Top 10 Ways to Prevent Chemical Plant and Storage Facilities Explosions

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Firestorm Expert Anyck Turgeon on Chemical Plant Safety

Anyck Turgeon Firestorm

The explosion at West Fertilizer Company’s storage facility in West, Texas on April 17, 2013 resulted in the death of 15 local residents and hundreds of injuries. Within a few hours, entire buildings and houses were pulverized leaving victims with crumbs of their life’s possessions and little hope for the future. As this incident was easily preventable, one needs to question the state of our needs versus our production and the safety measures used.

OUR DEPENDENCE ON FERTILIZERS:

Without fertilizer, millions of people would not exist today. Since World War II, fertilizer use expanded exponentially until early 1980s after reaching a peak of 23.7 million nutrient tons. The United States is one of the major global producers of fertilizer and this portion of its economy is critical as it feeds people all over the world. Per Wikipedia, “With an annual production of 12.5 million material tons of ammonia, the United States is the world’s third largest nitrogen fertilizer producer. The United States is the second largest phosphate-based fertilizer manufacturer on the globe producing over 10 million tons of phosphate (P2O5) yearly, which only trails China”. Given that nitrogen, phosphate and potassium (potash) are the main components to fertilizers and serve as the default chemical analysis identifier (like 10-20-10), it is important to realize the criticality of fertilizer production in the United States for food supply and global economy as the world depends on the United States to feed them.

Interestingly, The Fertilizer Institute (TFI) forecasts estimate the world’s population at nine billion by about 2050. Without fertilizer to boost crop production in the areas already cultivated, we would need to put additional land into production to keep people fed and healthy. In North America during the past 40 years, farmers have actually been able to use less land while tripling food production.

THE CASE FOR MORE SECURITY AT CHEMICAL PLANTS AND STORAGE FACILITIES

Unfortunately, as successful as our global and American fertilizer production has been, the on-going chemical explosions at manufacturing as well as storage facilities like in West, Texas (which are rarely disclosed and covered by the main media) make it clear that it

Chemical Quote

is time to use current security measures and enhance our safety practices. From visiting several chemical plants and storage facilities ranging from local public stores like Home Depot and Lowes to giant Dupont, Tenecco and Ultramar energy manufacturing plants, it is clear that smaller local production and storage facilities need to be held at much higher security standards. For example, along the same lines than your mother probably told you not to put your hand over a burning stove, it is not a good idea for plant employees to warm their contaminated hands and/or gloves from an open BBQ fire after handling toxic and explosive chemicals.

To this effect, in 2011, the US Department of Homeland Security (DHS) reported that more than one in three chemical facilities were ordered to remove highly toxic chemicals or to close their doors. A total of 1,600 chemical plants were deactivated and another 700 were re-aligned towards other functions.

An NBC news report found that the West Fertilizer Co. plant had 1,350 times the amount of chemicals that would trigger government oversight. As most fertilizer manufacturers and storage facilities carry a larger amount of toxic and explosive materials with high-rotation cycles between January and May, the presence of reported higher volumes and unknown chemicals is not surprising to most industry experts. Given the economic pressures experienced over the last years, many farmers and other fertilizer customers had limited their usage of fertilizer. Yet, as commodity prices for corn, wheat, soybeans and other crops peaked and demand for food increased, fertilizer manufacturers are now maximizing their relatively short production cycle to ensure revenue for the rest of the year (especially for meager months like December). The continuous pressure for higher profitability is an important motivator as current industry profit standards are estimated at 5 percent for smaller fertilizer producers. Also, it is important to note the willingness of the marketplace to pay higher rates for tailored fertilizing solutions (like higher moisture retention for Texas) – which demands the use of a larger variety of chemicals and offers a much better profit margin of around 38 percent. Therefore, it is quite common for fertilizing manufacturers and storage facilities, given the more sophisticated, locally-specific and lucrative needs of their clientele, to be carrying much larger volumes and varieties of chemicals than years before.

