Post-Harvey Lessons For Chemical Plant Managers

One of the many hazards exposed by Hurricane Harvey occurred in Crosby, Texas, when the Arkema chemical plant suffered fires and small explosions on Aug. 31 and Sept. 1. Floodwaters caused the fires by penetrating the facility and shutting down the cooling systems designed to stabilize 500,000 pounds of highly flammable materials inside. This ultimately caused a mandatory evacuation for all residents within a 1.5-mile radius of the plant. Local news outlets reported that Arkema had no plan in place for six feet of flooding and its last risk assessment was submitted in 2013.

With Hurricane Irma being tracked at 175 miles per hour in the Caribbean, it is possible that chemical plants in the path of destruction—including Florida and the southeastern United States—may face a similar scenario. Regardless of the location of your plant, here are some tips that can help reduce potential business interruption and physical injury during a major natural disaster:

Update your risk assessment. Use Harvey as a catalyst to revisit your risk assessment, especially since new information has emerged about the potential for natural hazards or disasters that can trigger a chemical accident. As recently discussed, the best assessments do more than just feature a column of checked boxes to achieve an organization’s objectives and mitigate business interruption. “They prioritize top risks, assign risk ownership, and most critically, integrate risk management and accountability into front line business decision-making,” says Dean Simone, PWC’s U.S., Asia-Pacific, and Americas Cluster Risk Assurance Leader.

Submit the assessment to the EPA or other government-appointed body, like your state’s Commission on Environmental Quality. Your facility needs to be able to withstand significant damage to prevent further incidents and public harm. The feedback will hopefully provide some useful criticism to ensure public safety and business continuity.

According to ABC’s Houston affiliate:

In at least one of Arkema’s hazard mitigation plans filed with the federal government, plant officials acknowledged that flooding is a risk. The site sits in a FEMA “high-risk” floodplain that has flooded in the past, leading to a power failure. That time, the site only had six inches of water, a former plant worker said.

It was later revealed in an internal company timeline of events that Arkema did not move temperature-sensitive chemicals via refrigerated trucks and instead banked on its two backup systems, which failed. It seems certain that Arkema will have to consider at least six feet of floodwater when it revises its plan.

Institute an emergency plant management system. This may be included in your company’s risk assessment, and it is important that your employees also know the protocol when it comes to disaster prevention. This includes establishing the lines of authority and communication while on-site and during a catastrophe. OSHA provides guidance for chemical plant management in the event of a mass disaster.

Develop public-facing communications plans. Your communications team, led by an executive officer, should have advisory plans in place in anticipation of, during and following an emergency. The good news is that you don’t have to draft them from scratch. The Centers for Disease Control and Prevention (CDC) offers communications worksheets, templates and guides dedicated to water, sanitation and hygiene-related emergencies and outbreaks. You can customize these documents to reflect your organization’s capabilities and to alert nearby residents and businesses.

Be sure to issue advisories through all possible outlets, including social media. One thing Arkema did correctly was send press releases, incident statements and alerts via Twitter in addition to traditional outlets in order to keep as many people informed as possible.

Communicate with local authorities and emergency workers. All energy plants impact their local communities, surrounding areas and ecosystems. Your company’s hazard plans should be communicated to local fire and police departments and hospitals. This ensures that emergency workers know the potential dangers your plant faces in the event of a disaster and the steps you plan to take to mitigate them.

Preventing Heat Illness: Water, Rest, Shade

With summer comes hot, humid weather and a greater chance of heat-related illness for outdoor workers. How to prevent heat illness? Three words: water, rest and shade, according to the Occupational Safety and Health Administration (OSHA).

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Heat illness is not to be taken lightly—in 2014, 2,630 workers suffered from heat illness and 18 died from heat stroke and other heat-related conditions on the job. Workers most at risk are those exposed to hot and humid conditions, especially those whose jobs require heavy lifting or heavy work tasks and who wear dense or bulky clothing and equipment.

Industries most affected by heat-related illness are construction, trade, transportation and utilities, agriculture, grounds maintenance, landscaping services and support activities for oil and gas operations, OSHA said. Workers who have not built up a tolerance to heat, including new workers, temporary workers, or those returning to work after a week or more off are all at greater risk, and all workers are at risk during a heat wave.

The body normally cools itself by perspiring. During hot weather, however, especially in high humidity conditions, sweating isn’t enough to keep the body cool. To keep body temperature from rising to dangerous levels, OSHA suggests drinking water and resting in the shade to prevent heat exhaustion or heat stroke.

If a worker becomes ill, OSHA recommends:

  • Call a supervisor for help. If a supervisor is not available, call 911.
  • Have someone stay with the worker until help arrives.

