Safety Regulations for Plants Storing Lethal Compressed Gas - Research Paper Example

A needed update to OSHA’s safety standards for compressed (Toxic) gas Abstract A series of three accidents occurred over a 33 hour period on January 22, 23 in the year 2010 at the DuPont Corporation’s Belle West Virginia, chemical manufacturing plant. A 58 year old worker died from exposure to leaked deadly Phosgene gas due to rupture of a braided steel hose connected to a1 ton capacity tank containing Phosgene. The accident occurred due to a series of preventable shortcomings, including the failure to maintain the integrity of the mechanical hose containing the deadly Phosgene gas. This incident brings about the need to revise on the OSHA safety standards for compressed gas especially for plants making use of highly toxic gases like Phosgene. The measures that can be adopted to bring about an improvement in the OSHA safety standards are discussed below. Existing OSHA standards The existing standards for safety regulations in relation to plants storing lethal compressed gas are according to the Department of Transportation (DOT) hazardous materials regulations 49 CFR parts 171-179 incorporated into the Occupational Safety and Health Administration (OSHA) regulations as a part of the OHSA regulation 29 CFR 1910.101(a) (Department of Labor, 1970) and other applicable standards. The standards require that the operators/employers determine the safety of the compressed gas cylinders under their control in relation to the mechanical integrity by visual inspection. Based on the service of the material in cases where a visual inspection alone is not enough it is best to keep a constant check on the mechanical integrity of the material used to contain the hazardous compressed gases. Periodic retesting and reinspection of the cylinder is required every five years. 49 CFR 173.34(e) specifies the required criteria to be included in the periodic retest which includes both an internal and external visual inspection plus testing with suitable apparatus based on the type of cylinder and compressed gas held by the cylinder. Safety release devices are a must in compressed gas containers like gas cylinders, portable tanks and cargo tanks. The pressure relief devices must be installed and maintained in accordance with the compressed gas association pamphlets available with OSHA. The general industry standard for compressed gas is adopted by OSHA from other regulations like DOT and it has its own set of standards like the OSHA 29 CFR1910.101 (Department of Labor, 1970) standards. These standards are not exhaustive and they need to be updated. The standards have not been changed over a period of 40 years, while the industries and gas plants as in the case of the DuPont plant have undergone major changes in the method of operation owing to advancements in technology. The 29 CFR 1910.101(b) (1970) standard deals with the compressed gases in areas like in-plant handling, storage and how the compressed gases are utilized in gas cylinders, portable tanks, rain tank cars or motor vehicle cargo tanks. They have to be in accordance with the compressed gas association pamphlet P-1-1965. The gases are not to be stored inside flammable materials or flammable cabinets. The Hazard communications standards require that the employees receive training in relation to the possible hazards while handling the equipment containing the hazardous gases and the measures to protect them from the hazard. The existing standards do not cover modern gases like Phosgene which was the cause of the accident at the DuPont plant. The OSHA is an agency of the department of labor and it was created to assure that all employees in the nation of the United States have healthful and safe working conditions. All companies and industries are required by OSHA to comply with the following general duty clauses namely, Maintain conditions and adopt practices that are necessary and appropriate to protect workers on the job while on duty. Be familiar with all standards that are applicable to the establishment and take the necessary steps to comply with them. Make sure the employees have and use protective equipment while at work as a safety practice. OSHA acts when problems related to safety are recognized prior to their happening by the employees, when there is a hazard, when the hazard might lead to fatal injuries to the employees, when the hazard is found to be correctable. Also OSHA has developed separate procedures for high risk industries like mechanical and chemical industries. Major hazards covered under the OSHA regulations at present are toxic substances, harmful physical agents, electrical hazards, fall hazards, hazardous waste, fire and explosion dangers, infectious waste, dangerous atmosphere, machine hazards and confined spaces (Department of Labor, 2000). The list is not exhaustive and highly toxic gases which are new to the industry like phosgene are not included in the safety guidelines designed by OSHA. Thus, there is a need to revise the OSHA taking into consideration the advanced technological methods used and include more methods to protect the employees from hazardous gases used in the plants. The causes of the accident Three consecutive accidents in the month of January, 2010 related to release of hazardous gases within a span of a week lead to investigation from Chemical Safety Board (CSB) at the DuPont Plant located at Belle, West Virginia, United States of America. The three harmful gases released due to the three accidents were methyl chloride, fuming sulfuric acid (oleum) and the deadly phosgene. On January 23, 2010 a veteran Carl Daniel Fish, 58 years old was exposed to highly toxic phosgene and he died the following day after being admitted in a critical condition at a hospital. The phosgene gas got sprayed on his chest and face due to a faulty hose pipe. A braided steel hose connected to a 1 ton capacity phosgene tank suddenly ruptured and the operator was exposed to the harmful gas. The fatal phosgene release came after two other accidents in the plant detected on January 22, 2010 which included a release of chloromethane from the plant’s F3455unit, and there was also a release of spent sulfuric acid at the plant (CSB, 2010). The chloromethane release remained undetected for several days. The plant announced shut down of a number of process units over the weekend for a complete check up process. The root causes that lead to the three accidents at the plant are negligence on the part of the management to impart knowledge on the safety standards to the staff at work in the plant, lack of