A separate key primary concern is the reported theft of toxic and explosive materials. Having heard from personnel at several chemical and storage sites about this common occurrence, one should question the reasons why such critical report tips of such actions are either lost or dismissed by federal and local authorities. From a chemical or storage management perspective, the opportunity to sell at a higher price and for profitability averaging of 33-80 percent after-hours to underground markets as well as securing insurance theft/loss money and declaring revenue loss towards lower income tax brackets is a very lucrative, intentional and serious fraud problem.

 

WHAT YOU SHOULD KNOW TO PROPERLY EXTINGUISH FIRES

Having been to a number of chemical production and storage facilities that had never been visited by local fire or police departments, one must question a plant’s ability to properly respond to a chemical fire with the right materials. For instance, electrical fires are considered class C and require a nonconductive extinguishing agent such as carbon dioxide (CO2). Extinguishers with a Blue Circle should be used rapidly in CO2 fire cases as this toxic element is merciless and remains to-date the fourth major cause of death in building fires. Below is a simple chart to assist readers in understanding various options to use in case of an emergency to dispose of the four major types of fires (e.g. heat, fuel, oxygen and chemical reaction) upon or after attempting to get professional assistance:

Fire Type Graph

As a chemical fire can progress quite rapidly from an incipient stage to smoldering, flame and heat stages, firefighters need a combination of solutions to properly deal with increasingly more complex situations such as the West Fertilizer Company plant explosion. For instance, in areas containing computers and electrical equipment, it is best to use noncorrosive chemical halogenated agents (1211, 1302) to extinguish fires. Unfortunately, water can’t be used in all occasions to extinguish everything so it is best to leave the responsibility of handling most explosions and fires to well-trained professionals. Remember that most fires are electrical in origin and that more fire fatalities result from toxic gases, smoke, high temperatures, CO2 and fear than from the flames and fire itself.  

TOP 10 TIPS TO PREVENT CHEMICAL PLANTS AND STORAGE FACILITY EXPLOSIONS

1)       Monthly reporting of chemical inventory to fire fighters and mutual aid associations -. Because most fertilizer plants use an electronic inventory management system, it would be easy for plant operators to generate monthly reports and forward them via e-mail to local fire departments and other first responders. Plants must ensure that losses are minimized and that inventory systems can’t be tampered with. Other measures include the use of fire sensors (such as ionization detectors for early warning, photoelectric smoke detection for interruption of the source of light or infrared flame detectors from flame emission or thermal detectors) that would alert plant operators and local emergency personnel of significant changes in temperature and any other possible dangers. Mutual aid associations which are cooperative organizations of industrial firms, business firms, and similar organizations can limit the damage of a disaster by providing material, equipment, and personnel support to a member in trouble. To be most effective, it is critical that accurate and updated information about inventory, floor plan and evaluation procedures be continuously provided to these organizations.

2)       Annual on-site inspections and interviews from one centralized agency – Most chemical production and storage plant managers are not in touch with their local authorities. It is troubling to discover that a large amount of uncovered minor explosions, fires and accidents that happen at chemical plants are never reported to governmental agencies, inspected by fire departments, or covered by the media. Given the recent discovery of “270 tons of ammonium nitrate at the West Fertilizer plant that were never reported in their 2011 risk management plan to DHS”, it is critical that on-site visits be completed at least yearly, preferably quarterly to monthly.

