COMMENTS ON CHEMICAL PLANT SAFETY & SECURITY RATING SYSTEM

I appreciate the initiative on the new safety and security rating system for chemical plants by the Indian Government and am sharing my comments sent to the Ministry on the new safety rating system:

1.    The initial screening criteria will eliminate many of the existing chemical units in the small and medium scale sector which also handle highly hazardous chemicals.  In such a case, what will be the action? I suggest that Initially, for SME sector, certification to OHSAS 18001 could be made mandatory and the proposed safety and security rating system be applied to MAH units. Later the modalities to extend it to SME sector could be worked out.

2.      In the initial screening criteria, one of the KPI’s is mentioned as “approved and documented PSM system available and implemented”. There is no reference to which PSM model to follow. I suggest that the basic OSHA CFR 1910.119 PSM rule of USA be followed. The threshold limit of chemicals for which PSM system applies could be the same list used in MSIHC rules.

3.    Any rating system is a snapshot of the organisations safety performance. However, in process safety management, top management commitment and technical competency of the people who run the system are important for achieving incident free performance. The proposal for the new safety rating system suggests that organisations with good safety performance will be incentivized. The opposite of this must also be implemented – if an organization that has been rated either 3,4 or 5 star in the new rating system experiences a reportable accident ( as defined in factory rules) after the award of the rating and within the periodicity of assessment, then the rating should automatically be downgraded to “Poor”.  This will ensure continued top management focus. The list of organizations who have been thus downgraded may be publicized on the Ministry of Chemicals and Fertilizers website or on a new website specifically dedicated to the “Chemical Plant Safety and Security Rating system”

4.      In the 19 KPI’s of final assessment, KPI’s 12,13 and 14 (Contractor management, emergency preparedness and response and training and competency) are already covered in the PSM system mentioned in KPI 2. They can be assessed as part of the PSM system.

5.      As the concept of “Occupier” and “Factory Manager” is already legally required for companies, I suggest that both of them be mandatorily assessed in final assessment on how they track PSM performance as well as competency levels to maintain the PSM system.

6.      In the evaluation questionnaire for PSM, in point 2.3, it is asked if QRA/LOPA is done for all operations and recommendations implemented? Instead, the question could be Whether Hazard Identification and risk analysis based on guidelines of IS 15526:2006 has been carried out and recommendations implemented?

7.      Finally, the new rating system will be recognized as unbiased and transparent by the public only if the if the assessment evidences for those organisations that have been awarded “Good, Very Good and Excellent” are posted on the website of the Ministry of Chemicals and Fertilizers or on a new website specifically dedicated to the “Chemical Plant Safety and Security Rating system”

                                                   END

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HPCL VISAK REFINERY FIRE INCIDENT INVESTIGATION

An investigation of the cooling tower explosion in HPCL Visak refinery by the joint chief  inspector of factories suggests that "HPCL failed to adopt safety steps"
Read the article in Times of India in this link.

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Implementing PSM - do not overdo it!

I often get RFQ's for PSM implementation some of which writes down everything under the earth!
Recently I got one that included occupational health, off the job safety, and customers and products! All these mentioned items are part of the basic necessities BEFORE PSM is implemented. So if you have a doubt in your basic safety do not implement PSM till you get your house in order!



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Explosion incident

"On May 8, 2005, a crew of three, a painter , an attendant and a supervisor were in the process of applying a paint/liner product on the interior of a rail tank car in an enclosed shop. The painter was inside the tank car and the attendant was standing on top of the railcar at the manhole. The supervisor had just stepped into his office when a loud explosion occurred. Flammable vapors had accumulated in the tank car and the shop.The attendant was blown from the top of the rail car to the floor of the shop but was basically unharmed' Read details in this link..

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Safety rating for chemical plants: A step in right direction | Business Standard

Safety rating for chemical plants: A step in right direction | Business Standard

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Accidents in the lab and process safety

 A recent fatal accident at a lab in a Chemical Plant in the UK highlights the need to understand that process safety also needs to be taken care of in the lab. Some sources are attributing the explosion was caused by the exposure of trimethylindium, a pyrophoric chemical, to the air.
Read more in this link
In another incident in 2008, a 23 year old Chemistry research student died form burn injuries during a lab experiment. A detailed explanation of the incident is given in this link. 

