Hurricane Harvey case highlights need for rigorous risk analysis

An American chemicals manufacturer, its CEO and one of its plant managers have been indicted for recklessly releasing chemicals after its Texan plant caught fire when Hurricane Harvey hit.

It’s a stark reminder of just how important a sense of vulnerability is and how extreme scenarios, however ‘unlikely’, should be considered says BPE’s Robert Bussey.

Robert, who is process safety manager at BPE, says the case has brought to the fore the issue of risk management in the chemicals industry and just how far manufacturers should delve when it comes to identifying risk.

In August 2017, flooding from Hurricane Harvey caused a fire to break out at Arkema’s chemical plant in Texas. The fire caused power failures at the plant, where organic peroxides, some of which must be stored below freezing to prevent them from combusting, are kept.

The unprecedented rainfall during the hurricane caused power and backup power to fail at the low-temperature warehouses. Staff moved the organic peroxides into refrigerated trucks, which also succumbed to power failures.

Employees were evacuated along with residents living within a 2.4km radius. Around 150t of organic peroxides decomposed and caught fire, releasing fumes and smoke that resulted in 21 people seeking medical attention including emergency responders, and the evacuation of more than 200 residents who could not return home for more than a week.

An investigation by the US Chemical Safety Board (CSB) found that though Arkema had not specifically planned for flooding, the safeguards at Crosby were sufficient to guard against a once-in-a-500-year-flood; unfortunately, Hurricane Harvey was much greater than this.

Robert Bussey asks: “When conducting risk assessments do companies consider low likelihood events or are they dismissed due to their rarity? Most sites spend their time at the lower end of the risk matrix, the slips. trips and falls. This is what we are most familiar with, this is what we deal with every day, so it’s easy to underestimate the likelihood of that big incident. I have been in many HAZOPs where an event was dismissed because of ‘double jeopardy’.

“The belief that because two or more failures are required to result in a consequence, then it’s too unlikely to consider. The Arkema incident is a perfect example of how real life actually works, not only did the power fail, so did the backup power and the trailer power, all on top of a weather event that should only happen once in 500 years.”

A grand jury concluded that Arkema North America, its CEO Richard Rowe and the Crosby plant manager Leslie Comardelle were responsible for the release of a toxic cloud over the local community. The indictment charges that all had a role in “recklessly” releasing chemicals into the air and placing residents and first responders at risk of serious bodily injury, a press statement from Harris County District Attorney says.

BPE’s Robert Bussey says the move follows an increasing precedent for regulators to prosecute named individuals. “The Tianjin explosion in China in 2015 is another classic example. As the Harris County attorney judge says, ‘Companies don’t make decisions, people do,’ and we’re increasingly seeing courts and regulators clamping down on those at the helm.”

He continues: “Long gone are the days when a faceless company was held responsible for an incident. We live in a more open society, where social media demands corporations be more responsible and individuals held accountable.”

Reflecting on what chemicals manufacturers in the UK can learn from the recent Arkema case Robert says: “Fortunately, no one was seriously hurt as a result of Arkema, but it should serve as a timely reminder that such events do still happen. Don’t overlook those low probability events. If the consequence is severe enough they need to be considered.”

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