To accomplish such a task, the empowerment of one central agency is needed responsible for all aspects of chemical plant security is mandatory. Currently, as pointed out in a previously published chemical safety guide, one need to peruse through 74 pages of resources to assess the right place to call in case of such an emergency. Given the magnitude of the pulverization witnessed in West, Texas, it is clear that calling 911 upon the explosion is a little too late. Currently, agencies such as the Occupational Safety and Health Administration (OSHA) offer on-demand inspections which results in many plants not being properly inspected properly for five to fifteen years. Also, no plant manager wants to deal with dozens of inspections from multiple agencies to find out several months later if something is wrong; by then, it typically is too late. Further, as a result of budgetary cuts and an increase in bureaucratic report writing as well as agency promotions, OSHA has decreased its investigative staff by half since the 1990s, and, at Department of Homeland Security (DHS), a large amount of the new resources appears to be marketing consultants promoting “if you see something, say something”. Several inquiries over the last five years have shown a pattern of responsibility transfer from one agency such as OSHA to another such as the Environmental Protection Agency (EPA) or the Boiler Commission, leaving a number of requests, tips, questions and suggestions unanswered. As these agencies have different responsibilities pertaining to the security of chemical plants, it appears that there may be too many gaps for us to be truly safe. Finger pointing will not erase human losses, fix long-term health issues of surrounding communities or ensure the prevention of similar incidents. Further, due to the recent coverage about most US protection agencies being most overworked and underfunded – such as the US Chemical Board -, it is important that fines for safety breaches shall not be reduced nor exemptions to safety rules be provided freely. Oversight and fairness can be ensured by the use of pictures upon each on-site inspection and recorded ad-hoc staff interviews.

3)       Mandatory testing of all equipment on a quarterly basis – The gap between current safety compliance requirements and the need to protect local communities appears to have been increasing yearly – especially as many chemical plants are not well maintained and use equipment that has passed its safe lifespan. Having seen many plants in which fire extinguishers had expired several years ago, eye washers had vanished and main ceiling fans had ceased to operate, one would question why it is OK to let a fertilizer plant full of highly explosive materials operate in this manner when it is not acceptable in most stores or homes. In order to pass compliance requirements, extensive on-site testing of all physical and technology aspects of chemical plants as well as storage facilities should be performed by external qualified parties just like third-party auditors and accountants are used to review corporate financial statements. As safety tags can be easily tampered with, actual physical testing of every device and manual inventory reconciliation also needs to be completed in order to ensure proper functionality.

4)       Training of all plant staff on a weekly basis – There are lots of free training resources are offered on-line such as videos by DHS, written security recommendations by organizations like TFI and conferences organized by ASIS that can keep help save human lives. If there is an explosion, the knowledge that one remembers from training can make the difference between life and death. Free videos from the Chemical Sector-Specific Agency (SSA), within the National Protection and Programs Directorate’s Office of Infrastructure Protection of DHS are available at: http://www.dhs.gov/chemical-sector-training-and-resources and, from the private sector, the free Safety4Dumbies book at: http://www.safetyinfo.com/.

5)       No time limits on inquiries – The current guidelines for reporting tips are so stringent that poorly managed and operated chemical facilities such as West Fertilizer, keep finding ways to fall through the system. It is important to report that 27 percent of survey respondents informed DHS that they would be unlikely to report any incident at their plant for fear of losing their jobs, which is consistent with a history of retaliations that resulted in termination. Just like the unusual presence of the third largest national bladder cancer treatment center in Beaumont, Texas (e.g.,  the Beaumont Hospital, Royal Oak which has been named a Blue Distinction CenterSM for bladder cancer), it is obvious that the lack of follow-through is resulting in painful, long-term costs to our entire society. In this era of high-technology, advanced communications and transparency, one should be able to leverage all resources to follow-up on all potential security risks without unnecessary rules or boundaries.

6)       A complete human resources manual should be developed by all companies and include a printed comprehensive safety-security guide that can be easily accessed by all staff. Upon employment, all of these guidelines should be reviewed with the employees, whose understanding of all requirements should be confirmed in writing. On-going training about the basic corporate safety rules and updates should be provided at least yearly, ideally monthly.  

7)       All chemical plant/storage facilities and visitors staff requires decontamination rooms and safety gear respectively – Protective clothing, – especially chemical suit/coverall, aprons, gloves, steel-toe boots, eyewear, chemical gas respirator safety masks, protective hoods and hard hats often get contaminated in fertilizer and chemicals plants. Contaminated goods need to be removed in a dedicated decontamination area. It is the responsibility of management to adopt and enforce intense cleansing practices, including a separate change area for all personnel. A good manager needs to anticipate a higher replacement budget and should plan for a minimum of four sets of protective gears per individual per year. This is not a costly investment but, will save lives as well as minimize harsh workers’ comp lawsuits. Most importantly, as I have seen many sites where visitors and staff decide to take verbal personal responsibility and walk around without protective gear, it is important that usage of protective equipment be implemented at all times without exceptions.

