Thursday, October 26, 2017

Canada's Chemical Valley - Industry and Municipality should get their act together!

Todays CP Morning Briefing get my attending with subject  "Ontario Government Ignores Engineers' Safety Concern".  In the Briefing it stated "New document says engineers were "muzzled" over safety concerns related to Sarnia's Chemical Valley". I used to live there. I used to work there. What is going on with an area once recognized to it's industry's safety attitude lead by companies such as Dupont and Imperial Oil? I clicked on the link to read the full briefing. It stated:
"Ontario engineers attempting to sound the alarm about public safety concerns in Sarnia’s Chemical Valley are being “muzzled,” according to a report cited by the National Observer.  The document is said to detail a meeting between the Office of the Environment Minister and the Professional Engineers Government of Ontario (PEGO), a union representing provincial engineers, and indicate that the government is ignoring concerns about chemical pollution from the area’s petrochemical refineries."
So it appears the government listen more to industry than their own employees. The information appear as part of a series called "The Price of Oil" published by National Observer. The CP Morning Briefing quotes from the article "Ontario government ignored public safety concerns, ‘muzzled’ engineers: document"  bCarolyn Jarvis & Andrew Russell October 17th 2017 as the 12th article in the series.
Sarnia, Imperial Oil, Global News, Canada's Toxic Secret, The Price of Oil

Sarnia used to have a excellent system for alerting residents about abnormal events in its Chemical Valley, and they properly still have. The system is financed by industry and consist of a red phones in all plant operating rooms directly connected to a central at the local police station. The plant with the abnormal event just picks up the phone an state that they have an abnormal situation in the plant with a certain severity. The severity code indicate the likely need for external assistance.

After an activation by one of the plants in the Chemical Vally it is up to the police and the municipality to decide if local residents should be alerted through an in homes alarm system and local radios. A 23 minutes video accompanying the article reveals two releases on two back to back days in 2014 from two different plants, which both lead to significant bad odors for local residents, and during which the police and municipality choose not to alert the public. Here is the description of one of these releases:
"At 3:25 p.m., in the middle of a frigid afternoon on Feb. 7, 2014, an alarm went off inside the Imperial Oil Refinery in Sarnia. A fuse leading to a heater had blown, causing a pipe to freeze and rupture, and over 500 kilograms of hydrocarbon gas spilled into the air. The plant went into lockdown, workers scurried to designated safe havens as the smell of gas drifted into nearby neighbourhoods.Residents reported burning eyes, dizziness and nausea. One woman on Facebook said the release “made my children start coughing and get headaches,” another observed that she suffered a “headache,” and “now I can’t stop vomiting.” Sarnia’s hospital declared a “code grey,” closing its air intake and postponing a surgery.Imperial notified Ontario’s Ministry of the Environment of the rupture and put out a press release. And that was that. At 8:28 p.m. an all-clear was issued. Local air monitoring in Sarnia hadn’t detected any “unsafe levels.”"
I remember from my time living in Sarnia, the local plants placed advertisements in the Sarnia Observer, when they had planned maintenance, which could produced increased noise and flaring, and provided a phone number to call with any concerns. 

I think the current situation with increased mistrust between residents and authorities is the result of chancing expectations, which the police and municipality have not recognized. The residents have come to expect to be informed about any event, which lead a plant to pick up the red phone, not just the ones you can clearly see from outside the plants. Then the residents can use their own judgement together with the information from authorities to decide what to do, e.g. shelter-in-place and stop ventilation or evacuate. What do you think?

A key concern stated in the video is that release of carcinogenic benzene in the Chemical Valley are 3 times the levels allowed by the provincial government, which appear to be very laks on enforcing the pollution limits on industry in the Chemical Valley. The video mention a number of cases of the blodcancers leukemia and myelodysplastic syndromes (MDS), which could be caused by exposure to benzene.

Naturally as a resident the less information you get from the plants and the authorities, e.g. police and municipality, the more concerned you get, when a friend or relative get seriously ill by cancer. If - as industry postulate - the level of chemicals in a release is of no concern to the public, then way not released the results of measurements made by plant staff and the municipality, and let the residents decide if they should be concerned?

I think openness with respect to all abnormal events serve both residents and industry best in the long run.

So let us get on with it!

Sunday, July 30, 2017

eJSA (electronic Job Safety Analysis) - A new name for a screwdriver?

The title of another article in the May issue of Hydrocarbon Processing had me thinking a bit about who does what in our refineries or chemical plants. The title was "Prevent human-created hazards with improved job safety analysis" by Mike Sawyer and Pathum Jayawardena.
The nature of refineries and chemical plants are processing of flammable and toxic substance. Such substances pose a hazards if they are not handled properly. But the above mentioned article made me think: Who creates the hazards?
And Sawyer and Jayawardena er right, the hazards are created by humans! The humans who design our refineries and chemical plants. They go on to argue, that since the harzards are created by humans, then they can be controlled by humans, and they furthers state, that the needed engineering is sound, practicable and available (Did they get the sequence wrong?). Therefore, they conclude, the reason we continue to have incidents, is that incomplete and inappropriate implementation of the engineered preventive measures. So there is a problem with the engineering.
A very simple advice about what to do before you start a job.
To my surprise they go on to suggest that the solution to the problem is job safety analysis. Do they mean job safety analysis of the engineering job? No. They actually appear to think, that the solution to an engineering problem is job safety analysis.
JSA is all about stopping up, and thinking before you start a job. Commonly JSA is performed as dry run of the job to be done. The dry run is performed away from the hazards, e.g. in a meeting room, and the purpose is clearly to make the person, who is going to do the job aware of the hazards and how to avoid the negative consequences of the hazards. However, in these modern IT times the authors suggest to use an electronic JSA or eJSA. A plus for the eJSA should be, that participants don't have to all be in the same location.

Here Sawyer and Jayawerdena appear to increase both ressource usage and bureaucracy by stating, that a trained hazard analysis facilitator should guide all involved through the analysis. Wait a minute! What is a hazard analysis facilitator? It is a position, which I have not heard about before. I think it would be more appropriate to use a JSA facilitator. In the company I started my career they were called supervisors. Then the authors state that a member of management or a designated representative must sign the form prior to the work being performed. Do they really mean the eJSA form? I think the permit to work forms used in all refineries and chemical plants I have been in, is the form that gives permission to actually carry out the job, and that form is - depending on severity of the hazards - normally signed by the shift superintendent.

Layout of Permit to Work System.
Specific types of permits may change from site to  site
The next suggestions are a bit fuzzy to me. Sawyer and Jayawerdena suggest that "eJSA should provide a database of pre-determined prevention techniqies, and goes on to discuss details of the eJSA form - or is it a database?

Conclusion: What Sawyer and Jayawerdena are discussing in their article in the May issue of Hydrocarbon Processing is normally called a Permit to Work (PW) system. And if a job requires personnel to perform highly hazardous jobs, then the PW form include a JSA.

PS: Maybe it is not a good idea to have school teachers write articles in Hydrocarbon Processing. At least that is my opinion.