Rafael Moure-Eraso: It's time for government and industry to adopt inherently safer technology

It will be a long time before residents of the Kanawha Valley forget the terrible explosion and fire that erupted at the Bayer CropScience plant in Institute in August 2008. Two workers were killed when a residue treater vessel -- designed to decompose insecticide waste -- exploded during a post-maintenance startup.That was tragic enough. But the accident could have been even worse had flying metal debris hit piping atop an above-ground tank of methyl isocyanate, or MIC, releasing the highly toxic chemical into the atmosphere. MIC is the same deadly substance that killed thousands in Bhopal, India, in 1984 at another similarly designed, Union Carbide plant. That was the conclusion of a careful study by my agency, the U.S. Chemical Safety Board, which spent more than two years investigating the 2008 accident.A question arose in our investigation: Was there an inherently safer alternative to storing and using MIC at the Bayer plant? The question of finding inherently safer materials, processes, and technology was not only applicable to Bayer CropScience, but also to the entire chemical industry as well. The principles of inherently safer technology, or IST, have the potential to make chemical production safer for workers and the public in the Kanawha Valley and across the country.Following the Bayer explosion and the MIC tank near-miss, Congress requested the CSB commission a study on the feasibility of implementing safer alternative chemicals and processes. The NAS recently released its findings and planned to outline them to the community in a public meeting in Institute.Although for environmental and business reasons Bayer announced earlier it would not restart MIC production at the plant, the NAS study and numerous CSB findings and recommendations show that consideration of inherently safer technology remains relevant to the workers and residents of the Kanawha Valley.In its report on the Bayer accident, the CSB recommended the Kanawha-Charleston Health Department create a "Hazardous Chemical Release Prevention Program" to assure citizens that facilities are maximizing their safety efforts, including the use of inherently safer technology. The gold standard for this kind of local oversight is Contra Costa County, Calif. Like the Kanawha Valley, Contra Costa is home to numerous chemical and petroleum operations. Alarmed years ago by a high process accident rate, Contra Costa County set up a prevention program that includes requirements to consider inherently safer technology with the intent that companies "incorporate the highest level of reliable hazard reduction to the greatest extent feasible." This model prevention program has been in operation since 1999, and has -- working closely with industry -- greatly reduced the number of major accidents, reaching zero in 2009.OSHA does the best job it can inspecting, advising, and regulating the chemical industry. It requires compliance with a preventive Process Safety Management or PSM standard for hazardous chemical processes. However, OSHA lacks the resources and the specialized inspectors to regularly audit all complex chemical plants for PSM compliance. I believe local oversight in the Kanawha Valley, as recommended by the CSB, could accomplish this goal and do much to make workers and residents safer. The CSB continues to urge the West Virginia state government and Kanawha County to establish a local chemical plant oversight program patterned after the model of Contra Costa County.After examining the Bayer accident and community concerns surrounding MIC (and other highly toxic materials), the NAS panel of blue-ribbon experts found that inherently safer process assessments can be valuable components of process safety management. The industry generally agrees that inherently safer operations can be achieved -- where feasible -- through four principles. These are: substituting one material with another that is less hazardous, minimizing the amount of hazardous material being used, moderating process conditions by lowering pressures and temperatures, and simplifying -- designing processes to be less complicated, and therefore less prone to failure.The NAS report found that while Bayer and previous owners of the site incorporated some considerations of inherently safer technology, these companies "did not perform systematic and complete inherently safer process assessments on the processes for manufacturing MIC or the carbamate pesticides at the Institute site." Thus large amounts of MIC, phosgene, and other toxic materials were produced or stored at the site for decades.
The NAS also found that industry as a whole lacks a common understanding of what is needed to identify inherently safer processes and accurately quantify their benefits, including the potential for reduced emergency preparedness costs. And the NAS said that conventional risk analyses used by companies tend to understate the likelihood of major accidents, which can occur due to systemic erosion of safety culture and management systems. Inaccuracies in accident risk analysis can mask the benefits of using inherently safer processes, the panel said. The NAS panel noted that the goal of inherently safer design is to not only prevent an accident, but also to reduce the consequences of an accident should one occur. Few nearby residents can forget the emergency response confusion after the Bayer explosion, as tens of thousands were instructed to shelter in place against an unknown disaster. The NAS notes one of the major benefits of inherently safer technology is that the severity of worst-case chemical releases is reduced and thus emergency preparedness planners can focus on more readily manageable scenarios.Some in industry have opposed mandatory IST programs because retrofits and updated processes with perhaps different, less toxic chemicals can be expensive to implement. However, the financial and human costs of chemical explosions and fires - and the costs of preparing a community for the worst case - need to be part of any decision process. The economic impact of the Bayer CropScience explosion is still very much experienced in the Kanawha Valley, even to this day nearly four years later.However, in our own investigations, the CSB has found many important examples of what can be done to enhance worker and public safety by implementing inherently safer technology at a manageable cost.A propane explosion and fire at a Texas refinery in 2007 caused the release of 5,300 pounds of toxic chlorine which could have injured or killed refinery workers had they not been quickly evacuated. The CSB recommended it switch to inherently safer bleach to decontaminate cooling water system. To its credit, Valero, which owned the facility, shifted all 11 of its U.S. refineries away from chlorine use. Now, thousands of workers at these refineries are exposed to far less hazard.After a massive explosion in 2010 at a natural gas-fired power plant in Connecticut that killed six workers during an operation in which large volumes of natural gas were blown through piping to clean it out, the CSB recommended the state ban the practice. The state did so, and the CSB has recommended OSHA do the same. Industry has quickly adapted, embracing inherently safer compressed air cleaning as a standard practice at power plants.
In fact, a recently published academic study in Process Safety Progress found over 90 implicit references to opportunities for adopting inherently safer technology in the CSB's investigations of major accidents.Despite the benefits of IST, federal efforts to promote its greater adoption by industry have encountered resistance. In 2002, responding to the 9/11 attacks and fears over the vulnerability of chemical plants, the EPA drafted a proposal that would have made chemical facilities "inherently safer by reducing quantities of hazardous chemicals handled or stored, substituting less hazardous chemicals for extremely hazardous ones, or otherwise modifying the design of processes to reduce or eliminate chemical hazards." This proposal from the previous administration has languished, however, for a decade.In light of the NAS report -- which illustrates how the Institute chemical site missed opportunities over the years to comprehensively adopt inherently safer technologies -- it is time for the EPA and other regulators to give this proposal another serious look and make IST a cornerstone of its accident prevention programs. It is time for industry to welcome the principles of IST -- substitute, minimize, moderate, and simplify -- and effect the changes needed to make chemical plants inherently safer. And residents and officials in West Virginia have an opportunity to jumpstart the effort by quickly establishing their own program.Moure-Eraso is chairman of the U.S. Chemical Safety Board.
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