8)       A central repository system – Although this may appear redundant given the first recommendation, it is an item that will require longer development. Perhaps of more immediate concern than the reporting of chemicals to the proper federal agencies is the lack of information provided to the local fire departments and other first responders. Whenever there is an accident, spill or explosion at a chemical or agricultural plant, first responders need an inventory of the chemicals that they might have to deal with. This is particularly important in the West explosion due the plant’s close proximity to two schools. City planning should be an on-going consideration and included as part of regular review sessions and a new consideration for the 6,000 sites identified as retail distribution centers such as West Fertilizer where farmers buy fertilizers may need to have much stricter zoning restrictions. Currently, there are too many exemptions that enable storage facilities to by-pass standard security practices that manufacturers are supposed to implement for us to be safe.

Back to the small and charming city of West in Texas, it was remarkable to notice sudden inundation by the media as well as physical security professionals such as law enforcement and first responders. For such an unknown small town, the costly death of humans is finally getting the interest of the media yet, as many similar but smaller type of incidents happen weekly, it is sad that nobody paid much attention until now. Speaking with a fire marshal in a smaller Canadian town similar to the one of West Texas, he admitted that such incident as the one is West could easily happen in his area but, that there would not be any possibility for them to handle such deluge of new resources. To ensure proper coordination (especially of such a large amount of new visiting resources), it would be critical to develop a robust external communication program as well as offer a central information system that included up-to-date information inventory, floor plans, contact list, etc. stored remotely at a set of two distant third party locations. This way, through portal access, authorized volunteer and professional resources could gain access to information without becoming an additional liability from their cell phones.

9)       Transparent as well as confidential Online and Phone Tips Reporting System – Of approximately 4,500 high-risk U.S. chemical plants, only 200 (75 of which were highly toxic) suspicious activity reports (SARs) were filed by designated agencies staff in 2011. This shows that there is a need for additional social-media and telephone reporting tools so the general public and employees learn quickly what to do in order to assist in holding all manufacturers and storage operators to higher operating standards. Another shocking fact is that sWhen citizens say something, it needs to be completely investigated and resolved. Smell complaints are critical and, trusting the answers provided by plant operators, management or legal representatives is not sufficient. To avoid legendary industry bribery, separate officers need to verify all tips on-site, frequently.

10)   Updating your Emergency Plan Director about Risk An emergency plan director is responsible for classifying an emergency, activating forces, ordering shutdown and evacuation, making announcements, requesting mutual aid and coordinating action. It is critical for this resource to be fluent with all chemicals, floor plans highlighting kill switches, boilers, computers and explosive as well as the combined chemical health risks. This person will serve as a liaison with outside agencies and, authorized to declare a state of emergency, to proceed with emergency shutdown, and to activate a remote control center. It is critical that this person be a top level manager and possesses a full understanding of chemistry. Due to the large amount of unusual chemicals that are typically present in fertilizer plants during the spring and fall seasons, the emergency plan director must understand the risk and be able to communicate them rapidly to all appropriate resources.  

So, as we all grieve such unfortunate losses, it is important that we act so we can pro-actively address our past mistakes and implement solutions for a healthier and safer future. Our next article about chemical explosions will address other necessary business protective measures such as insurance coverage and will expose the avoidance defense game of liabilities through bankruptcy.

RegisterJoin Firestorm President Jim Satterfield as he interviews Anyck on this subject, May 29th from 2-3 PM Eastern

 


 

About Anyck Turgeon:

With more than 25 years of technology innovation and security experience, Anyck Turgeon is a proven executive with unmatched end-to-end security expertise (including IT management, data security and privacy, fraud prevention/detection/management, governance/risk/compliance (GRC), physical security, chemical safety and executive/financial management).

