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PAPER W-38 "The Bhopal Tragedy: Its Influence on Process and Community Safety as Practiced in the United States" Ronald J. Willey 1 , Daniel A. Crowl 2 , and Wil Lepkowski 3 1 Professor, Department of Chemical Engineering, Northeastern University, Boston, MA, USA, email: [email protected] , tel: 1-617- 373-3962 2 Professor, Department of Chemical Engineering, Michigan Technological University, Houghton, MI, USA, email: [email protected] 3 Independent journalist, former senior correspondent, Chemical & Engineering News. Reston, VA, USA email: [email protected] Abstract: The chemical accident at 12:45 AM on December 3, 1984 in Bhopal India had a profound effect on the practice of chemical process safety in the United States. Fearing the possibility of similar events occurring in the United States, the United States Congress convened several hearings and investigations into the causes of the disaster. The inquiries focused both on the state of process safety within the US chemical industry and on the readiness of communities located near chemical operations to respond to sudden and dangerous toxic discharges. Of equal significance were concerns over the safety of workers in chemical plants. This paper reviews the major legislative, academic, and industrial changes initiated in the area of process safety after the event, their influence on saving lives, and on improving living conditions surrounding chemical complexes in the United States. Keywords: Bhopal, USA Governmental Response, CCPS, Education, SACHE

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Page 1: PAPER W-38 · Web viewAt the time, MIC’s primary hazard classification by the DOT was based on its flammability. The board concluded: “many questions now unanswered by DOT’s

PAPER W-38"The Bhopal Tragedy: Its Influence on Process and Community Safety as Practiced in the United States"

Ronald J. Willey1, Daniel A. Crowl2, and Wil Lepkowski3

1 Professor, Department of Chemical Engineering, Northeastern University, Boston, MA, USA, email: [email protected], tel: 1-617-373-39622 Professor, Department of Chemical Engineering, Michigan Technological University, Houghton, MI, USA, email: [email protected] Independent journalist, former senior correspondent, Chemical & Engineering News. Reston, VA, USA email: [email protected]

Abstract:

The chemical accident at 12:45 AM on December 3, 1984 in Bhopal India had a profound effect on the practice of chemical process safety in the United States. Fearing the possibility of similar events occurring in the United States, the United States Congress convened several hearings and investigations into the causes of the disaster. The inquiries focused both on the state of process safety within the US chemical industry and on the readiness of communities located near chemical operations to respond to sudden and dangerous toxic discharges. Of equal significance were concerns over the safety of workers in chemical plants. This paper reviews the major legislative, academic, and industrial changes initiated in the area of process safety after the event, their influence on saving lives, and on improving living conditions surrounding chemical complexes in the United States.

Keywords: Bhopal, USA Governmental Response, CCPS, Education, SACHE

1 Introduction

1.1 Bhopal’s Immediate Aftermath: Media Coverage of the Disaster within the USA

News of the disaster reached the front pages of all national news media approximately 36 hours (4 December 1984) after the disaster struck. It became the lead story on the national television and radio newscasts on the same day. The initial New York Times (NYT) headline in the 4 Dec 1984 issue read, “Gas Leak in India Kills at Least 410 in City of Bhopal – 12,000 reported injured – Officials say the fumes came from insecticide plant of U.S.-owned company NYT prominent headlines 2 days before the accident included: “Medication in Chile Termed Essential by US Officials,” and “When Terror Threatens what the U.S. Has Learned.”1 The page one photograph featured King Hussein of Jordan visiting Egypt. However, none of these headlines would cause the stir U.S. public activism similar to the December 4th headline. The “silent majority,” a term to characterize the bulk of the U.S. citizenship’s apparent lack of participation and concern for major events of the day, woke up.

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Many international headlines appear that did not lead to a public outcry or congressional hearings. The event in Bhopal on 3 December 1984 did.

Over the next month at least 50 additional articles appeared in the Times. , Time and Newsweek carried multi-page articles on the accident in their 17 December 1984 issues. Time devoted 10 pages (roughly 1/10th of the entire issue) to the accident. Many publications featured the horrors of the tragedy on their covers. The 17 December Newsweek cover and the magazine’s companion article both expressed what the obvious question of concern to Americans: “Can It Happen Here?

The first news story in Chemical and Engineering News (a biweekly professional publication published by the American Chemistry Society) appeared in its 10 December issue. Headlines were: “Bhopal,”, “India’s Chemical Tragedy: Death Toll at Bhopal Still Rising,” 2 and a week later “India’s Bhopal Disaster: Chemical Mishap Raises Thorny Issues,” 3.

In Business Week’s 17 Dec 1984 U.S. Representative Henry A. Waxman (D-CA), was quoted as saying: "This nation faces a quiet but deadly crisis. The public would not have to live in fear of nearby industrial facilities if the EPA met it s responsibility to assure that everyone in a community is safe,"4 In Business Week’s next issue, said he was considered proposing changes in the Clean Air Act to give the EPA the responsibility for setting standards for chemical plant safety and for overseeing companies’ emergency planning. Waxman and U.S. Representative James J. Florio (D-NJ) scheduled hearings in Charleston, WV for December 14, 1984.5

Meanwhile, Business Week was reporting that labor unions, with strong support from local citizen groups, were leading the drive for Community Right-to-Know legislation. The Reagan administration had been placing low priority on this legislation, despite previous chemical events within the United States that were raising public concern over the dangers of toxic chemicals and dangerous chemical operations. These included the “Love Canal” incident in which toxic chemicals had been into an abandoned canal near which residential housing and schools were subsequently built;6 dioxin contamination at Times Beach, Mo,7 Agent Orange exposure of Vietnam Veterans,8 and a release in Linden, New Jersey that dispersed malathion over a 20-mile area as far east as Staten Island. That accident caused approximately 100 people to seek emergency treatment in local hospitals.9

The tragedy of Bhopal crystallized public opinion and catalyzed the enactment of further legislation within the United States towards the chemical producing community to become more responsible to its employees and citizens living in chemical surroundings.

2 C&E News, 10 December 1984, p5 and 6.3 C&E News, 17 December 1984, p5 and 6.4 Business Week, 17 December 1984, p32.5 Business Week, 24 December 1984, p60-1.6 http://history.sandiego.edu/gen/nature/lovecanal.html accessed 10 July 2004.7 http://www.epa.gov/history/topics/times/02.htm accessed 10 July 20048 Business Week, 24 December 1984, p60-1.9 Newsweek, 17 December 1984, p44.

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2 Background

2.1 USA Governmental Controls in Place at the Time of the Accident

Widespread environmental consciousness in the U.S. began in the early 1960’s with publication of the book. “Silent Spring,” written by ecologist Rachel Carson”10,11 The U.S. Congress soon began debating with increased earnestness legislation to protect human health and the environment against toxic substances. Table 1 presents a time line of major events in the United States that contributed to the enhancement of environmental protection and process safety.

