If your company uses hazardous chemicals for certain processes but doesn’t fall under OSHA’s process safety management (PSM) standard, it’s probably a good idea to just follow the standard anyway.
Why go to the effort? Because adhering to the PSM standard may help you recognize hazards you didn’t know were there before they result in a catastrophe.
For example, the U.S. Chemical Safety and Hazard Investigation Board (CSB) found that a 2019 tank farm fire and chemical release in Houston Texas could have been prevented if the company adhered to the PSM standard.
The tank farm in Deer Park, Texas, which belonged to Intercontinental Terminals Company (ITC), wasn’t required to follow the PSM standard for the processes conducted at the facility, although it did adhere to it in part.
A CSB investigation into the incident – which caused substantial property damage, significantly impacted the environment and led to the issuance of several shelter-in-place orders – found that the incident wouldn’t have happened if the facility had followed the PSM standard in its entirety.
“This was a very large and disruptive event. The fire burned for three days, caused over $150 million in property damage at the facility, put the surrounding community potentially at risk, and significantly impacted the environment,” CSB Chairperson Steve Owens said. “This disastrous event could have been prevented if proper safeguards had been in place at the facility.”
Faulty pump releases flammable vapor undetected for 30 minutes
The ITC facility housed more than 240 aboveground storage tanks that were used to store petrochemical liquids and gases, fuel oil, bunker oil and distillates for multiple oil and chemical companies that leased the tanks.
On March 17, 2019, just after 10 a.m., an accidental release of butane-enriched naphtha product accumulated and ignited near a large aboveground atmospheric storage tank designated as Tank 80-8.
CSB investigators found that a circulation pump connected to Tank 80-8 failed and allowed the flammable vapor contained in the tank to escape. The pump continued to release the vapor undetected for roughly 30 minutes before it ignited, causing a fire to erupt and engulf the Tank 80-8 piping manifold.
Once this fire erupted, ITC was unable to isolate or stop the release. Fortunately, no one was injured during the incident.
Fire burned for 3 days
The fire intensified as it burned, eventually spreading to 14 other tanks located in the same containment area as Tank 80-8. It took three days to extinguish the fire, which caused substantial property damage to the facility, including the destruction of 15 80,000-barrel aboveground atmospheric storage tanks and their contents.
A shelter-in-place order was issued for the entire city of Deer Park due to benzene-related air quality concerns. Local schools and businesses either closed or operated under modified conditions as a result. A portion of a major highway in the area was also closed.
Containment wall collapse releases toxic liquid into waterways
To add insult to injury for the local community, a secondary containment wall surrounding the tank farm partially collapsed, allowing a mix of hydrocarbon products, firefighting foam and contaminated water to release into the surrounding waterways.
This resulted in the closure of a 7-mile stretch of the Houston Ship Channel adjacent to the facility. Several waterfront parks in Harris County and around the city of LaPorte also had to close down due to contamination.
No formal PSM program for Tank 80-8
The CSB found that ITC didn’t apply a formal PSM program to Tank 80-8 because the OSHA PSM standard didn’t apply to the tank and its equipment. Likewise, the Environmental Protection Agency (EPA) Risk Management Program (RMP) rule, which would also have required certain protections, didn’t apply. Those rules had a flammability rating exemption which applied to the butane-enriched naphtha mixture.
ITC did apply some PSM elements across the terminal, but certain key elements, such as the Mechanical Integrity and Process Hazard Analysis, weren’t in use for the atmospheric storage tanks containing highly hazardous chemicals.
Applying those key elements would have provided the company with “additional opportunities to identify and control hazards through multiple layers of protection,” including the multiple preventative and mitigative safeguards required by the PSM standard.
If ITC had developed and used a comprehensive PSM program, like the OSHA standard calls for, the issues regarding Tank 80-8’s pump and other equipment would have been detected and resolved, thus preventing the incident from occurring.
CSB calls on OSHA, EPA to expand PSM rules
CSB investigators found that OSHA’s and EPA’s failure to require ITC to have a formal PSM program for Tank 80-8 and its related equipment contributed to this incident.
The gaps in relevant regulations resulted in a lack of oversight that could have provided a process to identify and control the hazards leading to this catastrophic event.
As a result, the CSB issued recommendation to OSHA and the EPA to take action to address these regulatory gaps.
Companies have a duty of care to ensure safety at these facilities
The bottom line is that “companies have a duty of care to ensure safety at facilities that handle flammable or highly hazardous substances and protect surrounding communities and the environment regardless of whether the hazardous substances onsite fall under OSHA’s PSM standard or EPA’s RMP rule.”
The CSB states that to prevent catastrophic incidents, such as the one that occurred at the ITC facility, all companies that use hazardous chemicals in their processes “should apply a comprehensive process safety management system such as the Centre for Chemical Process Safety’s Guidelines for Risk Based Process Safety or Guidelines for Implementing Process Safety Management Systems.”
