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.