Even though it's stretched very thin due to limited personnel and severe budget cuts, the U.S. Chemical Safety and Hazard Investigation Board (CSB) continues every day to carry out its mission of trying to make processes safer and prevent people from being injured. So far, it's conducted 800 root-cause analysis investigations since it was founded in 1998, and it's achieved a remarkable 78.8% compliance rate along the way.
"We only have 20 people in Washington, D.C., and 20 people in Denver, Colo., so we can't possibly investigate everything that happens," said Manuel "Manny" Ehrlich, CSB board member. "When Deepwater Horizon happened in 2010, U.S. Rep. Henry Waxman was able to add $2 million to our budget over six years to help us conduct our investigation, but he eventually left Congress.”
Ehrlich presented the opening keynote address on Sept. 18, the first day of the NovaTech Automation Summit 2017 in Baltimore, Md.
Despite its past and present setbacks, Ehrlich reports that CSB has defined five "Drivers of Critical Chemical Safety Change" that are presently needed:
- The U.S. Occupational Safety and Health Administration combustible dust standard and its organizers have long been trying to settle on its precise definition, but Ehrlich adds that many users have already been implementing its useful principles as if it was a standard;
- Modernization of U.S. process safety management regulation, even though much work is still required to make it happen;
- Emergency response and planning effort, initiated in 2016 but lacks funding and knowledgeable participants;
- Preventive maintenance best practices and recommendations need to be developed; and
- Safe hot work practices also need to be developed because Ehrlich reports that 25% of incidents in this area involve lack of knowledge by participants.
"Beyond its investigations, CSB focuses on specialized elements of these drivers of critical safety change," added Ehrlich. "One of the challenges we see users face is the conflict between their hierarchy and structure versus human factors issues. There's a lot of potential danger in not knowing what you don't know. For example, many first responders don't know what expansion ratios are. Of course, many people say, 'I don't want to be a chemist,' but we're not asking them to do that. We just want them to have enough knowledge to keep their butts safe."
To help educate operators, technicians, engineers, and managers in the chemical and other process industries, CSB typically turns its investigations into compelling and instructive videos, which can be viewed at its website at www.csb.gov. During his keynote address, Ehrlich focused on two notable incidents, including the Jan. 30, 2007, explosion of a propane tank outside at a retail facility in Ghent, W.V., in which four people died, and the April 13, 2013, fire and explosion of ammonium nitrate at a fertilizer ingredients facility in West, Tex., in which 15 people died.
"We find over and over that operators and other staff have a lack of knowledge, training, and commitment to pay attention to what's going on in their processes," explained Ehrlich. "We say 'don't know, don't go' to stress that people should not enter areas if they don't know how to handle what's going on, so they can avoid becoming part of the problem. Eighty hours of training isn't enough. I have 4,000 hours, and there's a lot going on in many situations that I don't know how to deal with, so it's important to find someone who does."
Ehrlich points out that the West Texas catastrophe was especially problematic and instructive because ammonium nitrate is an oxidizer. This means it has enough oxygen in it to maintain combustion without an outside source of oxygen, and this exacerbated the fire and explosion at the fertilization facility. "Tragically, no one paid attention to the characteristics of this fire," said Ehrlich. "I don't believe regulations will solve everything, but having some rules in place would have really helped this situation, and protected the first responders and the community.”
"About 80% of fire departments in the U.S. are volunteer—that's about 1.2 million people—but there are no federal standards on what they should know and how to train them. When we met with survivors in Texas, one said more water should have been put on the fire, but that wouldn't have helped because of its chemical characteristics. Survivors want to believe that those who died were heroes, but they weren't trained, and that's why it's important to understand about oxidizers and the hazards of ammonium nitrate."