst case scenario shows no off-site impact. Since the facility is subject to the OSHA PSM program, the Cranbury site is classified as a Program 3 facility. PREVENTION PROGRAMS Carter-Wallace has developed programs to comply with the required environmental, health and safety standards. We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals through process management systems and programs which include: - Process safety information - Accident investigation - Training - Employee participation - Mechanical integrity - Hot work permit - Management of change - Contractor safety - Pre-startup review - Process hazard analysis - Compliance audits - Operating procedures In addition to our management programs, specially designed systems to control, prevent, detect, and mitigate potential accidental releases are also in place. These include level gauges on our storage tanks and manual shutoffs to prevent vessel overfilling. Aerosol can filling operations have alarms to warn of potential operating problems. The property is protected by firewater and sprinkler systems, and inspected annually by an outside independent company. Automatic firewater cannons also protect the storage tanks and loading and unloading operations. PLANNED CHANGES TO IMPROVE SAFETY Carter-Wallace strives for continuous improvement in its safety program. We train our employees to safely perform their assigned tasks. We also encourage our employees to suggest changes or improvements that will help improve safety and performance. We perform preventative maintenance to minimize the potential for unanticipated failure of operating equipment. We have recently reviewed and modified / updated many of the prevention program elements, including written operating procedures, mechanical integrity programs, management of change program, and our emergency response plan. We are presently reviewing recommendations identified during process hazard analyses of the aerosol production process equipment and procedures, performed by an independent expert with the participation of our facility personnel. EMERGENCY PREPAREDNESS AND RESPONSE Carter Wallace has an emergency response plan detailing procedures to respond to accidental releases and other emergencies. Our plan is tested through exercises and drills. Our plan has been shared with local emergency response organizations, including the Cranbury Township Fire Department and Local Emergency Planning Commission to ensure a coordinated response to an emergency. In the event of an emergency affecting our local community, Carter-Wallace will work closely with local, county and stage agencies to help ensure public safety. These agencies will take the lead in informing the public on appropriate actions in the event of an emergency. |