Personnel working in Labs and R & D's need to exercise the same caution, if not more, as they may be working with certain chemicals which may behave differently under different conditions.Process safety should start from the lab....



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One dead in LPG road tanker blast

 A LPG road tanker driver died in Mathura when his tanker met with an accident while allegedly avoiding cops who were demanding bribes. Read the news article in this link

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Simple properties of chemicals and process safety

The newspapers are full of reports of a dry ice explosion in a restroom in LA international airport. Dry ice or solid CO2 has a property of directly changing into gas from its solid state as it's temperature increases. If the dry ice is kept in an enclosed container, then it exerts immense pressure and can explode the container. The discovery channel has a video in this link which demonstrates vividly what can happen. Worth a see by all plant operators to realise the hazards of chemicals.


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Safety rating system for chemical units

The ministry of chemicals and fertilisers have published the draft safety rating system for chemical plants on their website for public comments. Give your comments to them by October end. You can access the draft rating system in this link. See the file in "important links" as well as "updates" scrolling on their website.


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Where does your reactor rupture disc vent?

An accident in a reactor caused a rupture disc to burst open and spew the reactor contents out, killing people. Very often, people think that just by installing a rupture disc, a reactor is safe. You need to properly design the outlet system of a rupture disc. Read about the incident in this link.

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Ammonia transfer line incident

An incident of ammonia release has been reported in the USA when apparently a pressure safety valve malfunctioned. Check your safety valves in transfer lines - where do the PSV's release?  Are they tested regularly? Many times, tranfer lines are always in use and operations do not find the opportunity to release them for maintenance.

Read about the incident in this link.

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Ruptured reboiler caused fire?

A company news release about the explosion at their Geismar plant indicates the following:

"According to the preliminary findings three main factors in combination with one another contributed to the incident:

>      The unexpected presence of liquid hydrocarbons in the reboiler in standby mode

>      The introduction of heat into this standby reboiler

>      The pressure relief system was isolated from the reboiler which was in standby mode"

Read the news release in this link.

It is heartening to see this news release on the company's website itself. In India, we are still waiting news about the investigation about the cooling tower explosion in a refinery!!

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"This is your pilot sleeping"

A recent incident in a British airline where both the pilot and copilot dosed off because of lack of adequate sleep in the previous nights highlights the importance of fatigue management in the chemical industry, too. While the chance of a control room operator in a common control room in a chemical unit to fall asleep unnoticed is less, fatigue often impairs judgement and reaction. For plants using process simulators for training, it is worth to take the trainee through a series of night shift training sessions so that he himself feels the difference.
Read about the incident in this link.

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Emergency exits

Thanks to Mr Salim Akthar for sharing news about a fatality in a cement plant where a person died due to lack of proper emergency egress. The incident occurred when the persons went to attend to a cement extraction problem in a silo.  As the choke suddenly cleared, the victim panicked and it appears that while trying to escape from the exit staircase his forehead struck against some equipment / obstruction on the way. He died due to the impact. This incident highlights the importance of emergency exits while performing non routine jobs.


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Possible dust explosion during hot work

Thanks to Sujith for sending information on a possible dust explosion in a tank storing HDPE in Korea, during welding work. The news article in the Korea Joongang Daily mentions:
"The sudden and massive blast hit the plant, located at the Yeosu Industrial Complex, at around 9 p.m. Thursday, catching workers engaged in welding off guard, some falling 30 meters (98.4 feet) down from the tank to the ground, according to witness accounts.
The death toll is likely to rise as five of the 11 wounded are reportedly severely burned. Firefighters contained the fire within 10 minutes after the blast.
The plant, owned by Daelim Industrial, was undergoing maintenance work at the time.
Workers were welding a door into the tank to make an entrance so the company could send inspectors in to examine the interior, the company said. 
“We checked if there was remaining gas in the tank every time workers were put to work, thus multiple times a day,” said an official with Daelim’s public relations team, who requested anonymity.
“Each time, the result was zero. There was no gas lingering in the tank and thus that was not what caused the explosion.” 

