Thursday, March 19, 2020

COVID-19 Chemical Facility Shutdowns

Earlier today an interesting TWEET® from @Kulinowski, the Interim Executive Director of the Chemical Safety Board (CSB) pointed at a valuable document in the CSB archives; “Safety Digest: CSB Investigations of Incidents during Startups and Shutdowns”. It looks at three incidents investigated by the CSB where three major accidents that occurred during startups and shutdowns. Kulinowski noted in her TWEET that: “Should a facility determine it is safer to suspend operations due to coronavirus, extra care must be taken to do so safely.”

She is, of course, absolutely correct, but with COVID-19 shutdowns being for indeterminant periods, careful planning needs to be applied to the period between shutdown and startup. Specific attention needs to be paid to the safety and security of chemicals remaining at the facility during the shutdown. Emergency response planning, both onsite and off, also deserves special scrutiny.

Chemical Safety

Each chemical held on site will have its own unique storage requirements for safely holding the chemicals for an indeterminant length of time. Management needs to determine those needs for each chemical held on site and determine the safety critical and quality critical storage requirements for each. Detailed monitoring plans need to be put into place for safety critical storage conditions with specific response plans should conditions approach safety critical limits.

Monitoring quality critical requirements is not as important on a real-time basis, but quality control testing of materials that were stored outside of normal standards could be an important safety step in the facility startup process. This is very important when auto-reaction or decomposition products could affect the control of startup or production processes.

Plans for either on-site or remote monitoring will have to take into account personnel status changes due to either COVID-19 quarantine or illness of the individuals involved. While on-site isolation of the monitoring team might seem to be a way to avoid subsequent COVID-19 problems, managers need to remember that individuals may transmit the disease up to four-days prior to showing symptoms.

Chemical Security

Chemical security issues, either regulatory or otherwise, are not going to go away during an extended facility shutdown. In fact, criminals or terrorists might decide that shutdown facilities are easier targets due to the decreased number of personnel on site. The eyes and ears of employees moving about the facility during normal operations is a valuable part of the security surveillance system at any facility. The lack of the presence of those employees at the facility will have to be taken into account in a review of the post-shutdown security procedures.

The updated security plan is also going to have to take into account the changing COVID-19 status of personnel involved in on-site patrolling, off-site monitoring and security response. It is very important to ensure that new personnel being brought onto the site are fully briefed on the chemical safety requirements for the facility.

Closed Facilities

It is almost inevitable that there will be facilities that transition from shut-down to closed if the COVID-19 problem persists for very long. With some medical researchers saying that social isolation requirements may need to stay in place for as much as 18 months, there will certainly be companies that go out of business during their COVID-19 shutdowns. It is unlikely that these facilities will undergo an orderly closing process with the removal of unsafe chemicals or chemicals with security issues.

Local governments are going to have to plan for monitoring such facilities after they close and stop funding the shutdown operations. Security companies are likely to be the first reporters of the change in status at these facilities. Law enforcement and emergency responders will need to monitor chemical facilities in their jurisdictions for this potential transition.

Unpredictable Future

COVID-19 is providing an epidemic of proportions that have not been seen since the 1918 flu epidemic. The fact that COVID-19 is transmissible before symptoms show are causing response problems at all levels of society. Chemical facilities need to take this into account and be prepared to update their shutdown plan on almost a daily basis. Planning also needs to take into account the unthinkable; going out of business. Coordination with suppliers, customers and local officials needs to be close and continuous.

And one final item for consideration. The national supply of chemical-qualified truck drivers, particularly those with hazardous material endorsements is already too low. As COVID-19 starts to take its toll on that relatively small community, transportation issues will be an increasing burden on chemical facilities.

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