Poor planning for a hurricane, lack of oversight for reactive chemicals and failed fire fighting systems all contributed to the Aug. 27, 2020 fire and toxic gas release at a Bio-Lab facility in Westlake, Louisiana.
The U.S. Chemical Safety and Hazard Investigation Board (CSB) released its final investigation report on the incident, which was a result of Hurricane Laura’s severe winds tearing the roofs off buildings at the facility and exposing reactive chemicals to hurricane rainwater.
Incident occurred when rainwater contacted reactive chemicals
Pool and spa chemicals containing trichloroisocyanuric acid (TCCA) were manufactured at the Bio-Lab facility. TCCA products slowly break down and release chlorine when placed into large bodies of water, such as pools and spas. However, when TCCA comes into contact with small amounts of water and doesn’t dissolve, it will undergo a chemical reaction that generates heat and produces toxic chlorine gas.
In preparing for Hurricane Laura, Bio-Lab had begun moving its supply of TCCA to a facility in Georgia. By the day of the incident, the company had successfully moved 825,000 pounds of the chemical, but several truck loads were missed, leaving behind more than 1 million pounds of TCCA.
As the Category 4 hurricane made landfall, its strong winds damaged buildings at the Louisiana facility, in some cases completely tearing off roofs where the TCCA was stored. Rainwater from the storm contacted the chemical, initiating a chemical reaction that caused a fire and created a large plume of hazardous gases, including toxic chlorine.
A portion of Interstate 10 had to be closed for more than 28 hours and a shelter-in-place order was issued for the surrounding community because of the hazardous gas release.
There were no employee, public or emergency responder injuries reported.
The CSB investigation report identifies five safety issues that contributed to the incident:
1. Extreme weather preparation
Bio-Lab failed to learn the importance of preparing for extreme weather after the 2017 Arkema incident in Crosby, Texas, which also occurred following a Category 4 hurricane.
The Arkema incident occurred after extensive flooding from Hurricane Harvey, which caused organic peroxide decomposition. That chemical reaction led officials to institute a 1.5-mile evacuation zone during the incident.
Despite the lessons the industry learned from the Arkema incident, Bio-Lab didn’t implement industry guidance for extreme weather preparation that was updated and published to prevent the occurrence of a similar event.
2. Process hazard analyses implementation
TCCA is not covered by the OSHA Process Safety Management (PSM) standard. Bio-Lab voluntarily implemented some elements of the PSM standard and even conducted a 2010 Process Hazard Analysis (PHA).
However, the company didn’t implement a PHA recommendation to determine whether buildings at the facility could withstand damage from hurricane-strength winds.
If the company had implemented that recommendation, it could have identified that the buildings were susceptible to damage from hurricane-strength winds. Controls could then have been put in place to prevent the TCCA from being exposed to hurricane rainwater.
Those controls would have prevented the incident.
3. Emergency preparedness and response
Bio-Lab experienced an approximately five-and-a-half-hour delay in responding to the event due to an “inadequate and largely nonfunctional” fire protection system and the absence of automated sprinkler systems.
This led to an unnecessary increase in the:
- amount of TCCA that underwent a reaction
- quantity of toxic chlorine released, and
- extent of the facility damage.
The company didn’t adequately maintain its fire protection system and failed to ensure that enough of its staff, including its assigned hurricane crew, knew how to activate a backup generator. Operation of the backup generator was important due to the power outage caused by the hurricane.
4. Adherence to applicable hazardous materials codes
The Bio-Lab plant was built in 1979 and didn’t conform to the existing National Fire Protection Association (NFPA) codes for high-hazard industry occupancies.
Required fire detection and automatic fire sprinkler systems weren’t used in the facility. These systems are required under the NFPA 400 Hazardous Materials Code. They’re also required by the state for structures built or remodeled after July 1, 2017.
However, existing facilities in Louisiana, such as Bio-Lab, are grandfathered to the state-adopted codes and standards at the time of construction unless changes are made or if the State Fire Marshal receives a complaint.
If the Bio-Lab buildings involved in the incident would have been equipped with automatic extinguishing systems, it’s likely that large amounts of water would have been applied to the TCCA earlier in the incident. That would have significantly reduced both the size of the fire and the toxic gas cloud.
5. Regulatory coverage of reactive chemical hazards
Despite the fact that TCCA can decompose and release toxic chlorine gas when exposed to moisture, the chemical isn’t regulated under the OSHA PSM standard or the U.S. Environmental Protection Agency (EPA) Risk Management Program (RMP) rule.
That means Bio-Lab wasn’t required to use baseline process safety management system elements to manage the safety of its TCCA-related operations under these regulations. OSHA and the EPA currently use predefined chemical lists to identify the processes that need to be covered under their respective rules.
A 2002 study conducted by the CSB found that relying solely on lists of chemicals is an inadequate approach for regulatory coverage of reactive hazards. To improve, the CSB states that it would require “regulators and industry to address the hazards from combinations of chemicals and process-specific conditions rather than focus exclusively on the inherent properties of individual chemicals.”
The CSB also found that OSHA and EPA didn’t properly consider reactive chemical hazards when they developed their chemical lists, resulting in a lack of regulatory coverage over many of these chemicals.
This regulatory coverage gap relating to reactive chemicals and their hazards:
- points to a weakness in relying on fixed chemical lists to determine regulatory coverage
- contributed to this incident, and
- contributed to many other reactive chemical incidents over the past three decades.