Read the article in this link.


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Hot work accidents

We keep hearing about hot work accidents and loss of life. They are totally preventable and we need to apply basic precautions. See a powerpoint on welding cutting and brazing in this link.

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State of preparedness for chemical emergencies

A news report in the Times of India indicates that are 380 "Major Accident Hazard" (MAH) prone industrial units, of which 331are operational in Gujarat.  It also mentions that toxic chemicals with more than 5,000 MT tonnes storages in Gujarat are acrylonitrile, ammonia, benzene, chlorobenzene, chloroform, cyclohexanone, ethylene dichloride, hydrogen, cyanide, P-xylene, styrene monomer and toluene. The report specifies the gaps in infrastructure required for chemical emergency preparedness. Read the report in this link.

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Inherent safety and LOPA

A Chemical Engineering friend of mine (Vijay) who has about 35 years of experience in Process Industry wrote in to say this:

"Participated in a LOPA study involving pyrophoric materials. However, what struck me was people failed to understand intrinsic safe and unsafe. They did not grasp that giving high SIL rank and spending lot more on SIL certified instrumentation does not buy any increased safety from accidents that can occur when a pyrophoric material is handled. Only a process change can make things safer, not SIL certification or LOPA for inherently unsafe processes. This also happens to be the message of Fukushima. But people dont get it".

There is a strong lesson in his message!!
 
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HPCL refinery fire death toll increases to 27

The latest figure indicates 27 people have died till now in the HPCL cooling tower fire. I feel very sad when newpaper articles mention the death toll, also mention that only one HPCL employee was killed in the incident. A life is a life whether it is a contract worker or employee.
I am waiting for any news about the investigation. Any one know anything about the investigation findings?

Novel solution to flange leaks due to thermal expansion

Often, flanges leak due to the thermal expansion difference between the flange material and the fasteners.  An interesting article by a company that deals with such leaks. Read the article in this link.
PS: This is for information only.

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Another confined space fatality due to nitrogen

On 18th May an engineer in a refinery in Iran died when he entered a vessel filled with nitrogen. Time and again we keep hearing about deaths due to nitrogen. What are you doing to raise awareness of your employees about the hazards of nitrogen?
Read this article in EHS today.


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Ammonia leak kills 7

Closely following on the heels of the ammonia leak in a cold storage facility in China, an ammonia leak in a factory in Gujarat has reportedly killed 7 people.
Ammonia is used in cold storage facilities as it is a refrigerant. However the large number of leaks and incidents in India and in the World indicates that cold storage owners do not give adequate importance to safety while handling ammonia. As part of Responsible Care, companies manufacturing and selling ammonia to cold storage users may assist in training the users on the hazards of ammonia. Read about the incident  in this link.


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Hydrogen sulphide -the deadly killer

Unconfined spaces are also dangerous as far as hydrogen sulphide is concerned. Be careful when working near a potential source of hydrogen sulphide, even though it may be in open space. Two case studies of accidents involving hydrogen sulphide are given in this link.

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Emergency response after the HPCL fire accident

The death toll in the fire accident in the cooling tower at HPCL, Visakh has climbed to 19. It is very sad to see so many lives lost. A specialist doctor laments the state of emergency preparedness of the hospitals to handle burn victims. We never seem to learn from the lessons of Bhopal. We seem to have have a learning disability as far as emergency preparedness goes, as it is assumed it will never happen. Read the article in the Times Of India where a leading doctor blasts the state of emergency preparedness after the accident in this link.

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Accident during dewatering pipeline after hydrotest

An accident where two workers during the de-watering of natural gas pipelines after hydrotest as they were struck by temporary de-watering piping, which was not properly anchored and broke loose from its coupling from excessive air pressure. Read about the incident in this link.