M-CAT Enterprises is an end-to-end security solution provider whereas the Tech Innovation Network (TIN) is an online platform featuring the foremost tech innovation leaders delivering revolutionary solutions in areas such as high tech, clean tech, biotech, healthcare, fraud, GRC, security, privacy and nanotech. Since TIN’s first recorded radio show aired in 2009, Ms. Turgeon has interviewed eminent thought leaders about their ground-breaking solutions that led cleaner air, intelligent automation and, most importantly, legitimate economic growth. Her global audience surpasses 1,167,983 professionals in high-tech, law, fraud, GRC and executive business management…Read More

The explosion at West Fertilizer Company’s storage facility in West, Texas on April 17, 2013 resulted in the death of 15 local residents and hundreds of injuries.  Within a few hours, entire buildings and houses were pulverized leaving victims with crumbs of their life’s possessions and little hope for the future.  As this incident was easily preventable, one needs to question the state of our needs versus our production and the safety measures used.

OUR DEPENDENCE ON FERTILIZERS:

Without fertilizer, millions of people would not exist today.  Since World War II, fertilizer use expanded exponentially until early 1980s after reaching a peak of 23.7 million nutrient tons.  The United States is one of the major global producers of fertilizer and this portion of its economy is critical as it feeds people all over the world.  Per Wikipedia, “With an annual production of 12.5 million material tons of ammonia, the United States is the world’s third largest nitrogen fertilizer producer.  The United States is the second largest phosphate-based fertilizer manufacturer on the globe producing over 10 million tons of phosphate (P2O5) yearly, which only trails China”.  Given that nitrogen, phosphate and potassium (potash) are the main components to fertilizers and serve as the default chemical analysis identifier (like 10-20-10), it is important to realize the criticality of fertilizer production in the United States for food supply and global economy as the world depends on the United States to feed them.

Interestingly, The Fertilizer Institute (TFI) forecasts estimate the world’s population at nine billion by about 2050. Without fertilizer to boost crop production in the areas already cultivated, we would need to put additional land into production to keep people fed and healthy. In North America during the past 40 years, farmers have actually been able to use less land while tripling food production.

THE CASE FOR MORE SECURITY AT CHEMICAL PLANTS AND STORAGE FACILITIES

Unfortunately, as successful as our global and American fertilizer production has been, the on-going chemical explosions at manufacturing as well as storage facilities like in West, Texas (which are rarely disclosed and covered by the main media) make it clear that it is time to use current security measures and enhance our safety practices.  From visiting several chemical plants and storage facilities ranging from local public stores like Home Depot and Lowes to giant Dupont, Tenecco and Ultramar energy manufacturing plants, it is clear that smaller local production and storage facilities need to be held at much higher security standards. For example, along the same lines than your mother probably told you not to put your hand over a burning stove, it is not a good idea for plant employees to warm their contaminated hands and/or gloves from an open BBQ fire after handling toxic and explosive chemicals. 

To this effect, in 2011, the US Department of Homeland Security (DHS) reported that more than one in three chemical facilities were ordered to remove highly toxic chemicals or to close their doors. A total of 1,600 chemical plants were deactivated and another 700 were re-aligned towards other functions.

An NBC news report found that the West Fertilizer Co. plant had 1,350 times the amount of chemicals that would trigger government oversight. As most fertilizer manufacturers and storage facilities carry a larger amount of toxic and explosive materials with high-rotation cycles between January and May, the presence of reported higher volumes and unknown chemicals is not surprising to most industry experts.  Given the economic pressures experienced over the last years, many farmers and other fertilizer customers had limited their usage of fertilizer. Yet, as commodity prices for corn, wheat, soybeans and other crops peaked and demand for food increased, fertilizer manufacturers are now maximizing their relatively short production cycle to ensure revenue for the rest of the year (especially for meager months like December). The continuous pressure for higher profitability is an important motivator as current industry profit standards are estimated at 5 percent for smaller fertilizer producers.  Also, it is important to note the willingness of the marketplace to pay higher rates for tailored fertilizing solutions (like higher moisture retention for Texas) – which demands the use of a larger variety of chemicals and offers a much better profit margin of around 38 percent.  Therefore, it is quite common for fertilizing manufacturers and storage facilities, given the more sophisticated, locally-specific and lucrative needs of their clientele, to be carrying much larger volumes and varieties of chemicals than years before.

