Yesterday, the Chemical Safety Board announced
the publication of their
final report on the investigation of the fire and chlorine gas release at
the Bio-Lab manufacturing facility in Westlake, LA immediately following the
passage of Hurricane Laura in August 2020. The incident was initiated when the
roof was blown off of a portion of the plant in which over 70,000 pounds of trichloroisocyanuric
acid (TCCA) was stored. Subsequent water contamination of the TCCA resulted in
an exothermic reaction which caused a facility fire and the release of a toxic cloud
that included copious amounts of chlorine gas. An additional portion of the
facility, a warehouse containing additional amounts of TCCA, was subsequently
involved in the incident.
Recommendations
The CSB identified five major safety issues in their
investigation:
• Extreme weather preparation,
• Process hazard analyses
implementation,
• Emergency preparedness and
response,
• Adherence to applicable hazardous
materials codes, and
• Regulatory coverage of reactive
chemical hazards.
Based upon the results of the investigation, the CSB
published six new recommendations:
• 2020-05-I-LA-1 – Bio-Lab - Evaluate
the hazards to the Bio-Lab Lake Charles facility from hurricanes and
accompanying wind, rainwater, floodwater, or storm surge forces,
• 2020-05-I-LA-2 – Bio-Lab - Develop
and implement an improved Process Hazard Analysis (PHA) action item management
system,
• 2020-05-I-LA-3 – Bio-Lab - Perform
process hazard analyses (PHAs) on all buildings and units processing or storing
trichloroisocyanuric acid,
• 2020-05-I-LA-4 – Bio-Lab - Revise
the Bio-Lab Lake Charles emergency response plan,
• 2020-05-I-LA-5 – State of
Louisiana - Require the facility operators to evaluate the hazards to their
facilities from hurricanes and accompanying wind, rainwater, floodwater, or
storm surge forces, and
• 2020-05-I-LA-6 – EPA - Implement
the five open recommendations issued in the 2022 U.S. Government Accountability
Office Report titled Chemical Accident Prevention: EPA Should Ensure
Regulated Facilities Consider Risks from Climate Change.
The Board also reiterated two long-standing and still open recommendations:
• 2001-01-H-R1 – OHSA - Amend the
Process Safety Management Standard (PSM), 29 CFR 1910.119, to achieve more
comprehensive control of reactive hazards that could have catastrophic
consequences, and
• 2001-01-H-R3, EPA - Revise the
Accidental Release Prevention Requirements, 40 CFR 68, to explicitly cover
catastrophic reactive hazards that have the potential to seriously impact the
public, including those resulting from self-reactive chemicals and combinations
of chemicals and process-specific conditions.
For more details about the incident, including the chemicals
involved, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/csb-publishes-louisiana-bio-lab-investigation
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