Saturday, August 10, 2024

Chemical Incident Reporting – Week of 8-3-24

NOTE: See here for series background.

Denver, CO – 8-3-24

Local news reports: Here.

Sodium hypochlorite spill at water treatment facility. Minor eye irritation, but no serious injuries. No reported damages.

Not CSB reportable.

Webster, TX – 8-7-24

Local news reports: Here, here, here, and here.

Chlorine gas release due to mixing sodium hypochlorite and sulfuric acid (possibly in a storage tank). Heat of reaction probably also produced water vapor cloud which aggrevated exposure issues. Sixteen employees and contractors were transported to hospital.

Possible CSB reportable depending on if any of the people transported to the hospital were admitted.

Commentary

With an 8 hour reporting standard {40 CFR 1604.3(c)} should facilities consider initiating a report when they know that at least one individual has been transported to the hospital, rather than waiting to find out if they have been admitted? The effort to complete the CSB’s reporting form, is relatively small, and there is no legal downside (the CSB is not a regulatory agency) to reporting an incident that ends up not being a covered incident standard set out in §1604.3(a). On the other hand, while the 8-hour reporting standard is a legally enforceable standard, and the clock starts at the time of the release, the CSB has shown no inclination to aggressively enforce this rule.

The whole point of this regulation is to ensure that the CSB has sufficient information to determine if they should conduct an investigation of the incident. The earlier they receive the incident information, the sooner they can get to the site (if deemed necessary) to begin the process of securing and processing the scene. Thus, I would argue that early reporting is to be recommended, even if it means that incidents that end up not being covered by the standard periodically get reported.

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