A separate key primary concern is the reported theft of toxic and explosive materials.  Having heard from personnel at several chemical and storage sites about this common occurrence, one should question the reasons why such critical report tips of such actions are either lost or dismissed by federal and local authorities.  From a chemical or storage management perspective, the opportunity to sell at a higher price and for profitability averaging of 33-80 percent after-hours to underground markets as well as securing insurance theft/loss money and declaring revenue loss towards lower income tax brackets is a very lucrative, intentional and serious fraud problem. 

WHAT YOU SHOULD KNOW TO PROPERLY EXTINGUISH FIRES

Having been to a number of chemical production and storage facilities that had never been visited by local fire or police departments, one must question a plant’s ability to properly respond to a chemical fire with the right materials.  For instance, electrical fires are considered class C and require a nonconductive extinguishing agent such as carbon dioxide (CO2).  Extinguishers with a Blue Circle should be used rapidly in CO2 fire cases as this toxic element is merciless and remains to-date the fourth major cause of death in building fires.  Below is a simple chart to assist readers in understanding various options to use in case of an emergency to dispose of the four major types of fires (e.g. heat, fuel, oxygen and chemical reaction) upon or after attempting to get professional assistance:

As a chemical fire can progress quite rapidly from an incipient stage to smoldering, flame and heat stages, firefighters need a combination of solutions to properly deal with increasingly more complex situations such as the West Fertilizer Company plant explosion.  For instance, in areas containing computers and electrical equipment, it is best to use noncorrosive chemical halogenated agents (1211, 1302) to extinguish fires.  Unfortunately, water can’t be used in all occasions to extinguish everything so it is best to leave the responsibility of handling most explosions and fires to well-trained professionals.  Remember that most fires are electrical in origin and that more fire fatalities result from toxic gases, smoke, high temperatures, CO2 and fear than from the flames and fire itself.   

TOP 10 TIPS TO PREVENT CHEMICAL PLANTS AND STORAGE FACILITY EXPLOSIONS

1)       Monthly reporting of chemical inventory to fire fighters and mutual aid associations -. Because most fertilizer plants use an electronic inventory management system, it would be easy for plant operators to generate monthly reports and forward them via e-mail to local fire departments and other first responders. Plants must ensure that losses are minimized and that inventory systems can’t be tampered with.  Other measures include the use of fire sensors (such as ionization detectors for early warning, photoelectric smoke detection for interruption of the source of light or infrared flame detectors from flame emission or thermal detectors) that would alert plant operators and local emergency personnel of significant changes in temperature and any other possible dangers. Mutual aid associations which are cooperative organizations of industrial firms, business firms, and similar organizations can limit the damage of a disaster by providing material, equipment, and personnel support to a member in trouble.  To be most effective, it is critical that accurate and updated information about inventory, floor plan and evaluation procedures be continuously provided to these organizations.

2)       Annual on-site inspections and interviews from one centralized agency – Most chemical production and storage plant managers are not in touch with their local authorities.  It is troubling to discover that a large amount of uncovered minor explosions, fires and accidents that happen at chemical plants are never reported to governmental agencies, inspected by fire departments, or covered by the media.  Given the recent discovery of “270 tons of ammonium nitrate at the West Fertilizer plant that were never reported in their 2011 risk management plan to DHS”, it is critical that on-site visits be completed at least yearly, preferably quarterly to monthly.