suitable alarm equipments, the inspection of the pipes and the cylinder were not done manually at the plant and it was done by a software program. Safety management or safety performance is a must in container stevedoring operations and through hierarchical regression analysis it has been found that safety concern, safety motivation and supervisors’ safety management are all related to a positive safety performance. Safety management procedures must be stressed by the management and this is possible only if strict rules and regulations are brought about by OSHA. The DuPont management was found to have approved a design for rupture alarm system at the containment unit where methyl chloride was stored. The system was not completely reliable as it did not inform the operators about release of methyl chloride from the storage unit on January 22, 2010 at 5:02 am. Methyl chloride is flammable and over 2,000 lbs of methyl chloride was released from the plant for five days before the leak was identified. Oleum was released due to corrosion under the insulation layer in a pipe carrying oleum on January 23, 2010, 7:03 am The phosgene gas release incident which occurred on January 23, 2010, 1:45 pm was the most destructive accident as one operator was killed due to the negligence on the part of management in relation to safety measures at the DuPont plant (CSB, 2010). The hazard awareness program at DuPont plant was insufficient and the operating personal were not aware of the hazards associated with trapping liquid phosgene in transfer hoses. The maintenance software program was not strong and required no authorization to make changes to the program. Also it lacked the required software and procedure to notify respective authorities in case of a repair in the pipes and storage system. There was no backup process to initiate timely change on the hose pipes. The reporting process was not up to the OSHA standards and the incident was not brought to the immediate attention of the plant supervisors and managers. There were no dedicated radio or telephone system in the premises of the DuPont plant and no emergency notification process was available. Timely and quality information was not provided to emergency responders due to lack of communication resources. According to the CSB report, DuPont was advised to revise the safety practices it followed. Updates to be carried out in the OSHA standards There is need to update the existing OSHA standards as the standard is ancient, developed in 1970 and it has not been totally revised ever since. The compressed gas safety standards must be updated to include modern safeguards for toxic gases like phosgene. Improved safeguards include secondary enclosures for units storing and using phosgene, mechanical ventilation systems, emergency phosgene scrubbers and automated audible alarms in order to avoid cases similar to the phosgene leak incident at DuPont. The OSHA 29 CFR 1910.101 (Department of Labor, 1970) standard for compressed gas, Process Safety Management (PSM) requires the employees to follow the required safety regulations to prevent catastrophic accidents caused due to such harmful chemicals. The OSHA standard deals with safe handling of compressed gases in containers in accordance with the CGA pamphlet p-1 1965. The current version of the CGA pamphlet p1 2008 is more comprehensive than the 1965 version that has been adopted by OSHA. There are only 13 poisonous gases listed in the 1965 version where as the current 2008 version lists 82 chemicals to be hazardous. If OSHA had adopted the current version of CGA p-1 pamphlet then DuPont would have been more accountable for the phosgene release incident. The OSHA 29 CFR 1910.101 general industry standard for compressed gases must be changed so that facilities and plants handling the toxic materials incorporate provisions similar to those found in 2010 edition, section 7.9, toxic and highly toxic gases in the National Fire Protection Association (NFPA). The changes must be made in relation to the safety standards followed and new methods for improved safety must be followed which includes the following; Enclosures Ventilation and treatment systems Interlocked failure safe shutdown valves Gas detection and alarm systems Piping system components Secondary layer of protection on the hose pipes carrying the toxic gases Appropriate measures have to be taken by OSHA to minimize the exposure of workers to hazards while handling highly toxic gases from cylinders and regulators, gages, hoses and the appliances. The OSHA managers, compliance officers and OSHA state personal involved in implementing the safety measures must make sure the regulated parties conform to the 29 CFR 1910.119 process safety management standard. At the DuPont plant many such standards were found to be violated and heavy fines were levied for lack of safety measures to DuPont chemical plant. The recognized and generally accepted engineering practices must be made as good as the industry practice codes and standards required by the following standards; NFPA 55 – compressed gases and cryogenic Fluids code (2010) The piping and storage related requirements for harmful toxic gases and fluids are discussed in detail in the updated 2010 code. CGA P-1 safe handling of compressed gases in containers (2008) The basic rules for safe handling and regulations to be applied in plants using compressed gases are listed. The earlier version of Compressed Gas Association (CGA) is included in OSHA. CGA E-9 standards for flexible, PTFE-lined pigtails for compressed gas services (2010) The standards for hoses carrying the compressed harmful gases made of stainless steel. Braided and PTF lined pigtails of a nominal inside diameter of 0.25 inches are listed here. ASME B31.3 Process Piping (2008) The piping requirements related to the material used, design, fabrication, assembly, examination, inspection and testing are listed out in the American Society of Mechanical Engineers (ASME) standard. Proper and adequate safety measures can be enforced on the organizations, plants and other facilities dealing with harmful toxic gases only if proper amendments are made to the existing OSHA standards for compressed gases. Bibliography Occupational Safety and Health Administration. Hazard Communication Guidelines for Compliance (2000). OSHA 3111. Washington, D.C.: U.S. Department of Labor. Occupational Safety and Health Standards. Hazardous Materials. Compressed gases (1975). Washington, D.C.: U.S. Department of Labor, 1975. U.S. Chemical Safety and Hazard Investigation Board, (January, 23, 2010) “DuPont Investigation”. Read More