The primary regulatory agency for the environment in the U.S. is, the Environmental Protection Agency (EPA), established in June, 1970, through the consolidation of several agencies existing at the time.12 Most states also had local environmental protection agencies in place, but with widely differing degrees of muscle. Their work focused mainly on water pollution problems and with the reduction of airborne nitric oxide and sulfur dioxide emissions from stationary and mobile sources.

One of the predominant pollution control issues of the time was the switch from non-catalytic emission controls for passenger vehicles to catalytic controls to reduce emissions of nitric oxide, carbon monoxide, and hydrocarbons. Stationary sources such as electric power plants also came under pressure to reduce sulfur emissions from coal by switching from high to low-sulfur coal and to #6 oil and natural gas. During that time, EPA was regulating only eight toxic pollutants and developing standards for several others of immediate priority. Methyl isocyanate (MIC) was not on that list.13

Rules and regulations for the protection of plant employees were also becoming established after passage in 1970 of the Occupational Health and Safety Act (OSHA)14 which created that Occupational Safety and Health Administration. Early OSHA programs concentrated on in-plant accidents and exposures to toxic chemicals. At the time, OSHA had set permissible exposure limits (PEL) for various chemicals. MIC’s PEL was set at 0.02 ppm averaged over eight hours,15 a value that was and still is one of the lowest for any chemical on the list. It was clear that MIC at that early time was seen as a highly lethal toxic chemical.

OSHA’s Hazard Communication standard, issued in November of 1983, required that companies provide information to their employees on hazards in the work place by means of labels, material safety data sheets (MSDS), and thorough training programs.16 Labeling and MSDS requirements were to become effective on 25 Nov 1985.

The regulatory impact of the Bhopal disaster strongly influenced the work of EPA and OSHA and required a substantial amount of coordination and communication between the two agencies. EPA has authority for offsite consequences while OSHA’s responsibility is directed toward on-site regulation.17 One issue, still not resolved, is whether exposure standards for workers should be any lower than EPA’s standards for the public that resides near chemical operations.

The U.S. Department of Transportation (DOT) was also given considerable responsibility for public protection against chemical leakages from trains, trucks, and aircraft.

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DOT developed a signage system for placarding transportation units that transport hazardous chemicals around the United States (known as the DOT hazard identification and classification system). At the time of the accident, these placards concentrated on flammability of MIC, and did not note MIC’s hazard as a toxicant.18

Another key law in the control of toxic chemicals was the Toxic Substances Control

Act (TOSCA), signed by President Ford on 11 October 1976.19 This act gave the EPA the ability to track the 75,000 industrial chemicals produced or imported into the United States. EPA repeatedly screens these chemicals and can require reporting or testing of those that may pose an environmental or human-health hazard. EPA can ban the manufacture and import of those chemicals that pose an unreasonable risk.20

On 21 October 1976, related legislation was enacted in the form of the Resource Conservation and Recovery Act (RCRA). That law required EPA to identify and publish a list of hazardous wastes and to set standards for the handling, transportation, and ultimate disposal of such wastes. States were to establish regulatory programs subject to EPA approval. Civil and criminal penalties were established for violation--up to $25,000 per day of noncompliance, a year in prison, or both.21 Essentially, RCRA was the first Federal legislation to control disposal of chemicals into open dumps. Producers became responsible for the ultimate disposal of their wastes, and for transporting and disposing of them according to EPA standards. Hazardous waste transporters and treatment, storage and disposal facility operators were also subject to the new regulations.22

Three related acts that became lumped under Superfund legislation completed the major lawmaking in the pre- and post- Bhopal period. They were the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the Superfund Amendments and Reauthorization Act (SARA), and the Emergency Planning and Community Right-to-Know Act (EPCRA).23 At the time of the Bhopal accident only CERCLA (1980) had been enacted. CERCLA provided the funding needed to clean up hazard waste sites across the United States, 114 of which were identified by the end of 1981).

2.2 U.S. Chemical Industrial Efforts in Loss PreventionThe chemical industry has a very active group of loss prevention specialists working

under the auspices of the American Institute of Chemical Engineers (AIChE), New York, NY. This group organized the first Loss Prevention Symposium in 1967 and has met annually ever since24. The 39th Loss Prevention Symposium will be held in Atlanta Georgia this Spring 2005.25 Many of the papers are published in the AICHE Safety and Health Division journal Process Safety Progress.

2.2.1 DIERS The Design Institute for Emergency Relief Systems, DIERS, (part of the AIChE) was

formed in 1976 in response to an alarming series of reactor explosions in North American chemical plants. The explosions were occurring despite the installation of protective relief systems that were regarded as acceptable at the time. One recorded case history involved the explosion of a styrene polymerization reactor in 1966 in Montreal.26 The sight glass in the relief system was unable to tolerate the pressure developed during two-phase relief. Concern had been growing in the process safety community, however, that the design of emergency relief systems needed improving

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DIER was originally conceived as a consortium of companies to develop methods for the design of emergency relief systems to reduce the frequency, severity, and consequences of pressure producing accidents Over 200 companies that comprise the DIERS Users Group and cooperatively assimilate, implement, maintain and upgrade the DIERS methodology, supporting research, holding annual meetings, and preparing publications. Of particular interest is the prediction of two-phase flow venting and the applicability of various sizing methods for two-phase vapor-liquid flashing flow. DIERS has spent $1.6 million to investigate the two-phase vapor-liquid onset/ disengagement dynamics and hydrodynamics of emergency relief systems. 27

2.3 USA Public Response to the Bhopal IncidentThe first recorded public meeting in response to the accident in Bhopal occurred one

week after the tragedy, on Sunday evening, Dec 9, 1984, in Institute, West Virginia (WV). Institute was home to one of the Union Carbide’s largest chemical plants. At the time, the plant was the only U.S. facility producing, MIC. The Institute community demanded to know how susceptible they were to a tragedy on the scale of the Bhopal release. Carbide by then had stopped all production and shipment of MIC pending various safety checks involving the OSHA, EPA, and state health authorities.28 The meeting gave Institute residents little assurance of their safety once MIC production would be resumed.

2.4 First Congressional Sub Committee HearingsThe first Congressional hearing on Bhopal and chemical safety was held on 12

December 1984, 9 days after the accident. It was convened by the House Education and Labor subcommittee on Health and Safety and appearing before it was OSHA Acting chief, Robert A. Rowland. The subcommittee told Rowland that the situation at Carbide’s Institute plant constituted an “emergency” and they spent the day hearing about what was being done to protect U.S. workers from MIC and other dangerous chemicals.29

On 14 December 1984, Representative Henry Waxman (D-CA) and Representative James J. Florio (D-NJ) held hearings in Charleston WV, some ten miles from Institute. Warren M. Anderson, Chairman of Union Carbide, and several other Union Carbide representatives testified. Representatives of the general public also testified including Perry Bryant, deputy director of Citizens Action, a public interest group in Charleston. …

The upshot of those initial hearings was to reveal to the public that much work needed to be done to prepare for the possibility of serious accidents at chemical operations near them. Indeed, a national debate at all levels of government ensued, involving to an unprecedented degree the combination of public officials, citizen action groups, industry, and the public at large. A revolution was occurring in the toxic safety environment in the United States.