To accomplish such a task, the empowerment of one central agency is needed responsible for all aspects of chemical plant security is mandatory.  Currently, as pointed out in a previously published chemical safety guide, one need to peruse through 74 pages of resources to assess the right place to call in case of such an emergency. Given the magnitude of the pulverization witnessed in West, Texas, it is clear that calling 911 upon the explosion is a little too late.  Currently, agencies such as the Occupational Safety and Health Administration (OSHA) offer on-demand inspections which results in many plants not being properly inspected properly for five to fifteen years.  Also, no plant manager wants to deal with dozens of inspections from multiple agencies to find out several months later if something is wrong; by then, it typically is too late. Further, as a result of budgetary cuts and an increase in bureaucratic report writing as well as agency promotions, OSHA has decreased its investigative staff by half since the 1990s, and, at Department of Homeland Security (DHS), a large amount of the new resources appears to be marketing consultants promoting “if you see something, say something”. Several inquiries over the last five years have shown a pattern of responsibility transfer from one agency such as OSHA to another such as the Environmental Protection Agency (EPA) or the Boiler Commission, leaving a number of requests, tips, questions and suggestions unanswered.  As these agencies have different responsibilities pertaining to the security of chemical plants, it appears that there may be too many gaps for us to be truly safe.  Finger pointing will not erase human losses, fix long-term health issues of surrounding communities or ensure the prevention of similar incidents. Further, due to the recent coverage about most US protection agencies being most overworked and underfunded – such as the US Chemical Board -, it is important that fines for safety breaches shall not be reduced nor exemptions to safety rules be provided freely.  Oversight and fairness can be ensured by the use of pictures upon each on-site inspection and recorded ad-hoc staff interviews.

3)       Mandatory testing of all equipment on a quarterly basis – The gap between current safety compliance requirements and the need to protect local communities appears to have been increasing yearly – especially as many chemical plants are not well maintained and use equipment that has passed its safe lifespan.  Having seen many plants in which fire extinguishers had expired several years ago, eye washers had vanished and main ceiling fans had ceased to operate, one would question why it is OK to let a fertilizer plant full of highly explosive materials operate in this manner when it is not acceptable in most stores or homes. In order to pass compliance requirements, extensive on-site testing of all physical and technology aspects of chemical plants as well as storage facilities should be performed by external qualified parties just like third-party auditors and accountants are used to review corporate financial statements.  As safety tags can be easily tampered with, actual physical testing of every device and manual inventory reconciliation also needs to be completed in order to ensure proper functionality.

4)       Training of all plant staff on a weekly basis – There are lots of free training resources are offered on-line such as videos by DHS, written security recommendations by organizations like TFI and conferences organized by ASIS that can keep help save human lives.  If there is an explosion, the knowledge that one remembers from training can make the difference between life and death.  Free videos from the Chemical Sector-Specific Agency (SSA), within the National Protection and Programs Directorate’s Office of Infrastructure Protection of DHS are available at: http://www.dhs.gov/chemical-sector-training-and-resources and, from the private sector, the free Safety4Dummy book at: http://www.safetyinfo.com/.

5)       No time limits on inquiries – The current guidelines for reporting tips are so stringent that poorly managed and operated chemical facilities such as West Fertilizer, keep finding ways to fall through the system. It is important to report that 27 percent of survey respondents informed DHS that they would be unlikely to report any incident at their plant for fear of losing their jobs, which is consistent with a history of retaliations that resulted in termination.  Just like the unusual presence of the third largest national bladder cancer treatment center in Beaumont, Texas (e.g.,  the Beaumont Hospital, Royal Oak which has been named a Blue Distinction CenterSM for bladder cancer), it is obvious that the lack of follow-through is resulting in painful, long-term costs to our entire society. In this era of high-technology, advanced communications and transparency, one should be able to leverage all resources to follow-up on all potential security risks without unnecessary rules or boundaries.   

6)       A complete human resources manual should be developed by all companies and include a printed comprehensive safety-security guide that can be easily accessed by all staff.  Upon employment, all of these guidelines should be reviewed with the employees, whose understanding of all requirements should be confirmed in writing.  On-going training about the basic corporate safety rules and updates should be provided at least yearly, ideally monthly.    