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Gas leak into cooling towers

In an article in the Hindu dated  August 27,2013, it quotes a top official of HPCL saying  "in fact such an accident is first of its kind in the world history. A blast of this kind in the cooling tower in unheard of”.

For those in the process industry, gas leaks into cooling towers are not a one off affair. Heat exchanger tube leaks can cause a surge of gas into cooling towers. I had experienced one such incident  30 years ago. Dr Trevor Kletz, in his book " What Went Wrong" mentions under the category "Heat Exchangers", in page 105, the following incident "A leak in another heat exchanger allowed flammable gas to enter a cooling water return line. Welding, which was being carried out on the cooling tower ignited the gas. The atmosphere in the cooling tower had been tested before work started, 5 hours earlier"

Cooling towers are often falsely thought to be harmless, but they can become killing towers in no time.


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HPCL refinery cooling tower fire incident

Refinery safety mechanism goes for a toss

Vizag refinery fire - a cause for concern

Visiting VIPs' face angry protests

 
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Gas leak into system caused the explosion in the cooling tower in refinery?

 Read this article in the Hindu in this link.

 
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Data on process incidents lacking even in USA

I read an interesting article in Dallas News which mentions that lack of data on chemical accidents is a big issue in USA. Just imagine...if this is the state in the USA which has the Chemical Safety Board and other agencies to investigate process incidents, imagine the plight in India!
The article mentions that out of 22000 chemical units in USA just 100 are members of ACC which requires data on accidents to be made public. The article ends in this note:
“Why would a company or organization do data checking? They might do it because there is a liability risk. They might do it because they feel it’s the right thing to do,” Podgurski said in an interview. “But even in an honest organization, deadline financial pressures will mitigate those efforts.”
Read the article in this link.


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Video of cooling tower fire

Details are still sketchy but it appears that the explosion/fire occurred during charging of water to the tower. We have to wait and see whether the investigation details will be made public. Meanwhile see a video of the fire in this link. 

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Explosion in refinery...

News just filtering in about an explosion in HPCL Visakhapatnam refinery in a cooling tower area. Reportedly one person was killed. Read about the news in this link.

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Ammonia leak incident in Mexico

Thanks to Mr Gnanasundaram for sharing news of an ammonia leak in a ammonia pipeline that has reportedly killed 7 people in Mexico. Apparently the leak occurred during excavation for a highway project. Read about the incident in this link. 


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Ammonia from the wind

I read an article where researchers have managed to produce hydrogen that is needed for ammonia synthesis using wind energy. So, if successful on a large scale, the reformer in the ammonia plant will become redundant.....inherently safer?
Read the article in this link.

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Explosion in plant

An explosion and fire in a chemical recycling plant in the USA is most likely due to a "chemical reaction". It is estimated that about 1000 barrels exploded in the fire. Luckily there were no fatalities. Read about the incident and see videos in this link.


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Human factor incident

In a plant having two identical flare systems, a permit was issued to open a flange in a KO drum connected to a flare which was out of service. the maintenance personnel instead opened a flange of a live flare which was venting as, thus creating an emergency. 
Have you identified such human factor hazards in your facility? Ask your operators and they will tell you.

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Hot work or Cold work?

An incident where a person passed away in a tank explosion revealed that the work permit that was used in the facility was a single permit for both hot work as well as cold work. The issuer had to tick mark whether it was a hot work or cold work to be done and take the appropriate precautions. The permit was issued without marking whether it was hot work or cold work to be carried out. Lack of this clarity led to a hammering operation with a ordinary hammer taking place at the top of the tank which had flammable material inside. The spark produced during hammering fell into the tank through an opening and the tank exploded. 

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5 people killed in ammonia leak in ammonia plant

Thanks to Balu for sending information on a ammonia leak in a ammonia plant that has killed 5 people in Ukraine. You can see the picture of the accident and details in this link.
Read another article in this link. 

