The Debate About Chemical Accidents: Where Do We Stand?


		AcuSafe -> August 2000 Newsletter
		Editorial: The Debate About Chemical Accidents: Where Do We Stand?

by David Garcia, J.D.
AcuSafe Editor

Opinions are sharply divided on the state of chemical accident prevention. Certainly accidents continue to happen, but are we comfortable with the programs that are in place? Do they offer sufficient protection so that the chance of accidents similar to the Union Carbide plant in Bhopal, India or the Phillips plant in Pasadena, Texas are remote? This article touches on the need for effective process safety and chemical accident prevention programs, measures the commitment that the process industries have for such programs, identifies the most significant factors in accidents that do occur, and discusses whether specific industry sectors are responsible.

The Need for Action

There are compelling reasons that suggest that we must continue to be diligent and incorporate process safety into a stronger safety culture. Despite several regulatory initiatives and ongoing process safety programs, there has not been a clear cut decline in deaths and injuries according to several recent studies. For example, according to the Chemical Safety Board 600K report, which counted federally reported incidents between 1987 and 1996:

Chemical incidents at fixed facilities fell 5.7%, but transportation-based incidents rose 49.4%. For fixed facilities there were peaks and valleys but the total numbers appeared about constant, while transportation incidents showed a significant increase.
Over 95% of counties had at least one incident during the study period; California, Texas, Ohio, New York, Illinois, Louisiana, and Michigan accounted for almost half of the total.
An average of 2,550 were killed or injured each year.
Incidents were most frequently reported for chemical manufacturing and fuel companies. Seven other industry sectors, however, experienced at least 5,000 incidents each during the period studied.

Similar analysis from Wharton School researchers shows that from 1994 through 1999, these accidents injured nearly 2,000 people and required the evacuation of more than 200,000 nearby residents. Property damage from the 1,913 chemical accidents the industry reported over those five years: $1 billion. What is significant about the study is that the reported years cover time after the 1992 OSHA PSM regulations became final.

One bright spot to the statistics on injuries and fatalities is that while total fatalities reached a 5-year peak in 1998 (the latest year for which statistics are available), the injury rate in the chemical and petroleum industries fell by more than one third from 1989 to 1998.

Are the Process Industries Embracing Chemical Accident Prevention?

AcuSafe readers represent a cadre of safety professionals who care very deeply about process safety issues, but it is difficult determining how representative this group is. One disturbing finding is how few Risk Management Plans have been submitted to EPA compared to the estimated number of facilities who are required to do so. As of February 2000 there were only 14,861 current RMPs in the EPA database compared to the 66,000 that EPA had originally anticipated. Part of this reduction is attributable to changes in the RMP rule after the June 1996 rule was released, most notably:

A stay of the RMP rule as it applies to facilities having more than 10,000 pounds of propane in a process,
Deleting the category of Division 1.1 explosives (as listed by DOT) from the list of regulated substances,
Clarifying that regulated flammable substances in gasoline used as fuel and in naturally occurring hydrocarbon mixtures prior to initial processing are exempted from threshold quantity determinations,
Modifying the definition of a stationary source so that naturally occurring hydrocarbon reservoirs are not stationary sources or parts of stationary sources.

In other areas, however, EPA seems to have at least addressed significant factors that could have reduced the estimated number of regulated facilities further. For example, the original estimate of the number of regulated facilities incorporated the reduction of chemical inventories or the use of unregulated substitutes. It seems unlikely that the low facility submission rates can be attributed entirely to EPA's errors in estimating the number of affected facilities. This could be indicative of a substantial number of facilities that choose to ignore the requirements and may not have an RMP/PSM program in place.

What Causes these Incidents?

Chemical incident statistics are very sketchy with respect to root causes and many reported incidents do not furnish much detail about the cause, but there is some published information that may point us in the right direction. According to the CSB 600K Report:

Among cases where the cause was known, 49% were as a result of mechanical factors, 39% from human factors and just 2% to weather-related phenomena.
Among cases involving mechanical factors, an overwhelming 97% were attributed to general equipment failure; 63% of human factors cases were attributed to human error.

The high rate of general equipment failure among reported incidents suggests that mechanical integrity/maintenance issues are significant and from the human error that training and proper procedures should also be examined. Without giving everything away just yet, AcuSafe's PSM Practices survey corroborates the CSB findings; mechanical integrity and proper operating procedures are by far the areas that most concern our participants. (Please take the time to complete the survey; results will be released next month, but we would like to see a few more submissions). It would be valuable if the CSB or some other group compiled accident information that touched on the root causes than the anecdotal evidence otherwise available.

Just a Few Bad Apples?

One phenomena that should be considered is that it is not fair to single out specific industry sectors, even those like the petroleum and chemical industries, which are responsible for more incidents than other industries. It could be that there is great variation within industries and that there needs to be greater scrutiny for the specific facilities that have ongoing issues. Again, this is not something that I am aware has been measured directly (e.g., 20% of facilities account for 90% of accidents), but there is evidence to suggest there is great variation within industry groups. For example, according to the American Petroleum Institute (API) 1999 Process Safety Performance Measurement Report, which compiled voluntary safety information from 46 refineries in the U.S., 21 (45%) reported no incidents in 1998, while those that did report at least one incident reported an average of 3.4 incidents in a single year. Clearly a great number of facilities are doing something right and the facilities with consistent issues have something to learn from them.

This editorial is certainly not exhaustive on the debate surrounding chemical accidents. Over the months, AcuSafe readers have shared their enthusiasm and confidence in their safety programs, while others have listed a laundry list of reasons why their programs are not functional or could be improved. Ultimately, the educational process is ongoing and it is hoped that we can learn from each other in creating effective process safety programs that reduce the chance of serious accidents and create more healthful conditions for workers. In coming months, AcuSafe will be examining the PSM elements that our readers have selected as needing the most improvement and creating articles with tips for improving those areas. Stay tuned!