7)       All chemical plant/storage facilities and visitors staff requires decontamination rooms and safety gear respectively – Protective clothing, – especially chemical suit/coverall, aprons, gloves, steel-toe boots, eyewear, chemical gas respirator safety masks, protective hoods and hard hats often get contaminated in fertilizer and chemicals plants. Contaminated goods need to be removed in a dedicated decontamination area. It is the responsibility of management to adopt and enforce intense cleansing practices, including a separate change area for all personnel. A good manager needs to anticipate a higher replacement budget and should plan for a minimum of four sets of protective gears per individual per year.  This is not a costly investment but, will save lives as well as minimize harsh workers’ comp lawsuits.  Most importantly, as I have seen many sites where visitors and staff decide to take verbal personal responsibility and walk around without protective gear, it is important that usage of protective equipment be implemented at all times without exceptions.

8)       A central repository system – Although this may appear redundant given the first recommendation, it is an item that will require longer development. Perhaps of more immediate concern than the reporting of chemicals to the proper federal agencies is the lack of information provided to the local fire departments and other first responders. Whenever there is an accident, spill or explosion at a chemical or agricultural plant, first responders need an inventory of the chemicals that they might have to deal with. This is particularly important in the West explosion due the plant’s close proximity to two schools. City planning should be an on-going consideration and included as part of regular review sessions and a new consideration for the 6,000 sites identified as retail distribution centers such as West Fertilizer where farmers buy fertilizers may need to have much stricter zoning restrictions. Currently, there are too many exemptions that enable storage facilities to by-pass standard security practices that manufacturers are supposed to implement for us to be safe.

Back to the small and charming city of West in Texas, it was remarkable to notice sudden inundation by the media as well as physical security professionals such as law enforcement and first responders.  For such an unknown small town, the costly death of humans is finally getting the interest of the media yet, as many similar but smaller type of incidents happen weekly, it is sad that nobody paid much attention until now.  Speaking with a fire marshal in a smaller Canadian town similar to the one of West Texas, he admitted that such incident as the one is West could easily happen in his area but, that there would not be any possibility for them to handle such deluge of new resources.  To ensure proper coordination (especially of such a large amount of new visiting resources), it would be critical to develop a robust external communication program as well as offer a central information system that included up-to-date information inventory, floor plans, contact list, etc. stored remotely at a set of two distant third party locations. This way, through portal access, authorized volunteer and professional resources could gain access to information without becoming an additional liability from their cell phones. 

9)       Transparent as well as confidential Online and Phone Tips Reporting System – Of approximately 4,500 high-risk U.S. chemical plants, only 200 (75 of which were highly toxic) suspicious activity reports (SARs) were filed by designated agencies staff in 2011.  This shows that there is a need for additional social-media and telephone reporting tools so the general public and employees learn quickly what to do in order to assist in holding all manufacturers and storage operators to higher operating standards.  Another shocking fact is that sWhen citizens say something, it needs to be completely investigated and resolved.  Smell complaints are critical and, trusting the answers provided by plant operators, management or legal representatives is not sufficient.  To avoid legendary industry bribery, separate officers need to verify all tips on-site, frequently.

10)   Updating your Emergency Plan Director about Risk An emergency plan director is responsible for classifying an emergency, activating forces, ordering shutdown and evacuation, making announcements, requesting mutual aid and coordinating action. It is critical for this resource to be fluent with all chemicals, floor plans highlighting kill switches, boilers, computers and explosive as well as the combined chemical health risks.  This person will serve as a liaison with outside agencies and, authorized to declare a state of emergency, to proceed with emergency shutdown, and to activate a remote control center. It is critical that this person be a top level manager and possesses a full understanding of chemistry.  Due to the large amount of unusual chemicals that are typically present in fertilizer plants during the spring and fall seasons, the emergency plan director must understand the risk and be able to communicate them rapidly to all appropriate resources.      

So, as we all grieve such unfortunate losses, it is important that we act so we can pro-actively address our past mistakes and implement solutions for a healthier and safer future.  Our next article about chemical explosions will address other necessary business protective measures such as insurance coverage and will expose the avoidance defense game of liabilities through bankruptcy. 

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