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Confined space fire incident

I had just posted the previous post on causes of confined space incident when I was told of an incident where a non flameproof light fitting was taken inside a newly painted vessel to check the interior painting quality. The flammable vapors inside caught fire and two people inside the confined space were seriously injured. Treat your work permit system with respect. Over a period of time they tend to get relaxed.

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Recurring causes of confined space incidents

Read a good article on recurring causes of confined space incidents (with incidents) in this link.

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Pipe explosion during hydrotest

An explosion in a chemical plant in China was reportedly during a hydrotest of a hydrogen pipeline. Read the incident in this link. 

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Lessons from Hazira fire

With reference to my previous post about a fire in a refinery, a fire had occurred in January 2013 in a oil depot of IOC at Hazira.that Killed 5 workers. The investigation report of that incident mentions that  the root cause of the incident was ignition of flammable vapours inside a floating roof tank pontoon.It appears that the pontoon was earlier repaired with old corroded plates that led to the leak. The cause of ignition was most likely a spark generated due to a falling object.


Read the report in this link.

See a video of the fire in this link. 


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Operator dies in flare KO drum area fire

A fire in a flare KO drum area has killed an operator in an IOC refinery in Koyali.  The incident occurred on 16th July and the operator succumbed to his burns on 25th July. While the reasons for the incident are being investigated, please remember that Flare systems are emergency safety systems and that we need to pay them great attention. Often fires get reported due to water seals blowing, overflows from flare stacks, and inadequate maintenance. Are you giving your flare systems the same importance as a single stream rotating equipment?

Read the news article about the incident in this link. 

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MOC survey results

Thank you to the participants of the MOC survey
Results are given below:

Total participants: 45

What do you feel is the weakest link in your MOC program?

Lack of commitment by top management                              21.7%   

Too elaborate and complicated                                               29.7%   

Lack of time                                                                            48.6%

Do you have adequate time to conduct a PSSR?

Yes                                                                                          64.9%

No                                                                                            35.1%

Do you feel the PHA conducted as part of MOC is really bringing out all process hazards?

Yes                                                                                         48.6%

No                                                                                           51.4%

What is the greatest challenge to your MOC program?

Majority answered that it is lack of proper engineering documentation

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3D virtual simulator for chemical plants

Now this is one technology driven change that sure is going to benefit process safety! The Department of Energy is running a program with West Virginia University to test 3D virtual simulators for training process plant simulators. Read an article about this in this link.

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Accident in urea plant in 1992 - Are you taking precautions?

 In 1992, while doing maintenance work on an ammonia feed pump in a urea plant in India, 11 persons died due to sudden ingress of ammonia reportedly due to a failed suction valve bush.What precautions are you taking when handing over equipment for maintenance to prevent such incidents?
Read the incident in this link.

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A balloon causes a refinery outage!

A news report indicates that a refinery in the US experienced a "momentary power problem that prompted a plant restart". Apparently, the problem was caused by a Mylar balloon that got caught in power lines supplying the refinery. Read the article in this link.

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Explosion in solvent tank

An explosion took place in a solvent tank that was part of a process that was being started up for the first time. It is reported that the explosion took place even though there was a nitrogen blanketing system of the tank. When you start a plant for the first time or after any modifications, be very careful. Humans make mistakes and especially during the time pressures for commissioning.


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Management of Change survey

Dear Readers,
Kindly take a few minutes to complete a Management of Change survey (6 questions, multiple choice) in this link.

Date of closing of survey is 24.7.13. Results will be published in blog. Thank you for your participation.


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Operating discipline!

For those of you folks who are practicing behavior based safety in your organisation to improve safety culture, see this very educational video in this link. 


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An organisations take on Safety Culture

In an article in Power Magazine, I read about a company called NV Energy who have developed a very good safety culture and it shows in their accident stats. You may argue that they are a small organization but I believe what they are doing is also applicable to big organizations.

 Read the article in this link.


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3d printed chemical reactor achieved

Further to my last post, "Scientists in the UK have used reactors made on a 3D printer to complete a three stage organic synthesis. The reagents, catalyst and purification step for the synthesis are completely integrated into the chambers of the sealed reactor. When the reactor is rotated, gravity pulls reactants through the different chambers to complete the synthesis".

