Category Archives: Emergency response

Safety Performance vs Production Costs

Are these two forces at loggerhead?

The Wall Street Journal just published an article on June 29, 2010 on this thorny topic. This generally pro-business newspaper wrote a scathing expose on how cost cuttings at BP have affected its safety performance.

The paper cites an internal BP investigation that a small oil spill from a BP oil platform in 2008 was caused by a “defective pipeline pump that BP had put off repairing” in the “context of a tight cost budget.” The budget was “underestimated” resulting in “conflicting directions/demands.” Management decided that the problem with the pumps “was not in itself a cause for safety or environmental concern.” The repair was deferred until the following budget year.

The Journal reports that “after a six-month inspection of the Texas City refinery last year, OSHA hit BP with an $87 million fine, the biggest in the agency’s history. About $57 million of  what OSHA describes as failure to abate hazards similar to those that caused the 2005 explosion which killed 15 people.”

It is also reported in the Journal that senior management at BP “focused on meeting performance targets, which determined bonuses for top managers and low-level workers alike.”

According to a former BP health and safety manager who was quoted in the Journal, workers had “high incentive to find shortcuts and take risks.”

The CEO of BP also spoke of “slaying two dragons at once; safety lapses that led to major accidents, including a deadly 205 Texas refinery explosions; and bloated costs that left BP lagging” Shell and Exxon Mobil.

After the small BP spill in 2008, BP’s internal report “warned of lax safety oversight and tight budgets.” As reported in the Journal, the BP report went on to conclude: “A key question to ask, especially with apparently minor and disconnected defects, is ‘what’s the worst thing that could happen?'”

I think we all know the answer to that.

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Lessons we can all learn …..

The US Chemical Safety Board (CSB) conducts chemical accident investigations and issues findings and recommendations. Several years ago, it conducted an investigation on a refinery explosion in Texas that killed 15 and injured 180 persons. Here are some of its findings:

  1. “Cost cutting, failure to invest and production pressures” from senior management impaired process safety performance at the refinery.
  2. “Reliance on low personal injury rate” as a safety indicator failed to provide a true picture of process safety performance.
  3. There was a “check the box” mentality at the plant where people simply just checked off on safety procedures even though they had not been completed.
  4. “Personnel were not encouraged to report safety problems and some feared retaliation for doing so.”
  5. There were “numerous surveys, studies and audits identifying deep-seated safety problems” but management’s response was often “too little, too late”.

We can all learn from these fatal mistakes.

The issue of reward structure at manufacturing facility is a tricky one. Many companies offer bonuses to middle managers for meeting production deadlines. Fewer companies offer similar rewards for excellence in safety. And when they do offer reward on safety, it often pertains mainly to personal safety and not process safety. That is understandable since it is harder to quantify process safety. There are lots of safety indicators for personal safety.

One of the findings by the CSB was that the refinery relied too much on its low personal injury rate as a false indicator that the process was safe. Just because people are not getting injured working next to a building that is about to collapse does not mean that the building will not collapse.

Measuring the wrong thing is worse than not measuring anything at all.

Another fatal mistake this refinery made was that it failed to act on the findings of its own numerous studies and audits. What is the point of doing all these audits if you are not going to fix the problems?

The “check the box” mentality at this refinery is most likely a result of the lack of ownership and training on the part of the employees. If an employee does not feel that he is part of the safety process and does not understand the rationale behind a long check list that he is given to complete, he is likely to just check them off. That’s just human nature.

We can all learn from these mistakes.

What can we learn from the BP oil Spill?

The massive oil spill from BP’s offshore drilling rig began on April 20, 2010.  It is now officially the worst environmental disaster in U.S. history.

There will be government investigations into what caused the accident and how it could have been prevented. The federal government has initiated a criminal probe into the accident and a Presidential Commission has been formed to look into the root causes of the incident. Someone will probably end up in jail.

What can we learn from this environmental disaster now? Here are some things that we know for sure at this point.

There is no such thing as a fail-safe system. Engineers and experts have assured the public repeatedly that an accident of such magnitude could never happen or are extremely unlikely to happen. Well it happened. The experts have been proven wrong. In fact BP’s 582-page emergency plan entitled “BP Gulf of Mexico Regional Oil Spill Response Plan” dated June 30, 2009 does not contain specific plans to deal with an accident of this magnitude. According to the plan, the TOTAL worst case discharge from an uncontrolled blowout from an exploratory well off shore was 250,000 barrels. The low estimate from the federal government on the amount of oil spilled is around 20,000 barrels per day. That’s 600,000 barrels per month and the spill began on April 20 with no end in sight.

There was no detailed discussion on how to stop a deep water blowout in the response plan. There were no Plan A, Plan B or Plan C outlined in the plan to address this magnitude of a spill. There was no mention of “Top Hat” or “Top Kill” in the plan. That’s why it has taken BP so long to stop the blowout. In fact, the Financial Times of London quoted BP’s CEO on June 3 as saying it was “entirely fair” to criticize the company’s preparations. The CEO went on to say that “what is undoubtedly true is that we did not have the tools you would want in your tool kit.”

The second thing we know is that too many emergency response plans contain a lot of fluff and extraneous material just to make them look substantive and impressive. One would have thought that a 582-page document would have the room to cover ALL possible worst case scenarios – including a blowout of a size that matches what actually happened. But that was not the case.