3 Methods

3.1 Federal Governmental Legislation Influenced by the Accident in Bhopal

3.1.1 EPA Right-to-know and SARA

The Bhopal accident served to as a reminder that things could go badly wrong wherever chemical were processed, produced, and stored. Congress was quick to call

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hearings. Environmental and related legislation that was stalled in Congress began to flow. The first results were the Superfund Amendments and Reauthorization Act (SARA) signed by President Reagan on the 17 October 1986 and the related Emergency Planning and Community Right-To-Know Act (EPCRA). Under EPCRA owners or operators of facilities were required to prepare or make available Material Safety Data Sheets (MSDS) for hazardous chemicals under the Occupational Safety and Health Administration regulations. An MSDS for each hazardous chemical on site or a list of MSDS chemicals was to be provided by 17 October 1987 to each state’s emergency response commission, to the local emergency planning committee, and to the fire department with jurisdiction over the facility. The first-year minimum requirement was for companies to report hazardous chemicals that were produced, used, or stored at levels above 10,000 pounds, or 4,540 kg. Materials designated "extremely hazardous substances" because of their importance in terms of planning has a reporting threshold of 500 pounds (227 kg) or the threshold planning quantity, whichever was less. The rule also consolidated the originally proposed 23 health and physical categories into five: acute health hazards; chronic health hazards; sudden release of pressure; reactivity as physical hazards; and flammability as physical hazards.30

Essentially, SARA required plants that produced or used chemicals to make public any information that related to possible threats to the communities near them. The communities for their part were required to establish so-called Community Action Emergency Response (CAER) programs with the aim of ensuring that fire, police, and other safety services were quickly informed about the nature of any leak and that plans would be put in place for protecting the community from possible toxic discharges.

3.1.2 Toxic Release Inventory (TRI)In 1987 U.S. Environmental Protection Agency (EPA) required companies to submit

toxic release inventories (TRI) as part of the “community right to know” philosophy of the legislation. Since 1988, U.S. Companies have reported TRI data to EPA annually, which the agency reviews and makes available to the public. The information contains releases in pounds via air, water, and land on an annual basis. Access to this information is available through a number of web sources including the American Chemistry Council’s Responsible Care©31 (discussed below in more detail).

3.1.3 Clean Air Act Amendment of 1990President George H.W. Bush signed the Clean Air Act (CAA) Amendments on 15

November 1990. Included in these amendments were a number of authorizations related to process safety and the environment. . The CAA established regulations and programs to prevent accidental chemical releases and to minimize the consequences of such accidental releases when they occur. These regulations and programs were a direct outcome of response to the accident in Bhopal and related incidents that had occurred in the United States.

The CAA Amendments of 1990 established:

Section 304. a chemical process safety management (PSM) standard to protect employees from hazards associated with accidental releases of highly hazardous chemicals in the workplace. It requires facilities having more than a threshold quantity of certain highly hazardous chemicals listed by OSHA to implement and document an accident prevention program.

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Section 112(r)(7) regulations and guidance to prevent and detect accidental releases and to require facilities with more than a threshold amount of a hazardous chemical to develop and implement risk management plans (RMPs) including off-site consequences of worst-case releases.

Sections 112(r)(3), (4) and (5). a list of at least 100 substances that pose the greatest risk of causing death, injury, or serious adverse effects to human health or the environment from accidental releases along with a threshold amount for each substance.

Section 112(r)(6) a Chemical Safety and Hazard Investigation Board (CSB) to investigate accidental releases and advise EPA and the Department of Labor, Occupational Safety and Health Administration (OSHA) on the efficacy of their regulatory programs.

The Process Safety Management (PSM) Standard is the most comprehensive legislation directly affecting the chemical industry as a result of Bhopal. The full rule, issued on 24 February 1992, is entitled “Processes Safety Management of Highly Hazardous Chemicals; Explosives and Blasting. Table 2 is an exhaustive, yet incomplete, listing of the various paragraphs in 29 CFR 1910.119. This is list presented in this manner to impress upon the reader the seriousness that the U.S. government and the public placed on the control of future chemical and related industrial accidents.

The purpose of this rule was to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. These releases may result in toxic, fire or explosion hazards. PSM rules involve any chemical at or above a specified threshold quantity (TQ) as provided in a list.32 MIC’s TQ is 250 lbs (114 kg). Hydrocarbons used for fuel purposes are exempted.

Several items in Table 2 list were formally self-regulated by the industry. Before PSM, companies could decide their own process safety policy within the plant and corporation with few guidelines. For example, “management of change” was previous determined within a company. Policies varied tremendously from plant to plant. If a pump should fail, a local foreman could change out a pump with another type with no formal hazard review. Under the new rules, this change out is not allowed without a hazard review of the consequences unless it is with a replacement “in-kind” (the identical pump is swapped in). Previous to this rule, a number of process accidents occurred where a process change was made with very little documentation of the consequences.

3.1.3.1 EPA-RMPUnder the Clean Air Act Amendment of 1990, the EPA initiated a Risk Management

Plan (RMP) with the final rule issued in June 1996.33 If the process is subject to an OSHA PSM, portions of the PHA conducted can serve as the initial process hazard analysis for EPA purposes. However, the EPA RMP considers only offsite impacts while the OSHA PHA considered only onsite impacts.

A well-done PHA identifies all failure scenarios that could lead to significant exposure of workers, the public, or the environment. The only issue that requires further consideration

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is whether protection measures that are adequate for worker safety are inadequate for public and environmental safety. For flammables, any scenario that could affect the public almost certainly would have the potential to affect workers; measures taken to protect employees likely will protect the public and the environment. For toxics under PSM, however, a loss of containment by venting toxic vapors to the outside air may not affect the employees, but may affect the public and the environment. In each circumstance, a PHA should define how the loss of containment could occur. However, for the RMP, the PHA team should reassess venting as an appropriate mitigation measure.

The RMP must analyze the worst-case “distance to endpoint”. It is the distance intended to provide an estimate of the maximum possible area that might be affected by a catastrophic release from a facility. It is intended to ensure that no potential risks to public health are overlooked, but the distance to an endpoint estimated under worst-case conditions need not be considered a “public danger zone.” Mathematical models can be used to analyze the worst-case release scenario as defined in the rule. When estimating the worst case release distances, the rule does not allow facilities to take into account active mitigation systems and practices that could limit the scope of a release. Specific systems (e.g., monitoring, detection, control, pressure relief, alarms, and mitigation) may limit a release or prevent the failure from occurring.

Congress mandated that RMPs be made available to the public, except for any Confidential Business Information (CBI) they may contain. Public access to the Off-Site Consequence Analysis (OCA) sections of RMPs is restricted, but the public may still read, if not copy, these sections.