Read the article in this link.
The next step in process safety may well be micro reactors and micro plants.......stay tuned!! 

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3d printing and process safety

The news has been full of reports of how a company put their plan for 3D printing of a plastic gun on the net and how one person was even able to fire a bullet from it. It appears right now that the printer prints using plastic material. The advantages claimed are accuracy, less wastage. An article by Bloomberg  "Your future will be made by 3D printers" is interesting to read.

In the future, maybe 3D printing will improve process safety by eliminating manufacturing defects!!


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Drones for flare tip inspection

While we read about drones being used for military purposes, here is another use for them -a refinery has used a drone fitted with a camera for inspection of the flare tip while refinery was in operation. Now this is what I call as innovative usage of technology! Read the article in this link. 

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A confined space fatality

Three years ago, a experienced person (17 years experience) lost his life when he entered a space inside a ship that was inerted with nitrogen. This, through he was trained and experienced.
 Read the accident report in this link.

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Another hot work tank explosion

A refinery in China experienced a hot work accident that killed two workers. Apparently the tank in which the accident took place was decommissioned. Ensure you take all precautions when doing hot work on tanks.
Read the news articles in these links:
Tank explosion 1
Tank explosion 2

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Vessel blast kills one

In a fertilizer manufacturing facility very close to the Louisana unit, one person was killed when a vessel ruptured when it was being pressurized with nitrogen.
Read about the incident in this link.

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Photos of the fire in chemical plant

See photos of the fire in the chemical plant in Louisana in this link

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Explosion in chemical plant

An explosion in a chemical plant (manufacturing ethylene/propylene) in Louisana has killed one person and injured several. We have to wait for the CSB to investigate and report the findings.
Read about the incident in this link
Watch the video in this link.

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Rescuers die in a confined space rescue

A tragic accident where two rescuers lost their lives trying to rescue two persons who had lost consciousness inside a chimney is reported in a bio gas plant under construction in Thailand. This incident stresses the need for training would be rescuers. World over, many deaths continue to occur as rescuers enter confined space without proper protection and loose their lives. Read the incident in this link. 

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Process safety leadership survey results

A total of 55 readers undertook the survey and I thank them for their participation. The results are given below:
 

1. How much do you think are your top management really committed to process safety?

Very much                                                         39.2 %   

Sometimes                                                        25.9%   

Needs improvement

(they say something and do something else)  34.9%   

2. In times of production problems, do you think process safety gets bypassed according to the urgency?

 Yes                    22.9%   

Sometimes        60.4%   

Never                 16.7%   

3. Do your PSM audit findings receive adequate follow up from top management?

 Yes                                                46.8%   

Needs improvement                      53.2%   

4. Do your inspection departments findings get overruled by top management to maintain production?

 Yes, but with a technical basis     47.9%   

Yes, without a technical basis       25.0%   

No, never                                       27.1%   

5. Do you get contradicting signals from top management regarding process safety?

 No, never              41.7%  

Yes, sometimes    56.3%   

Yes, always           2.0%     

6. Do you feel the root cause analysis of process incidents and near misses really bring out the root causes?

Yes                       72.9%   

No                         27.1%   

                             

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Treat tanks with care

Storage Tank Safety | Treat Tanks with Care | Chemical Processing




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Follow safety norms or face closure, Andhra Pradesh Minister warns units | The Hindu

Follow safety norms or face closure, Andhra Pradesh Minister warns units | The Hindu

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Lessons from the near miss at Heathrow airport

Last week, a plane had to make an emergency landing at Heathrow airport soon after take off as one of the engines failed. No one was injured. Preliminary investigations have revealed that the engine cowls (covers) on both the engines were left unlocked and came off during take off, damaging the engine and other parts.
The air accident investigation board's report indicates that there had been 32 previously reported fan cowl door detachment events, 80% of which had occurred during the takeoff phase of flight!

Read the report in this link. 



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