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Codes, Guidelines and Executive Action Keys to Chemical Safety

Greg Enright

The U.S. Chemical Safety and Hazard Investigation Board's actions in response to the Kleen Energy disaster are one example of the impact the organization has had on the development of safety codes and standards developed and issued by standards-developing organizations following investigations by the board.

On Feb. 7, 2010, workers at an under-construction Kleen Energy power plant in Middletown, Conn. prepared for a routine procedure known as a “gas blow” that would remove debris from gas pipes.

There would be nothing routine about the procedure on this day, however.

To perform the operation, the workers forced natural gas through the piping at a high pressure and volume. Rather than being dispersed into the atmosphere, the natural gas was allowed to build up in a courtyard behind the facility’s main building. With numerous potential sources of heat in the vicinity, such as welding work and space heaters, it was only a matter of time before such heat interacted with the gas. The result was a massive explosion that killed six workers and injured 60 others.

The U.S. Chemical Safety and Hazard Investigation Board (CSB), an independent federal agency charged with investigating industrial chemical accidents, investigated the incident and a similar one that took place at a North Carolina meat processing plant eight months earlier. (View the CSB video, Deadly Practices, on YouTube.)

The CSB concluded that relevant industry codes and standards did not address safe practices for cleaning fuel gas piping and did not require fuel gas piping to be vented safely outdoors. It made an urgent recommendation to the National Fire Protection Association (NFPA) to revise the scope of its National Fuel Gas Code (NFPA 54/ANSI Z223.1), which provides requirements for fuel gas piping system safety. It urged the NFPA to:

  • Remove the existing NFPA 54 fuel gas piping exemptions for power plants and systems with an operating pressure of 125 pounds per square inch gauge or more.
  • For cleaning methodology, require the use of inherently safer alternatives, such as air blows or pigging with air in lieu of flammable gas.

 

In response, the NFPA developed and issued a new gas process safety standard in less than 24 weeks. This was significantly shorter than the typical NFPA code development process, which lasts roughly 104 weeks. NFPA 56 prohibits the use of flammable gas to clean piping and provides guidance for the use of non-flammable alternatives. Notably, the standard requires that discharged gases be released to an outdoor location or captured for further processing before release.

The CSB’s actions in response to the Kleen Energy disaster are but one example of the impact the organization has had on the development of safety codes and standards developed and issued by standards-developing organizations (SDOs) following investigations by the CSB. The incident and others were highlighted by the CSB in a recent brief. Others included:

American Petroleum Institute (API) – Human Fatigue as a Risk Factor

On March 23, 2005, a BP refinery in Texas City, Tex. was rocked by explosions and a fire that resulted in 15 deaths, 180 injuries and significant financial losses. The disaster occurred in a part of the plant’s facility known as an Isomerisation (ISOM) Unit, which is designed to boost the octane level in unleaded gasoline. The ISOM Unit included a 170-foot splitter tower to divide the refined gasoline into light and heavy components.

On the day of the disaster, this tower was being restarted after a month-long shutdown for scheduled maintenance. During the start-up, the tower overfilled, opening pressure relief devices that dumped the flammable liquid into a blowdown drum. The incoming liquid exceeded the capacity of the blowdown drum and into the atmosphere, where it ignited, causing the explosions and fire.

A CSB investigation concluded that one of the chief factors leading to the catastrophe was high fatigue levels of the operators. They had been putting in 12-hour shifts every day from the time of the splitter tower shutdown until the day of the incident. The CSB recommended that the American Petroleum Institute develop a fatigue standard, which it did, releasing it in 2010. A second edition is expected to be released in 2019.

International Code Council (ICC): Combustible Dust Hazards

In 2011, ferrous powder producer Hoeganaes had three combustible dust incidents occur at its Gallatin, Tenn., facility that killed four workers and injured three others. Upon investigation, the CSB found that although the state of Tennessee and the city of Gallatin had adopted the 2006 edition of International Fire Code (IFC) into law, the code did not specify whether compliance with and enforcement of referenced NFPA standards were mandatory or voluntary in the IFC. Following the CSB’s recommendation, revised language was incorporated that clearly identified the responsibilities of facility owners, and that standards “shall be” complied with, thus eliminating any ambiguity when it came to combustible dust hazards.

Despite the chemical industry’s increased use of safety-related processes and technologies within its plants, safety improvements have remained relatively stagnant, as a 2018 report from Accenture Consulting (Safety Culture in Chemicals) points out. The report refers to the lack of significant improvement in Non-Fatal Recordable Injury Rates and Number of Fatal Injuries by the North American Industry Classification System (NAICS) in chemical-related industries from 2011 to 2014.

A significant factor for the needle not moving on these metrics, the authors said, is safety culture.

“Safety is usually a core value at chemical companies, but executives and managers often fail to ‘walk the talk’ and reinforce that value. Instead, their actions tend to emphasize — and reward — production performance,” the authors wrote. “The result is the creation of a cultural norm focusing on ‘doing whatever it takes to get the job done.’ That in turn can lead to behaviors, such as rushing and taking short cuts, which contribute to the increased risk of an incident occurring on the job.”

To see actual improvement, the authors added, companies need to instill an understanding that production and safety are inseparable. Leaders need to back up their words with actions that keep safety in the foreground, “including recognizing people who contribute positive and innovative ideas, and discouraging employees from taking risks just to speed up operations — even as they push to meet production goals.”

About the Author: Greg Enright, is Content Marketing Manager, Intelex Technologies. He is a veteran writer, journalist and editor with more than 20 years of experience covering the Information Technology and Finance sectors. At Intelex, his focus is on Health and Safety issues. He can be reached at greg.enright@intelex.com

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April 15, 2019 @ 10:20 AM EDT Chemical, Energy - Oil and Gas, Manufacturing Environment, Health & Safety, Risk Management

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