EPA originally planned to place the RMP information system on the Internet for easy access by the public, as well as by governments, based on the recommendation of many members of a Subcommittee created under the Federal Advisory Committee Act. However, concerns were raised that Internet access to a large, searchable database of OCA results could be used as a targeting tool by terrorists and other criminals. Although EPA subsequently decided not to place the OCA sections of RMPs on the Internet, new concerns were raised that recent amendments to the Freedom of Information Act (FOIA) would compel EPA to release this information in electronic format. Congress responded by passing the Chemical Safety Information, Site Security and Fuels Regulatory Relief Act (CSISSFRRA), which the President signed on August 5, 1999.

3.1.3.2 Chemical Safety BoardThe U.S. Chemical Safety Board (CSB) was authorized by the Clean Air Act

Amendments of 1990 and became operational in January 1998. The Senate legislative history states: "The principal role of the chemical safety board is to investigate accidents to determine the conditions and circumstances which led up to the event and to identify the cause or causes so that similar events might be prevented."34

Congress gave the CSB a unique statutory mission and provided in law that no other agency or executive branch official may direct the activities of the Board. Following the successful model of the National Transportation Safety Board (NTSB) and the Department of Transportation (DOT), Congress directed that the CSB's investigative function be completely independent of the rulemaking, inspection, and enforcement authorities of EPA and OSHA. Congress recognized that Board investigations would identify chemical hazards that were not addressed by those agencies.Error: Reference source not found

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Although the Board was created to function independently, it also collaborates in important ways with EPA, OSHA, and other agencies.Error: Reference source not found Two other separate papers are planned for the conference by the CSB and will cover their role and history in more detail.

3.1.4 NTSB-SignageAfter the accident in Bhopal, the National Transportation Safety Board (NTSB) urged

the Department of Transportation to give priority attention to re-examining its hazard identification and classification system. At the time, MIC’s primary hazard classification by the DOT was based on its flammability. The board concluded: “many questions now unanswered by DOT’s hazard identification and classification system must be answered to determine which flammable liquids, Class B poisons, corrosives, and other materials can pose life threatening hazards during accident conditions as we now know MIC can”35 An outcome from this is that all transportation vehicles must have NTSB diamonds clearly shown on their vehicles. These diamonds now have differing backgrounds depending upon the severest consequence (toxicity, reactivity, or flammability) that the material processes.

3.2 Industrial Sector ResponsesIndustrial responses evolved collectively through various trade associations. The most

notable is the Responsible Care© program initially started under the Chemical Manufactures Association (CMA)36 which later became the U.S. American Chemistry Council (ACC). The following information is modified from the ACC website.37

“Since 1988, members of the American Chemistry Council (ACC) have significantly improved their environmental, health, safety and, in recent years, security performance through the Responsible Care initiative. Participation in Responsible Care is mandatory for ACC member companies, all of which have made CEO-level commitments to uphold these requirements:”

Measuring and publicly reporting performance; Implementing the Responsible Care Security Code; Applying a modern management system to achieve and verify results; and Obtaining independent certification that a management system is in place and

functions according to professional standards.

“Responsible Care companies use a modern management system to drive environmental, health, safety and security performance. This approach provides a rigorous and structured framework for assessing a company’s needs, setting specific goals and sharing progress and activities with the public. A key component of the management system is mandatory certification by independent, accredited auditing firms.”

The Responsible Care web siteError: Reference source not found offers links to performance data (by company and by the aggregate) in the areas of the environment (the TRI discussed above), process safety (recordable incident rate presented below), security, products, accountability, and economy (research and development expenditures).

Additional initiatives came from other industrial trade organizations such as the Chlorine Institute38, the American Petroleum Institute (API) who initially drafted what was to

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become the OSHA PSM39, and National Association of Chemical Distributors (NACD) who initiated Responsible Distribution40.

Many U.S. corporations place extensive emphasis on process safety as can be witnessed in corporate annual reports. An example is Dow Chemical’s 2003 Annual Report41. Environmental Health & Safety (EH&S) is mentioned 35 times in this report. This emphasis, in part, is directly related to the accident in Bhopal raising stock holder awareness what negative publicity (and lower of share holder equity) that can result should a chemical accident occur.

3.3 Professional Societies Changes Influenced by the Accident in BhopalThe AIChE took the main lead to initiate stronger commitments to process safety for

the private sector. Founded in 1985, The Center for Chemical Process Safety (CCPS) brings together manufacturers, insurers, government, academia, and expert consultants to lead the way in improving manufacturing process safety.

CCPS and its sponsors are committed to protecting employees, communities, and the environment by developing engineering and management practices to prevent or mitigate catastrophic releases of chemicals, hydrocarbons, and other hazardous materials. The Center’s charter has the following goals:42

ADVANCING state-of-the-art process safety technology and management practices. SERVING as a premier resource for information on process safety. FOSTERING process safety in engineering and science education. PROMOTING process safety as a key industry value.

Since 1985, CCPS has published over 80 books and products, held 18 international conferences, and cultivated our Safety in Chemical Engineering Education (SACHE) university curriculum program (discussed in detail below). CCPS published 12 elements of process safety to help companies identify the key tenets of a process safety program. These 12 elements of process safety are listed Table 4. The CCPS recipe for success is collaboration focused on a need. Participants from sponsor companies identify needs, pool their knowledge, and leverage their resources to consolidate industry best practices toward meeting those needs. In the process, they learn from each other and from the world’s experts, benchmark their companies’ programs, and raise the image of the industry as a whole (text adapted directly from43.

3.4 Academic Response Influenced by the Accident in Bhopal44 After its founding in 1985, one of the first projects of the AIChE Safety and Health

Division was to incorporate loss prevention into 6 or 7 major chemical engineering courses taught at the university level. The division asked Tom Carmody, the founding director of the AIChE Center for Chemical Process Safety (CCPS), if a set of problems demonstrating process safety for the core courses could be part of CCPS’s work. He agreed that it would be a good project, but wasn’t sure CCPS could fund it completely. About that time it was learned that there might be some National Science Foundation money available for work. CCPS applied for and received a grant. That was the initiation of the AIChE CCPS Undergraduate Education Committee (UEC). Owen Kubias, then S&H division chair, became chair of the committee.

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The committee drew up a set of criteria for the project and solicited bids from interested universities. The proposal by Reed Welker and Charles Springer from the University of Arkansas was accepted. Two books resulted from this effort. The first book was directed at the students and contained the problem statements and background material on the importance of the problem. The second book was a solution manual for faculty that also included additional supporting materials. The books were published in 1990 and became a best seller for CCPS.

A meeting of the CCPS Undergraduate Education Committee at the AICHE Annual Meeting in Chicago in 1990 was pivotal for the next educational activity of CCPS. It was clear that a more proactive method was required to excite universities about process safety. Joe Louvar, Dan Crowl, and Owen Kubias presented papers at the 1990 Annual Meeting in Chicago on the integration of process safety into the chemical engineering curriculum. While waiting for a late afternoon presentation, Louvar, Crowl, and Kubias conceived the acronym SACHE – Safety and Chemical Engineering Education. The Undergraduate Education Committee also discussed ways to continue the committee’s activities and arrived at the idea of offering teaching materials demonstrating process safety to universities each year for a nominal membership fee. The idea behind SACHE is simple: provide a consortium of member universities that join together to prepare and distribute instructional materials in process safety at minimal cost.

