Ethics in oil companies and in drug companies

Image is important to both oil companies and drug companies. The image of a company can be quickly damaged by reaction of the public as in the story about the News ofthe World, which was developing as I started writing this, or by investigative journalism such as in the story in a Danish tabloid about GEHealthcare's Omniscan (Use Google translate if you want to read this Danish article) which can result in the rare but deadly decease NSF or nefrogene systemic fibrosis in patient with a weakened kidney, or by an unfortunate bad luck as in the case of B.P.'s deep water well in the Gulf of Mexico where the shears hammered into a solid connection between pipe sections instead of cutting the pipe.

Image is preserved by doing and being seen to do the ethically right things in the eyes of the public, which include both shareholders and customers as well as regulators in government or local authorities.

In the case of the drug company it is alleged that GE Healthcare withheld information from doctors testing their drug for use on patient with weakened kidneys. The withheld information is alleged to include experiments in 1989 with rats becoming ill from the drug, published in Investigative Radiology, and unpublished experiments in 1992 with rabits with similar results as well as experiments by the Belgian chemistry professor Robert Müller in 1994 using the active ingredient in Omniscan, gadolinium. Maybe the harm to GE Healthcare from the ongoing debate about this issue in Denmark will be minor. Only the future will show.

However, in 1989 Exxon experienced what is properly the worst environmental disaster in our life time. The tanker Exxon Valdez ran aground in Prince Williams Sound on Bligh Reef shortly after leaving Alaska for Long Beach in California. It has taken years for the nature in the cold Alaskan waters to recover from the huge spill. Exxon's board reacted. OIMS - Operations Integrity Management System was introduced. And more than 20 years later OIMS is still hard at work in Exxon. Maybe built in problem escalation procedures in OIMS was the reason Exxon did not years earlier experience an event like the blow-out of a deep water well experienced by BP in 2010!

I actually begin to thing the deference between the leaders in process safety and the followers are all in the ethical approach to running the company.

Eliminate producing to storage!

In the June 2012 issue of Hydrocarbon Processing was an excellent article titled ”The Bhopal disaster” providing another view of this tragic event, which caused the loss of lives of thousands of innocent people around the chemical plant. Ever since reading the article I wanted to write a note to the editors of  Hydrocarbon Processing, but apparently this proud magazine don't deal with their readers. At least I have not found a letter-to-the-editor section in the magazine, or even an e-mail address to the editors.  In stead I have decided to publish my thoughts here. At the time of the event I was a relatively young process control engineer at a petrochemical facility in Sarnia, Ontario, and even though the disaster happened on the other side of the world we were very much influenced by it.

Can it happen in our backyard?

One of the issues I and my colleagues discussed in the days and weeks after the event: Can this happen in our plant? It can! Al it takes is one single management decision to reduce process safety. At Bhopal that management decision was to continue the production of MIC, while the MIC consuming process was not running. Why was this decision made? There was of course many other management decisions, that contributed to the scale of the disaster, such as the cooling system for the MIC storage tanks and the maintenance work initiated on other pieces of equipment meant to mitigate a release.

Trevor Ketch has many times stated, that what you don't have can't hurt you – or anyone.  I interpret this to mean, that you should not produce hazardous intermediates such as MIC to storage, just because the storage is there. At Bhopal the purpose of the two large horizontal storage cylinders was originally not storing locally produced MIC. It was storing MIC imported from the UCC plant at Institute in West Virginia. The huge storage capacity was designed with disruption of supply in mind. The lesson to be learned from this is: If a facility is no longer needed, then shut it down, and remove it. And also when you design flexibility into a plant by providing storage of intermediate hazardous materials, then consider the business trade off of a major process safety event involving this hazardous material and a restart of the unit producing the hazardous material, when the consuming unit is not consuming for whatever reasons.

A close call in Europe

Europe had a little known close call of a similar disaster during the flooding in major parts of central Europe in the summer of 2003. During the flooding a prior decision to produce chlorine to storage was a contributing factor in a release of about 80 tons of chlorine  The partly filled chlorine tanks were not designed for the buoyancy created when more than 10 meters of water covered the tanks. So one of the tanks were torn of its foundation and the buoyancy ripped apart the piping to and from the tank. The heavy chlorine gas spread along the ground, but lifted due to dilution a short distance from a population center as evidenced by pictures of bushes, that were red on one side due to chlorine exposure, and normal green on the other side. The chlorine consuming part of the plant was shut down earlier in that year after an explosion. But management decided to continue producing chlorine to storage.

Time for a new strategy

Maybe the chemical engineering community should start adopting the strategy used by Dow Chemicals at their diisotoluene plant at Freeport, which uses phosgene as an intermediate, to eliminate intermediate storage of hazardous materials consumed in the same facility. Dupont toke that same path already in 1984, when management decided not to start up a new facility which involved intermediate storage of MIC. The MIC storage was eliminated, and the facility later successfully started up. In contrast to this the former UCC facility at Institute produced MIC until a few years ago.

So in my view until the decisions on the management layer are corrected, then the decisions by the engineers in the plant will only have limited impact on process safety performance of chemical plants worldwide.

Can complex fire fighting be reduced to just 3 things?

You know how with time you get to trust certain publications more than others. Then it is almost unbearable when that trust is broken. For a long time I have considered Hydrocarbon Processing a good and reliable source of information about anything relating to the hydrocarbon processing industries, and of-course I am particularly interested in articles about plant safety. However, when reading an article in the November issue I became quite disappointed by the effort of the editor and author of the HP Special Report "Keep it simple: Three key elements to fighting complex flammable liquid fires".