According to the Mayo Clinic, heatstroke symptoms include:

  • High body temperature. A body temperature of 104⁰ F or higher is the main sign of heatstroke.
  • Altered mental state or behavior. Confusion, agitation, slurred speech, irritability, delirium, seizures and coma can all result from heatstroke.
  • Alteration in sweating. In heatstroke brought on by hot weather, your skin will feel hot and dry to the touch. However, in heatstroke brought on by strenuous exercise, your skin may feel moist.
  • Nausea and vomiting. You may feel sick to your stomach or vomit.
  • Flushed skin. Your skin may turn red as your body temperature increases.
  • Rapid breathing. Your breathing may become rapid and shallow.
  • Racing heart rate. Your pulse may significantly increase because heat stress places a tremendous burden on your heart to help cool your body.
  • Headache. Your head may throb.

The Mayo Clinic urges immediate action to cool the overheated person while waiting for emergency treatment, including:

  • Get the person into shade or indoors.
  • Remove excess clothing.
  • Cool the person with whatever means available—put in a cool tub of water or a cool shower, spray with a garden hose, sponge with cool water, fan while misting with cool water, or place ice packs or cold, wet towels on the person’s head, neck, armpits and groin.

OSHA Releases Updated Workplace Safety and Health Voluntary Practices

To help medium and smaller-size businesses initiate effective safety and health programs, the Occupational Safety and Health Administration today released Recommended Practices for Safety and Health Programs, an update of its 1989 guidelines, reflecting changes in the economy, workplaces, and evolving safety and health issues. The recommendations feature a new section on multi-employer workplaces and a greater emphasis on continuous improvement, OSHA said.

“Since OSHA’s original guidelines were published more than 25 years ago, employers and employees have gained a lot of experience in how to use safety and health programs to systematically prevent injuries and illnesses in the workplace,” Dr. David Michaels, assistant secretary of labor for occupational safety and health said in a statement. “We know that working together to implement these programs will help prevent injuries and illnesses, and also make businesses more sustainable.”
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The recommendations include seven core elements for a safety and health program:

• Management leadership
• Worker participation
• Hazard identification and assessment
• Hazard prevention and control
• Education and training
• Program evaluation and improvement
• Communication and coordination for host employers, contractors and staffing agencies

Implementing recommended practices brings benefits to businesses that include healthier employees, fewer injuries and, ultimately, lower workers compensation costs:

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  • Preventing workplace injuries and illnesses
  • Improving compliance with laws and regulations
  • Reducing costs, including reductions in workers compensation premiums
  • Engaging workers
  • Enhancing their social responsibility goals
  • Increasing productivity and enhancing overall business operations

Because management leadership is an important part of the equation, OSHA recommends that business owners, managers, and supervisors:

  • Make worker safety and health a core organizational value.
  • Be fully committed to eliminating hazards, protecting workers, and continuously improving workplace safety and health.
  • Provide sufficient resources to implement and maintain the safety and health program.
  • Visibly demonstrate and communicate their safety and health commitment to workers and others.
  • Set an example through their own actions.

To establish a program, OSHA said organizations need to create a written policy signed by top management that describes the organization’s commitment to safety and health. By creating specific goals and objectives, management sets expectations for the company’s managers, supervisors and workers. The goals and objectives should focus on specific actions that will improve workplace safety and health, OSHA said.

Tyson Foods Cited for Violations after Employee Finger Amputation

Cited for multiple violations, Tyson Foods was fined $263,498 by the U.S. Department of Labor Occupational Safety and Health Administration after an employee’s finger was amputated in an unguarded conveyor belt, the DOL reported yesterday.

Inspectors found recessed drains and fire hazards resulting from improperly stored compressed gas cylinders, which exposed employees to slip-and-fall hazards due to a lack of proper drainage.

Established in 1935 and headquartered in Springdale, Arkansas, Tyson is the world’s Tysonlargest meat and poultry processing company, with more than $40 billion in annual sales. The company produces more than 68 million pounds of meat per week. OSHA gave Tyson 15 business days from receipt of its citations to comply, request an informal conference with OSHA’s area director, or contest the citations and penalties before the independent Occupational Safety and Health Review Commission.

“Tyson Foods must do much more to prevent disfiguring injuries like this one from happening,” Dr. David Michaels, assistant secretary of labor for Occupational Safety and Health, said in a statement. “As one of the nation’s largest food suppliers, it should set an example for workplace safety rather than drawing multiple citations from OSHA for ongoing safety failures.”

OSHA inspectors found more than a dozen serious violations, including:

  • Failing to ensure proper safety guards on moving machine parts
  • Allowing carbon dioxide levels above the permissible exposure limit
  • Failing to provide personal protective equipment
  • Exposing employees to an airborne concentration of carbon dioxide
  • Not training employees on hazards associated with peracetic acid and other chemicals.

OSHA also cited the company for repeated violations for not making sure employees used appropriate eye or face protection when exposed to eye or face hazards. The agency cited Tyson for a similar violation in a 2012 investigation at its Carthage facility. The company also failed to separate compressed gas cylinders of oxygen and acetylene while in storage – a violation for which OSHA cited the company in 2013 at its facility in Albertville, Alabama.

According to OSHA, the inspection falls under its Regional Emphasis Program for Poultry Processing Facilities.