At the Annual Meeting in Los Angeles in 1991, this new program was presented to a meeting of chemical engineering professors. Over 30 schools made an immediate commitment to the SACHE program. Since then, some 125 universities have joined SACHE from within the U. S. and around the world.

The initial focus of SACHE was to prepare teaching modules for use in the chemical engineering classroom. These modules are prepared by industrial and academic contributors under contract from SACHE. The modules are reviewed by the SACHE committee. The purpose of the modules is to provide instructional resource materials for faculty. To date over 40 modules have been prepared and distributed. Earlier modules included slide, lecture and background materials, but more recent modules have replaced the slides with PowerPoint based materials. Table 5 presents a list of these instructional modules.

SACHE has also hosted 7 faculty workshops on process safety (4 at BASF in Wyandotte, MI, 2 at Dow Chemical in Freeport, TX, and one at Exxon-Mobil in Baton Rouge, LA). These workshops consisted of lectures on the fundamentals of process safety, followed by plant and laboratory tours and demonstrations to show how the fundamentals are put into practical application. The faculty are also given a good dose of industrial safety culture, with the hope that this will translate into faculty efforts to meet undergraduate student needs in process safety.

Currently, SACHE is implementing web-based instructional materials that students would use directly.

4 ResultsFigures 1 through 3 were taken from the U.S. Census Statistical Abstracts. Each one

shows declining trends meaning fewer fatalities in manufacturing (Figure 1), fewer deaths in manufacturing per 100,000 (Figure 2), and fewer toxic releases of chemicals (Figure 3). Each figure shows a time lag of about 8 years, but the drops are significant. U.S. Industry is safer.

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As reported directly in Error: Reference source not found, “Chemical accidents continue to impose considerable costs in terms of human lives and health, property damage, and public welfare. Facilities covered by the RMP rule reported that from mid-1994 to mid-1999 there were about 1,900 serious accidents that caused 33 deaths, 8,300 injuries, and the evacuation or sheltering of 221,000 people. These accidents cost the affected facilities more than $1 billion in direct damages and two to four times that in business interruption losses. Almost 80% of these accidents occurred at facilities already subject to the OSHA process safety management standard, which is designed to reduce accidents. These accidents also represent less than 10 percent of all unintended releases of hazardous substances reported to the government during this period.”

4.1.1 Success of the TRIFigure 4 shows a continue drop in toxic releases as time continues. The following is

taken directly from referenceError: Reference source not found

“Given the opportunity, the public uses hazard information to take action that leads to risk reduction. Various segments of the public have strong incentives to use OCA information in ways that reduce risk. For example, there is a broad consensus that national publication of the Toxics Release Inventory (TRI) data by the government, followed by analysis by citizens’ groups and the news media, led to action by industry to reduce emissions. Nationally, reported TRI emissions have fallen 43 percent since 1988, a time in which industrial production has risen 28 percent. Although other factors likely contributed to the decline in emissions, negative press coverage directed at certain facilities appears to have led these facilities to achieve reductions in their TRI emissions.”

The report goes onto point out the importance of public access to the informationError: Reference source not found.“Ease of access to information is important to public use and risk reduction. Data available in paper form on request from state or local agencies are rarely sought. For example, data on the location and identity of hazardous chemicals are requested about 3,500 times a year from Local Emergency Planning Committees (LEPCs). There are about 3,200 LEPCs in the country and about 560,000 facilities subject to requirements to report information on hazardous chemicals to LEPCs. Meanwhile, environmental data on Environmental Defense’s “Scorecard” website are at least 250 times more likely to be reviewed by the public than information from LEPCs. Likewise, early indications are that the meetings which facilities were required to conduct by CSISSFRRA to explain OCA information to the public have drawn very few attendees, even when citizens received individual invitations. In contrast, when industry has gone out to places the public already frequents (for example, a shopping mall) and provided consequence information directly to citizens, outreach and communication about chemical accident risks has been more successful.”

4.1.2 AcademiaRecognition of the importance of process safety to the education of students is

demonstrated by a change in Accreditation Board for Engineering and Technology, Inc. (ABET) criterion for chemical engineering programs in 2000. The criterion was changed by the addition of wording related to safety and the environment in the ABET 2000 criteria

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(initiated in 2001). The criterion for chemical engineering programs in the United States now reads:45

“The program must demonstrate that graduates have: thorough grounding in chemistry and a working knowledge of advanced chemistry such as organic, inorganic, physical, analytical, materials chemistry, or biochemistry, selected as appropriate to the goals of the program; and working knowledge, including safety and environmental aspects, of material and energy balances applied to chemical processes; thermodynamics of physical and chemical equilibria; heat, mass, and momentum transfer; chemical reaction engineering; continuous and stage-wise separation operations; process dynamics and control; process design; and appropriate modern experimental and computing techniques.”

The ambitious CCPS sponsored SACHE program has resulted in two major results. First, over 40 modules have been prepared and distributed to chemical engineering departments for faculty use in instruction of process safety. Second over 150 professors from more than 130 universities have completed the SACHE workshop and have brought their knowledge back to their home universities. Approximately 50 U.S. universities now offer process safety courses. Approximately 10 of these universities have required courses. Many integrate process safety into existing courses, including design, UO lab, and others. Content has also appeared in textbooks for other courses.46

5 ConclusionThe accident in Bhopal had a profound effect within the United States. It resulted in a

substantial change in U. S regulations, the formation of the AICHE Center for Chemical Process Safety, and the formation of the Safety and Chemical Engineering (SACHE) program. . These initiatives resulted in a change in the practice and education of chemical engineers in the U. S.

Certainly lives have been saved. Furthermore, practicing and graduating chemical engineers are much more aware of process safety and environmental issues through profess ional and educational development.

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Table 1. Significant Record of Event Related to Environmental and Process Safety in the United States

Date Process Safety or Environment Landmark1 Jun 1962 “Silent Spring,” by Rachel Carson appears – initiates public concern for

the environment due to overuse of pesticides22 Apr1970 First “Earth Day” 47

9 Jun 1970 Reorganization plans issued by President Nixon – Establishing the EPA29 Dec 1970 Occupational Safety and Health Act (OSHA) of 1970 enacted by the 91st

Congress31 Dec 1970 President Nixon Signs into law the Clean Air Act (CAA)

AIChE establishes the 11 Oct 1976 President Ford approves the Toxic Substances Control Act (TSCA)21 Oct 1976 President Ford approves the Resource Conservation and Recovery Act

(RCRA)28 Dec 1977 President Carter approves the Clean Water Act of 1977.

Dec 1980 Congress authorizes the Superfund: Includes: Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Superfund Amendments and Reauthorization Act (SARA) Emergency Planning and Community Right-to-Know Act (EPCRA)

2 Dec 1984 Accident at Bhopal1985 AIChE establishes The Center for Chemical Process Safety (CCPS)

17 Oct 1986 President Reagan signs the SARA reauthorization act. CERCLA was amended.

9 Oct 1987 EPA Administrator Lee M. Thomas signs the final rule for hazardous-chemical reporting requirements under Superfund Title III, Sections 311 and 312, the emergency-planning and community-right-to-know law. (EPCRA) Requires MSDS to be provided to emergency response personnel. Local emergency planning committees (LEPCs) required.

