I wasn't aware of the T2 Labs explosion in Florida in 2007. There's a good CSB video on the event at the URL at the bottom of this note.

- Ralph

Improving Reactive Hazard Management 

John F. Murphy, PE

It has been nearly eight years since the U. S. Chemical Safety and Hazard Investigation Board (CSB) issued the results of its hazard investigation into reactive chemical incidents with the report entitled Improving Reactive Hazard Management. The investigation reported that over a twenty year period there were 167 serious incidents that involved chemical reactivity in the United States resulting in 108 fatalities. These numbers do not include the many incidents that are not reported. Some things have been done to decrease the occurrence of reactive chemical incidents, but reactive chemical incidents continue to occur with regularity. I count 12 serious reactive chemical incident investigations completed by the CSB since the completion of the hazard investigation. This is just the tip of the iceberg. 

Many reactive chemical incidents are not reported and the CSB can only investigate a small fraction of the process safety incidents that are reported. According to the CSB web site only 60% of the recommendations from the CSB report have been closed. The most important closed recommendations are the inclusion of the definition of reactive chemical incidents in the EPA Risk Management Plan (RMP) regulation and the completion of the Essential Practices for Managing Chemical Reactivity Hazards concept book by The Center for Chemical Process Safety (CCPS). This book is publically available on the OSHA web site. Recommendations to improve the OSHA PSM standard regarding reactive hazards are still open, although industry should improve reactive hazard management because it is good business and the right thing to do, not just because the regulations require compliance.

The CSB found that over 90% of the reactive chemical incidents that occur are the result of known chemical hazards documented in publically available literature. We know that even eight years later, people who need to know about reactive hazards are not getting the information they need. One recent incident investigation has resulted in another significant recommendation by the CSB regarding the management of reactive chemicals.

=93On December 19, 2007, four people were killed and 13 others were transported to the hospital when an explosion occurred at T2 Laboratories Inc. during the production of a gasoline additive called methylcyclopentadienyl manganese tricarbonyl=94

The following recommendations were offered by the CSB.

American Institute of Chemical Engineers 

=95 Work with the Accreditation Board for Engineering and Technology, Inc. to add reactive hazard awareness to baccalaureate chemical engineering curricula requirements.

=95 Inform all student members about the Process Safety Certificate Program and encourage program participation.

Accreditation Board for Engineering and Technology, Inc. 

=95 Work with the American Institute of Chemical Engineers to add reactive hazard awareness to baccalaureate chemical engineering curricula requirements.

AIChE is actively working with ABET to adopt these recommendations. By including reactive hazard awareness in the undergraduate chemical engineering curriculum, there is a better chance that future chemical engineers will identify reactive hazards before they become incidents.

The CCPS Reactivity Management Round Table (RMR), which began with a meeting organized by CSB to address the management of reactive hazards, was initiated by CCPS in 2003. The RMR had 100 members with about 40 active members when it was initially organized. Over the years active participation in the RMR has decreased. I was at the last meeting in San Antonio where there were only about ten members of the RMR present. I interpret this lack of support a sign of complacency by the industry on the reactivity management issue. The RMR continues to work on the reactive chemical issue. With support from the RMR, the National Oceanic and Atmospheric Administration (NOAA) has done an excellent job keeping its Chemical Reactivity Worksheet on its web site current. The Chemical Reactivity Worksheet is a free program that can be used to find out the about the reactivity of substances or mixtures of substances. The data base contains reactivity information for more than 5,000 common hazardous materials.

The most exciting project supported by the RMR is the Reactivity Evaluation Software Tool (REST) which is presently under development. The primary objective of REST is to assist all users, especially small to medium size companies, to identify chemical reactivity hazards associated with their chemical processing and support operations. Once the tool is available, the challenge is to get people who need it to use it. REST should be available to users by the end of 2010. CCPS is also offering to the industry basic training on process safety including managing reactive hazards in its new training course entitled Process Safety Boot Camp.

There are tools to manage reactive hazards; we just need to use them!

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