Thursday, October 22, 2009

Reader Comment 10-20-09 Generalities

Like many bloggers that have full time jobs, I sometimes get in a hurry when I write a blog post. When that happens I frequently get a little careless in my use of generalities in describing various situations. Well, last Tuesday a reader, Anonymous, caught me and called me to task. The comment is a little too long to re-post here, but you can find it appended to the end of my post, "IST and TIC Manufacturers".

I certainly admit that not all large companies have good safety or security programs. Anonymous’ example of Bayer CropScience is certainly an excellent example of a facility that has very questionable and objectionable safety processes. The point that I was trying to make was that large companies have adequate resources that are a prerequisite for good safety and security programs. The fact that some (more than a few readers would say ‘many’) do not use those resources in a way that benefits the welfare of their employees and neighbors is the reason that we need a strong oversight capability from the Federal government.

Likewise, smaller companies with their limited resources, generally have a harder time putting adequate security programs into place. The fact that a small facility can be at particularly high-risk facility because of the chemicals on site makes this a particularly dangerous combination. Having said that, I am sure that there are small high-risk facilities that have made very efficient use of their resources to effect a perfectly good security program. These facilities deserve recognition that, for security reasons, they will never adequately receive.

Finally, I certainly did not intend to imply that simply requiring facilities to conduct an IST assessment will result in the wholesale conversion of facilities to less hazardous processes. There are very many, probably most, facilities that use very dangerous chemicals that, for a variety of technical and financial reasons, will never be able to convert to safer chemicals or processes. What I wanted to call attention to is that for facilities that do not have the internal expertise to do a real, in-depth process safety analysis (which is what an IST assessment really is), there is no way for them to identify an IST alternative.

Requiring them to get an assessment done, almost certainly by outside consultants, might reveal to them a safer, more economical way to get their jobs done. If a clearly beneficial IST is identified in such an assessment, companies will implement them. Anyone that believes that chemical companies, as a matter of course, conduct ‘real, in-depth process safety analysis’ of process before it is started up are in for a rude awakening. Just read the Chemical Safety Board report on the explosion at the T2 facility in Florida.

Usually the quality of such PSAs is reflective of the resources available and thus the facility size. But, large companies have certainly been known to cut corners, see the multiple problems at the BP facility in Texas City. Again, this is why strong enforcement action is necessary. In closing, thanks to Anonymous for calling me out on my gross use of generalizations. Even bloggers need the occasional inspection report to keep them on the straight and narrow.

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