1987 EPA conducts first “Toxics in the Community,” Toxic Release Inventory (TRI) survey

15 Nov 1990 President Bush signs the Clean Air Act Amendments. 24 Feb 1992 Occupational Safety and Health Administration (OSHA) Process Safety

Management Standard (PSM); (29 CFR 1910.119) appears in the Federal Register

31 Jan 1994 EPA List of Substances and Threshold Quantities for accident prevention program appears in the Federal Register

20 Jun 1996 EPA Accidental Release Prevention Requirements: Risk Management Program (RMP) appears in the Federal Register

1998 Chemical Safety Board is initiated.5 Aug 1999 President Clinton signs the Chemical Safety Information, Site Security

and Fuels Regulatory Relief Act (CSISSFRRA)12 Jun 2002 Congress enacted 29 U.S.C. 669a, to expand the OSHA act to include

"health and safety of workers who are at risk for bioterrorist threats or attacks in the workplace”

47 http://earthday.envirolink.org/history.html accessed 18 July 2004.

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Table 2. Process Safety Management of Highly Hazardous Chemicals. Adapted from 29 CFR 1910 Occupational Safety and Health Standards, Subpart H, Standard Number: 1910.11948 (a)

Main Paragraph

Letter 1910.119

Subparagraph Number and Partial Details

(a) Application

(1) These standards apply to chemicals above the specified threshold quantities of chemicals listed in Appendix A (not presented in this paper) and flammables liquid or gas above 10,000 lbs unless flammables are solely used for fuels. (2) Does not apply to retail facilities, oil or gas well drilling, unoccupied remote facilities

(b) Definitions

Section contains various definitions such as “hot work” etc.

(c) Employee

Participation

(1) Employers shall develop a written plan of action regarding the implementation of the employee participation required by this paragraph. (2) Employers shall consult with employees and their representatives on the conduct and development of process hazards analyses and on the development of the other elements of process safety management in this standard. (3) Employers shall provide to employees and their representatives access to process hazard analyses and to all other information required to be developed under this standard.

(d) Process Safety

Information

(1) Information pertaining to the hazards of the highly hazardous chemicals in the process. This information shall consist of at least the following: (i) Toxicity information; (ii) Permissible exposure limits; (iii) Physical data; (iv) Reactivity data:(v) Corrosivity data; (vi) Thermal and chemical stability data; and (vii) Hazardous effects of inadvertent mixing of different materials that could foreseeably occur. (2) Information pertaining to the technology of the process. (i) Information concerning the technology of the process shall include at least the following: (A) A block flow diagram or simplified process flow diagram (see appendix B to this section); (B) Process chemistry; (C) Maximum intended inventory; (D) Safe upper and lower limits for such items as temperatures, pressures, flows or compositions; and, (E) An evaluation of the consequences of deviations, including those affecting the safety and health of employees. (ii) Where the original technical information no longer exists, such information may be developed in conjunction with the process hazard analysis in sufficient detail to support the analysis. (3) Information pertaining to the equipment in the process. (i) Information pertaining to the equipment in the process shall include: (A) Materials of construction; (B) Piping and instrument diagrams (P&ID's); (C) Electrical classification; (D) Relief system design and design basis; (E) Ventilation system design; (F) Design codes and standards employed; (G) Material and energy balances for processes built after May 26, 1992; and, (H) Safety systems (e.g. interlocks, detection or suppression systems)

(e) Process (1) The employer shall perform an initial process hazard analysis (hazard

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Hazard Analysis (PHA)

evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. (2) The employer shall use one or more of the following methodologies that are appropriate to determine and evaluate the hazards of the process being analyzed. (i) What-If; (ii) Checklist; (iii) What-If/Checklist; (iv) Hazard and Operability Study (HAZOP): (v) Failure Mode and Effects Analysis (FMEA); (vi) Fault Tree Analysis; or (vii) An appropriate equivalent methodology. (3) The process hazard analysis shall address: (i) The hazards of the process; (ii) The identification of any previous incident which had a likely potential for catastrophic consequences in the workplace; (iii) Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases. (iv) Consequences of failure of engineering and administrative controls; (v) Facility siting; (vi) Human factors; and (vii) A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace. (4) The process hazard analysis shall be performed by a team with expertise in engineering and process operations, and the team shall include at least one employee who has experience and knowledge specific to the process being evaluated. Also, one member of the team must be knowledgeable in the specific process hazard analysis methodology being used. (5) The employer shall establish a system to promptly address the team's findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; (6) At least every five (5) years after the completion of the initial process hazard analysis, (7) Employers shall retain process hazards analyses and updates or revalidations for each process covered by this section…

(f) Operating Procedures

(1) The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements.(i) Steps for each operating phase:(A) Initial startup;(B) Normal operations;(C) Temporary operations; (D) Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner.(E) Emergency Operations;(F) Normal shutdown; and,(G) Startup following a turnaround, or after an emergency shutdown.(ii) Operating limits: (A) Consequences of deviation; and (B) Steps required to correct or avoid deviation.(iii) Safety and health considerations: (A) Properties of, and hazards presented by, the chemicals used in the process; (B) Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment; (C) Control measures to be taken if physical contact or airborne exposure occurs; (D) Quality control for raw materials and control of hazardous chemical inventory levels; and, (E) Any special or unique hazards.(iv) Safety systems and their functions. (2) Operating procedures shall be readily accessible to employees who work in or maintain a process. (3) The operating

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procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate. (4) The employer shall develop and implement safe work practices to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel. These safe work practices shall apply to employees and contractor employees.

(g) Training (1) Initial training. (i) Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, shall be trained in an overview of the process and in the operating procedures as specified in paragraph (f) of this section. The training shall include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. (ii) In lieu of initial training for those employees already involved in operating a process on May 26, 1992, an employer may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures. (2) Refresher training shall be provided at least every three years, and more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process. … (3) Training documentation. The employer shall ascertain that each employee involved in operating a process has received and understood the training required by this paragraph. …

(h) Contractors

(1) Application. This paragraph applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. It does not apply to contractors providing incidental services which do not influence process safety, such as janitorial work, food and drink services, laundry, delivery or other supply services. (2) Employer responsibilities. (i) The employer, when selecting a contractor, shall obtain and evaluate information regarding the contract employer's safety performance and programs. (ii) The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor’s work and the process. (3) Contract employer responsibilities. (i) The contract employer shall assure that each contract employee is trained in the work practices necessary to safely perform his/her job. (ii) The contract employer shall assure that each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan…

(i) Pre-startup Safety Review

(1) The employer shall perform a pre- startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. (2) The pre-startup safety review shall confirm that prior to the introduction of highly hazardous chemicals to a process: (i) Construction and equipment is in accordance with design specifications; (ii) Safety, operating,

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maintenance, and emergency procedures are in place and are adequate; (iii) For new facilities, a process hazard analysis has been performed and recommendations have been resolved or implemented before startup; and modified facilities meet the requirements contained in management of change, paragraph (l). (iv) Training of each employee involved in operating a process has been completed.