The 582-page plan was prepared by outside consultants. There is evidence that parts of the BP plan contain boilerplate languages used by other plans elsewhere. One example that has been cited by the media and much to BP’s embarrassment is that the BP plan actually lists walruses as among the Gulf of Mexico’s sensitive biological resources (see section 11 of the report). We all know that walruses live in the Arctic and sub-Arctic regions. They simply do not live in the balmy waters of the Gulf of Mexico. The fact that no one has caught this glaring mistake in the plan during the review process should be a cause of concern. The consultants who prepared this plan has offices in Alaska. A reasonable person could reasonably infer that the reference to walruses came out of a spill response plan that had been prepared for the frigid waters off Alaska. Cutting and pasting did not work this time around. It seldom does, It also tells us that the regulatory agencies responsible for reviewing the BP plan missed the mark by a wide margin.

So what else does this 582 page plan tell us? Size does not matter. It is the content and specifically local contents that really count. Despite its massive volume, the plan contains none of the different remedies that BP has actually tried out since the spill. One valuable lesson we learn from this disaster is that next time when we prepare a spill response plan or a contingency plan we need to focus on site-specific environmental conditions and not pad those plans with boilerplate cut-and-paste languages and fluff. All that flowery language in its 582-page has not helped BP plug that hole. Another valuable lesson we learn is that if we engage the services of an outside consultant or contractor to write our plan, we need to READ it carefully before sending it on to the agencies.

One final lesson we have learned is that if we spend a lot of money to develop a new manufacturing process to make a new widget, we need to also spend some money on how to control the pollution coming out of this new process. That’s one thing the oil industry has failed to do. It spent billions of dollars developing new deep water oil drilling technology without considering new technologies to deal with spills at such great depths.


Preparedness and Prevention Requirements

Both large and small hazardous waste generators are subject to the provisions of Part 265, Subpart C of RCRA – which calls for the generators to prepare for and prevent chemical accidents at the place where they store hazardous wastes. Subpart C requires the following:

  1. An alarm or communication system that is capable of providing emergency instructions to employees.
  2. A two-way communication system at the waste storage area.
  3. Fire fighting equipment such as fire extinguishers, water hose stations, automatic sprinklers and spill control and decontamination equipment.
  4. Regular testing of the equipment in 3 to ensure that they work.
  5. Adequate aisle space in the waste storage area to enable emergency personnel to get to the source of the emergency.
  6. Procedures that will minimize the possibility of fire, explosion or spills.
  7. Coordination with local authorities (fire department, police department and local hospitals) on how emergencies will be addressed.

It is very common for an inspector to find deficiencies in this area. Either you have a two-way telephone system or you don’t. Either you have adequate aisle space or you don’t. If your equipment is not working or in bad shape, the inspector will notice that too.

These are all low-hanging fruits for the inspectors. That’s why they are one of the most commonly cited RCRA violations.

Just for fun, take our general environmental quiz. Only you know the test score.

When do you need to clean up a chemical spill?

People often ask when do they need to initiate cleanup of a chemical spill. When they have a chemical spill, do they have to clean it up immediately?

The simple answer is yes. You need to clean it up as soon as possible. If you fail to clean up your spill promptly and the chemical you spill is a hazardous waste (it exhibits one or more of the hazardous waste characteristics or it is a listed waste), EPA will consider your site to be a hazardous waste disposal site and you will be subject to all the permitting requirements of a RCRA facility.

In other words, you can be cited for operating a RCRA Treatment and Storage Disposal Facility without a permit!

The agency is pretty clean on that. Just read its guidance document RO 12748 in RCRA Online.

Things you should do even when they are not required by law

There are several things in the environmental world you should do even though they are not  required by law. They fall into the category of “good management practices”.

If you are a hazardous waste generator, you are required by law to inspect your central waste storage area weekly. However, you will not find any regulations that specifically require you to document the weekly inspections. As a good management practice, you should always keep a written log of your weekly inspections. This serves two purposes. One, it keep your staff vigilant in making sure the storage area is clean and the containers are in good condition. Second, it gives you a way to show the inspector that you are actually doing the weekly inspections.

If you are a small quantity generator (you generate less than 1000 kilograms of hazardous waste in a calendar month), you are required by law to have an emergency response plan. However, the regulations do not say that you have to have a “written plan”. If you have such a plan, you might as well have it in writing.

Another thing you should alway do as a SQG. You should alway keep track of how much wastes you are generating on an on-going basis. Why? That’s the only way you can demonstrate to an inspector that you are a small quantity generator. Read my earlier post on this subject.

Verizon Wireless and EPA’s corporate audit program

Verizon Wireless has just agreed to pay $468,600 in civil penalty to EPA for a series of violations uncovered in its corporate wide audit at 655 facilities in 42 states. Here is a link to EPA’s press release.

A corporate audit agreement is an agreement that allows corporations, universities or other organizations with many facilities to plan corporate-wide or facility-wide audits with an advance understanding between the entity and EPA regarding schedules for conducting the audit and disclosing violations. EPA factors in the companies’ cooperation and willingness to do the audit voluntarily, and the penalties are typically lower than if the same violations were discovered through enforcement.

Some of the violations that Verizon uncovered included failure to prepare SPCC plans, failure to obtain air permits and failure to file Tier II reports.