The CFAT Act of 2008 discussed in Friday’s blog would try to enforce a requirement for chemical facilities to use what is generically called Inherently Safer Technology. This is a broad term that refers to the use of less dangerous chemicals, less energetic reaction conditions and/or even reduced chemical inventories to reduce the hazards to a surrounding community from the results of a successful terrorist attack. While this appears to be an easy way to reduce hazards, it is not the panacea that many advocates claim.
Generally speaking, chemical facility operators would prefer to use inherently safer technology. A great deal of time, energy and money is spent in making chemical processes safer. No one makes any money when a reaction vessel or storage tank explodes, especially when it effects potential litigants outside of the front gate. When highly hazardous chemicals are used or produced in a process, extensive work has to be done to analyze the hazards associated with the process and to implement additional control measures to keep that process within safe operating parameters.
Now with the implementation of the CFATS regulations, facilities with dangerous chemicals and or processes will be spending additional money on layering security controls on top of the safety controls already in place. No one is arguing that these measures are not necessary, but they will be expensive. If a facility could avoid that expense by changing to a less hazardous chemical they almost certainly will, if they can.
I have worked as a Process Chemist in the specialty chemicals industry for 12 years. I have worked in R&D and in chemical plants. I have worked with new product development and introduction as well as on process improvement operations. One of the things on which I have spent a great deal oftime is the substitution of chemicals in an established chemical process. A look at how that process works will illustrate the problem with requiring the use of inherently safer technologies.
Substituting with the Same Chemical
The most frequent chemical change made in an established process is the substitution of a chemical with the same chemical made by a different supplier. This is done to reduce costs or to assure the ready supply of a chemical. While this sounds like a simple substitution, it is not.
First lab work needs to be done to confirm that the two chemicals are the same, or close enough to the same not to matter. With industrial chemicals there is no such thing as a pure chemical; there is always some level of contamination. Different processes, different raw materials, and even different process equipment can lead to changes in both the amounts and types of contamination present in a chemical. Analytical tests are done to measure the types and amounts of that contamination.
Lab batches are made using the new chemical and all of the other actual raw materials from the manufacturing plant. This is done to assure that there are no unusual side reactions that arise because of the differences in the contaminants. Reaction conditions are observed to see if there are unusual increases in temperature, production of gasses or other byproducts. Multiple production lots of the new chemical are used to look for production variations in the new supplier’s process.
Extensive testing of the finished lab batches will be done to insure that the same product is being made with the newly sourced chemical. If the manufactured chemical is used as a raw material in another chemical process, samples are sent to customers (both internal and external) for them to evaluate. Those customers will have to go through a similar testing process.
Once these tests are completed the product can be introduced into the manufacturing facility. A limited supply of the chemical will be obtained from the supplier and a trial batch of material will be made. The batch will normally be segregated while additional in-house and customer testing is done on the trial material. Once approved the new supplier is allowed to provide this raw material. Unfortunately, this simple type of change has nothing to do with changing to an inherently safer process.
Substituting an Entirely New Chemical
Changing one of the chemicals involved in a chemical reaction is not the same thing as substituting olive oil for corn oil in a cooking recipe. To get the same final product changing one raw material usually requires the changing of at least one of the other chemicals involved in the reaction. What you are essentially doing is developing an entirely new product.
First someone has to come up with the idea for the new reaction. Then a literature search has to be made to see if someone else has done work on that process. If there are no current patents involved then the chemists involved can start their lab work. As the lab work progresses the Environmental, Health and Safety people start to take a hard look at the prospective chemicals and processes involved.
The lab work involved can take months to years, depending on the complexity of the process. Minor variations of the process need to be run to see what process upsets can be tolerated, both from a quality and safety point of view. Intermediate samples from the process will require testing to see how they willbehave in various process upset conditions; high and low temperatures, high and low pressures for example.
Lab samples of the product need to be sent to customers for testing. The testing for a new material, rather than a simple substitution of the same raw material, will require substantially more testing. If this is an industrial chemical the product made from this material will require substantial testing, some of the testing can take months or years to complete depending on the application. If this is a commercial product going directly into the hands of consumers, safety testing will also have to be done to detect health or safety issues. That testing can also be quite time consuming.
It is not unusual for test results to require additional lab work to correct problems found in the testing process. This means that it is quite typical for a change in raw materials to take years of lab work to get the new process into shape for introduction into the manufacturing facility.
Introducing a new process into a manufacturing facility is also a time consuming process. If new process equipment is required this must be purchased, installed, and employees trained on the operation of the equipment. If no new equipment is needed the introduction process is only slightly easier.
New chemicals require a safety review prior to introduction. Employees have to be trained on safe handling. New processes also require a safety review prior to being run in the facility. Invariably some equipment modifications will have to be done. Procedures will have to be written and reviewed. Employees will have to be trained on the new procedures. Depending on the complexity of the new process this pre-introduction procedure can take any where from weeks to months.
Finally a trial batch of material is made using the new process. If every thing works as planned, and it seldom does the first time, the material again is sent out for testing. Frequently the testing is not required to be as extensive as with the lab samples, but this will still be time consuming. If testing reveals new problems more lab work is required. Depending on the extent of process changes required to correct those problems, the whole process introduction work may have to be repeated.
Once all of the bugs are worked out the new process is put into commercial production. Except that there are a number of check points along the way at which the process can be stopped. Economic analyses are done at just about every step of the process to ensure that only potentially economically successful processes are worked upon. The time and resources necessary to bring a new process or product to fruition are expensive. If the new process is not economically viable, the company needs to know that as soon as possible.
The Chemical Industry Does Not Support Mandatory Reliance on Inherently Safer Technology
Because of the time and resources involved in developing and implementing any significant process change, industry is reluctant to allow a government agency to determine what process change can reasonably be made. If the agency were to make the same type of well thought out economic evaluation that the company would expect to make, the company would have to share way too much information with that agency. Any thing short of that level of information sharing would leave the decision by the agency potentially devastating to the company or suspect to proponents of the forced application of Inherently Safer Technology. In short, it is a no win situation for both the agency charged with making the decision and the company thatis forced to comply with that decision.