(j) Mechanical

Integrity

(1) Application. Paragraphs (j)(2) through (j)(6) of this section apply to the following process equipment: (i) Pressure vessels and storage tanks; (ii) Piping systems (including piping components such as valves); (iii) Relief and vent systems and devices; (iv) Emergency shutdown systems; (v) Controls (including monitoring devices and sensors, alarms, and interlocks) and, (vi) Pumps. (2) Written procedures. The employer shall establish and implement written procedures to maintain the on-going integrity of process equipment. (3) Training for process maintenance activities. The employer shall train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe manner. (4) Inspection and testing. (i) Inspections and tests shall be performed on process equipment. (ii) Inspection and testing procedures shall follow recognized and generally accepted good engineering practices. (iii) The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience. (iv) The employer shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test. (5) Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation. (6) Quality assurance. (i) In the construction of new plants and equipment, the employer shall assure that equipment as it is fabricated is suitable for the process application for which they will be used. (ii) Appropriate checks and inspections shall be performed to assure that equipment is installed properly and consistent with design specifications and the manufacturer's instructions. (iii) The employer shall assure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.

(k) Hot work Permits

(1) The employer shall issue a hot work permit for hot work operations conducted on or near a covered process. (2) The permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations; it shall indicate the date(s) authorized for hot work; and identify the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work operations.

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(l) Management Of Change

(1) The employer shall establish and implement written procedures to manage changes (except for ``replacements in kind'') to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process. (2) The procedures shall assure that the following considerations are addressed prior to any change: (i) The technical basis for the proposed change; (ii) Impact of change on safety and health; (iii) Modifications to operating procedures; (iv) Necessary time period for the change; and, (v) Authorization requirements for the proposed change. (3) Employees involved in operating a process and maintenance and contract employees whose job tasks will be affected by a change in the process shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process. (4) If a change covered by this paragraph results in a change in the process safety information required by paragraph (d) of this section, such information shall be updated accordingly. (5) If a change covered by this paragraph results in a change in the operating procedures or practices required by paragraph (f) of this section, such procedures or practices shall be updated accordingly.

(m) Incident Investigation

(1) The employer shall investigate each incident which resulted in, or could reasonably have resulted in a catastrophic release of highly hazardous chemical in the workplace. (2) An incident investigation shall be initiated as promptly as possible, but not later than 48 hours following the incident. (3) An incident investigation team shall be established and consist of at least one person knowledgeable in the process involved, including a contract employee if the incident involved work of the contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. (4) A report shall be prepared at the conclusion of the investigation which includes at a minimum: (i) Date of incident; (ii) Date investigation began; (iii) A description of the incident; (iv) The factors that contributed to the incident; and, (v) Any recommendations resulting from the investigation. (5) The employer shall establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented. (6) The report shall be reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable. (7) Incident investigation reports shall be retained for five years.

(n) Emergency Planning

And Response

The employer shall establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38(a). In addition, the emergency action plan shall include procedures for handling small releases. Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120 (a), (p) and (q).

(o) Compliance

Audits

(1) Employers shall certify that they have evaluated compliance with the provisions of this section at least every three years to verify that the procedures and practices developed under the standard are adequate and are being followed. (2) The compliance audit shall be conducted by at least one person knowledgeable in the process. (3) A report of the findings of the audit shall be developed. (4) The employer shall promptly determine and document an appropriate response to each of the findings

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of the compliance audit, and document that deficiencies have been corrected. (5) Employers shall retain the two most recent compliance audit reports

(p) Trade Secrets

(1) Employers shall make all information necessary to comply with the section available to those persons responsible for compiling the process safety information (2) Employer can request that the persons to whom the information is made available to enter into confidentiality agreements

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Table 3. Recent Publications from AIChE-CCPS

Title DescriptionEssential Practices for Managing Chemical Reactivity Hazards.

An easy-to-use resource that guides small and large companies alike through the process of determining if chemical reactivity hazards exist, and provides the steps needed to address these hazards

Understanding Explosions

This concept book helps prevent explosions by describing the many types of explosions and the conditions under which they occur.

Guidelines for Investigating Process Safety Incidents, 2nd Edition:

An update of a CCPS classic, this edition includes recent experiences and extensive checklist resources. An enclosed CD-ROM provides the book in electronic format for greater portability for field investigations.

Guidelines for Facility Siting and Layout:

This Guideline book captures the science and art of siting and layout together in one place, and offers real examples and lessons learned.

Guidelines for Fire Protection in the Chemical, Petrochemical, and Petroleum Industries:

This new book consolidates all the relevant standards and codes into one place to make them easier to follow and implement.

Process Safety Beacon The monthly process safety newsletter for operators has begun its third year, teaching process safety lessons in clear, interesting language, to plant operators and staff around the world.

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Table 4. CCPS Objectives and their relationship to OSHA 29 CFR 1910 and EPA 40 CFR 68

CCPS Objectives OSHA 29 CFR 1910 119 EPA 40 CFR 681. Accountability, Objectives, and Goals2. Process Knowledge and Documentation

(d) Process safety information .48-.65 Safety information

3. Capital Project Review and Design Procedures

(i) Pre-startup safety review, (j) Mechanical integrity

.20 - .42 Pre-startup review

4. Process Risk Management (e) Process hazard analysis, (i) Pre-startup safety review

.20 - .42 Hazard assessment, .50 Process hazard analysis

5. Management of Change (l) Management of change .36 Management of change6. Process and Equipment Integrity

(e) Process hazard analysis, (f) Operating procedure, (j) Mechanical integrity

.56 Maintenance (mechanical integrity)

7. Incident Investigation (m) Incident investigation .60 Accident investigation8. Training and Performance (f) Operating procedures,(g)

Training, (i) Pre-startup safety review, (n) Emergency planning & response

.52 SOPs,.54 Training, .95 Emergency response program

9. Human Factors (e) Process hazard analysis, (f) Operating procedures

.24 Process hazard analysis, .28 Standard operating procedures

10. Standards, Codes, and Regulations

(o) Compliance audits .58 Safety audits

11. Auditing (o) Compliance audits .58 Safety audits12. Enhancing Process Safety Knowledge

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Table 5. SACHE Materials Available for Educational Purposes from AIChE-CCPS, New York, NY

Title Author Year ISBN NumberTank Failures - Slides and Lectures Willey 1993 ISBN 0-8169-0602-5Fires - Slides and Lectures Welker/Springer 1993 ISBN 0-8169-0603-3Explosion Proof Electricals - Slides and Lecture Cyanamid/Page 1993 ISBN 0-8169-0599-1Chemical Process Safety Management, Flixborough and Pasadena (TX) Explosions, and Miscellaneous Case Histories - Slides and Lecture

