the editorial from the latest issue of the Safety & Health News
newsletter from the American Institute of Chemical Engineers Safety and
aware of the T2 Labs explosion in Florida in 2007. There's a good CSB
video on the event at the URL at the bottom of this note.
Reactive Hazard Management
It has been nearly eight years since the U. S.
Chemical Safety and Hazard Investigation Board (CSB) issued the results
of its hazard investigation into reactive chemical incidents with the
report entitled Improving Reactive Hazard Management. The investigation
reported that over a twenty year period there were 167 serious incidents
that involved chemical reactivity in the United States resulting in 108
fatalities. These numbers do not include the many incidents that are not
reported. Some things have been done to decrease the occurrence of
reactive chemical incidents, but reactive chemical incidents continue to
occur with regularity. I count 12 serious reactive chemical incident
investigations completed by the CSB since the completion of the hazard
investigation. This is just the tip of the iceberg.
chemical incidents are not reported and the CSB can only investigate a
small fraction of the process safety incidents that are reported.
According to the CSB web site only 60% of the recommendations from the
CSB report have been closed. The most important closed recommendations
are the inclusion of the definition of reactive chemical incidents in
the EPA Risk Management Plan (RMP) regulation and the completion of the
Essential Practices for Managing Chemical Reactivity Hazards concept
book by The Center for Chemical Process Safety (CCPS). This book is
publically available on the OSHA web site. Recommendations to improve
the OSHA PSM standard regarding reactive hazards are still open,
although industry should improve reactive hazard management because it
is good business and the right thing to do, not just because the
regulations require compliance.
The CSB found that over 90% of
the reactive chemical incidents that occur are the result of known
chemical hazards documented in publically available literature. We know
that even eight years later, people who need to know about reactive
hazards are not getting the information they need. One recent incident
investigation has resulted in another significant recommendation by the
CSB regarding the management of reactive chemicals.
December 19, 2007, four people were killed and 13 others were
transported to the hospital when an explosion occurred at T2
Laboratories Inc. during the production of a gasoline additive called
methylcyclopentadienyl manganese tricarbonyl=94
recommendations were offered by the CSB.
American Institute of Chemical
=95 Work with the Accreditation Board for
Engineering and Technology, Inc. to add reactive hazard awareness to
baccalaureate chemical engineering curricula requirements.
all student members about the Process Safety Certificate Program and
encourage program participation.
Accreditation Board for
Engineering and Technology, Inc.
=95 Work with the American Institute
of Chemical Engineers to add reactive hazard awareness to baccalaureate
chemical engineering curricula requirements.
actively working with ABET to adopt these recommendations. By including
reactive hazard awareness in the undergraduate chemical engineering
curriculum, there is a better chance that future chemical engineers will
identify reactive hazards before they become incidents.
Reactivity Management Round Table (RMR), which began with a meeting
organized by CSB to address the management of reactive hazards, was
initiated by CCPS in 2003. The RMR had 100 members with about 40 active
members when it was initially organized. Over the years active
participation in the RMR has decreased. I was at the last meeting in San
Antonio where there were only about ten members of the RMR present. I
interpret this lack of support a sign of complacency by the industry on
the reactivity management issue. The RMR continues to work on the
reactive chemical issue. With support from the RMR, the National Oceanic
and Atmospheric Administration (NOAA) has done an excellent job keeping
its Chemical Reactivity Worksheet on its web site current. The Chemical
Reactivity Worksheet is a free program that can be used to find out the
about the reactivity of substances or mixtures of substances. The data
base contains reactivity information for more than 5,000 common
The most exciting project supported by the RMR is
the Reactivity Evaluation Software Tool (REST) which is presently under
development. The primary objective of REST is to assist all users,
especially small to medium size companies, to identify chemical
reactivity hazards associated with their chemical processing and support
operations. Once the tool is available, the challenge is to get people
who need it to use it. REST should be available to users by the end of
2010. CCPS is also offering to the industry basic training on process
safety including managing reactive hazards in its new training course
entitled Process Safety Boot Camp.
There are tools to manage
reactive hazards; we just need to use them!