The author of the article goes to great lengths not to reveal details about the event. Although he does state, that the fire occurred at a refinery in Baton Rouge, Louisiana in December 1989, and that an 8-inch product line was involved. A quick googling with the search terms: fire baton rouge december 1989, gave a results page on which the first six results indicated, the event which is the basis for the HP article is the December 24th, 1989 explosion and fire at Exxon's (now Exxon Mobil's) Baton Rouge refinery. Even though the HP article contain numerous details such as the amount of hydrocarbons released and the over-pressure from the initial explosion and also details about the what the fire chief of the refinery was doing at the time of the explosion no references are given. Also the authors relation to the event is unclear, but I guess he is working for company selling foam concentrate.
For a good description of what happened in Baton Rouge on December 24th,1989 I would recommend the article "Bad Santa" in Industrial Fire World based on a presentation at a conference in March 2006 by Jerry Craft, who was fire chief at Exxon's Baton Rouge Refinery at the time of the event, and the article "Tale of Two Cities: Baton Rouge, 1989 & Buncefield, 2005" from the website of Williams Fire, and the New York Times news story from December 25th, 1989 as well as the description in Roy E. Sanders book "Chemical Process Safety: Learning From Case Histories".

Now back to the HP article. The first sub-headline is "Power loss leads to fire". This appear not to be the case based on the 2006 conference presentation published on IFW. Neither does the New York Times article from Christmas Day 1989 mention anything about a power outage prior to the explosion and fire. Nor does Roy E. Sanders in his short description of the event. However, according to the 2006 conference presentation the explosion of the vapor cloud did knock-out power at the refinery and several other process plants in the area. The authors continue "Due to abnormal freezing temperatures, this power outage caused the facility systems to go into fail-safe mode". The abnormal freezing temperatures had nothing to do with going into fail-safe mode, but the power failure AFTER the explosion caused the refinery to go into fail safe mode. It is unfortunate, when such erroneous cause-effect relations are stated in an article without any source references.
Only two places in the article refer to three key elements. That is in the introduction, and according to the author the elements are 1) high quality foam concentrate, 2) simplistic equipment, and 3) deploying the right fire fighting method. I expected to read more about these elements in the article, but I have failed to find that.
In the last subsection "Post-incident analysis" I am presented with some rather general statements about such analysis and its virtue before the three key elements - simple equipment, high-quality foam concentrate and good understanding of hazardous situation - are repeated  However, fighting the Baton Rouge refinery fire successfully required complex resources such as areal images from helicopters to create overview of the many fires, creativity in connecting a 20-inch water supply to a 2-inch hose, creativity in laying out hoses, creativity in keeping the fires at bay until a foam attack was possible and several high powered pumps to apply water and foam. Simple it was not!
The second last subsection "Training is key", and I can only say "Yes, of course!". Having been associated with the petrochemical industry in Sarnia's Chemical Valley I learned firsthand how training together on major simulated events, such as a fully evolved tank fire, was a key to working together in a  real event. However, also here the author seem to attempt to hide or obscure information. For example "the refinery fire department" have become "the team permanently situated at the refinery", and "emergency situation" have become "dynamic emergency situation". Is there such a thing as a "non-dynamic emergency situation"? Similarly "The team that responded", when it is well known from public available sources, that Williams Fire and Hazard Control was CALLED-IN to assist with the fire fighting and especially the foam attack. Or "The potential of a fire on the magnitude of the 1989 Louisiana refiney blaze", when "The likelihood of a fire on the magnitude of the 1989 Louisiana refinery blaze" is properly what was meant?

Since the initial release in the Christmas Eve 1989 event was caused by the rupture of an 8-inch product line, I am surprised, that none of the sources mention anything about liquid relief valves. Could it be, that the pipeline designers had not expected temperatures as low as those experienced in December 1989 for extended periods of time, and therefore assumed the content of the pipeline would always be gas?

The problem with the HP Special Report in the area Plant Safety and Environment I write about here is that it attempts to simplify the fighting of a complex huge fire such as the one at Exxon's Baton Rouge Refinery on Christmas Eve 1989 to just three elements. The idea reducing fighting complex flammable liquid fires to just three elements is a good one. However, if I should select the three elements, then they would be: 1) Full scale exercises involving all potentially teams at least twice a year: once at the area level involving a whole site event and the whole community, and once at the plant level involving a unit event and the whole site with mutual aid assistance, 2) Table top exercises three to four times a year involving all fire chiefs at area plants focusing on strategies of cooperation and attack, 3)  Ensuring the area - together - have the necessary equipment and other resources, e.g. foam concentrate in sufficient amount, getting area views of emergencies in real time, or movement of rail cars, and 4) A system to keep track of what each member of each team is doing to facilitate personnel exchange during the event. Ups! That was four!

If one wants to sell more foam concentrate, then maybe it would be a good idea to write an article about its properties of different types of foam concentrate and the equipment needed to mix it as well as video clips of how efficient foam is in quenching a hydrocarbon fire. If your company handle hydrocarbons, then you must make certain you have the right foam concentrate and equipment. For example are not all types of foam is equally useful on fires involving alcohols.

I hope everyone will have safe 2013, and that some of us will meet at the 2013 Loss Prevention Symposium in Florence, Italy in May.