Bethea 1994 ISBN 0-8169-0608-4

Nitroaniline Reactor Rupture - Slides and Lecture Willey 1994 ISBN 0-8169-0634-3Seminar on Seveso Release Accident Case History - Slides and Lecture Willey 1994 ISBN 0-8169-0902-3Dust Explosion Control Video/Slide/Lecture Louvar/Schoeff 1994 ISBN 0-8169-0634-4Toxicology and the Chemical Engineer Welker/Springer 1995 ISBN 0-8169-0606-8Consequences of Operating Decisions-Lecture Cobb 1995 ISBN 0-8169-0633-5Industrial Hygiene and the Chemical Engineer-Slide Lecture Springer/Welker 1995 ISBN 0-8169-0604-1Phillips' Explosion -Video Bethea 1996 ISBN 0-8169-0673-4Inherently Safer Plants Kubias 1996 ISBN 0-8169-0669-6Property of Materials Willey 1997 ISBN 0-8169-0694-5Potential Accidents from Safety Systems Hendershot 1998 ISBN 0-8169-0732-3Emergency Response Planning Bethea 1998 ISBN 0-8169-0671-8The Human Healthrisk Assessment Process Jayjock 1998 ISBN 0-8169-0734-XThe Bhopal Disaster Willey 1999 ISBN 0-8169-0766-8Vapor Cloud Dispersion Modeling CD-ROM 2001 ISBN 0-8169-0729-3Piper Alpha -- Spiral to Disaster Willey 2001 ISBN 0-8169-0823-0Methacrylic Acid: Tankcar Explosion and Methods of Safe Handling Willey 2001 ISBN 0-8169-0850-8Case History: Hickson Pharmachem Ltd., Runaway Reaction, Explosion & Fire

2001 ISBN 0-8169-0849-4

A Batch Polystyrene Reactor Runaway Willey 2001 ISBN 0-8169-0797-8Fire Protection Concepts, SACHE DVD Welker 2002 ISBN 0-8169-0670-XAn Introduction to Reactive & Explosive Materials Willey 2002 ISBN 0-8169-0799-4Mini Case Histories Louvar &

Dakshinamoorthy2003 ISBN 0-8169-0883-4

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Figure 1. Number of Workers Killed in Manufacturing by Year Since 1960 (Original Source National Safety Council, 2nd source, U.S. Census Bureau Statistical Abstracts of the United States)

0

200

400

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1960 1965 1970 1975 1980 1985 1990 1995 2000 2005

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ber o

f Fat

aliti

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otal

per

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r

PSM

TRI

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HA

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al

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0

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1970 1975 1980 1985 1990 1995 2000 2005

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OSH

A

Bhop

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CSB

TRI

OSH

A

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Figure 2. Number of Deaths in Manufacturing Per 100,000 Employees for the United States by Year for the Last 31 years

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0

2

4

6

8

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12

1960 1965 1970 1975 1980 1985 1990 1995 2000 2005

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Bhop

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Figure 3. OSHA incident rate for the years 1960 to 2002 as Reported in the 2003 U.S. CB Statistical Abstract of the United States: 2003.

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0

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2000

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1985 1990 1995 2000 2005

Year

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ions

of P

ound

s

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Air emissionsPS

MTRI

Bhop

al

CSB

Figure 4. Toxic Chemical Releases from the Chemical and Allied Products as Reported in the 2003 U.S. CB Statistical Abstract of the United States: 2003 Table No. 379.

Page 28: PAPER W-38 · Web viewAt the time, MIC’s primary hazard classification by the DOT was based on its flammability. The board concluded: “many questions now unanswered by DOT’s

References:

1 New York Times, 2 December 1984, A1.10 Carson, R. “Silent Spring,” Houghton Mifflin 40th anniversary ed, 2002.11 See also http://www.epa.gov/history/topics/perspect/carson.htm, accessed 17 July 2004.12 http://www.epa.gov/history/org/origins/reorg.htm, accessed 10 July 2004.13 C&E News, 11 February 1985, p54.14 www.osha.gov, Frequently Asked Questions (on About OSHA webpage), 7 July 2004.15 C & E News, 11 February 1985, p 57.16 C & E News, 11 February 1985, p 57.17 http://www.epa.gov/Arkansas/6sf/pdffiles/rmp_general_guidance_3.pdf accessed 18 July 2004.18 C & E News, 24 Dec 1984, p5.19 http://www.epa.gov/history/topics/tsca/03.htm accessed 17 July 2004.20 http://www.epa.gov/region5/defs/html/tsca.htm accessed 17 July 2004.21 http://www.epa.gov/history/topics/rcra/05.htm accessed 17 July 2004.22 http://www.epa.gov/history/topics/rcra/03.htm accessed 17 July 2004.23 http://www.epa.gov/history/topics/cercla/index.htm accessed 17 July 2004.24 http://www.chem.mtu.edu/org/aiches&h/lps.html accessed 10 July 2004.25 AIChE Spring National Meeting, Atlanta Georgia, 2005.26 R. J. Willey, SACHE Case History: “A Batch Polystyrene Reactor Runaway,” prepared for SACHE (Safety and Chemical Engineering Education) as a product of the AIChE-CCPS. March 2000, ISBN 0-8169-0797-627 http://www.aiche.org/diers/ accessed 18 July 2004.28 C&E News, 17 December 1984, p7.29 C&E News, 11 February 1985, p57.30 http://www.epa.gov/history/topics/cercla/08.htm accessed 17 July 2004.31 http://reporting.responsiblecare-us.com/reports/tri_cmpny_rpt.aspx accessed 24 July 23, 2004.32 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9761 accessed 17 July 2004.33 Portions of this text is from http://www.epa.gov/Arkansas/6sf/pdffiles/rmp_general_guidance_3.pdf accessed 18 July 2004.34 Text is directly from http://www.csb.gov/index.cfm?folder=mission_history&page=index, accessed 18 July 2004.35 Chemical & Engineering News, Dec 24, 1984, p5.36 http://www.americanchemistry.com/cmawebsite.nsf/s?readform&nnar-5ztk7s accessed 23 July 2004.37 http://www.responsiblecare-us.com/about.asp accessed 23 July 2004.38 http://www.cl2.com/ accessed 23 July 200439 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9760 accessed 17 July 2004.40 http://www.nacd.com/index.cfm accessed 23 July 200441 http://www.dow.com/publicreport/2003/pdf/233-00214.pdf accessed 23 July 200442 http://www.aiche.org/ccps/aboutccps.htm accessed 18 July 2004.43 http://www.aiche.org/ccps/pdf/CCPSAnnual_2004.pdf accessed 18 July 2004.44 http://www.aiche.org/sache/pdf/spring03news.pdf p.3. accessed 18 July 200445 http://www.abet.org/criteria.html46 Fogler, H.S., "Elements of Chemical Reaction Engineering," 2nd Ed., Prentice Hall, Englewood Cliffs, New Jersey, 1992.48 Adapted from http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9760 accessed 17 July 2004.