Review - CSB Publishes Louisiana Bio-Lab Investigation Report

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 - subscription required.