Chemical Safety Board Issues Remote Isolation Recommendations to EPA, OSHA and API

The U.S. Chemical Safety and Hazard Investigation Board (CSB) released a new safety study, “Remote Isolation of Process Equipment,” which issues recommendations to key regulators and calls for greater use of remote isolation equipment at chemical facilities in the United States.

Based on the agency’s investigations of several catastrophic chemical incidents in recent years, the CSB’s new safety study concludes that the chemical industry has not fully recognized that the effective remote isolation of process equipment is critical to quickly stopping releases of hazardous materials, which can help prevent fatalities and serious injuries to workers at chemical facilities, reduce damage to the facilities, and better protect communities and the environment.

Over the last several years, the CSB has reviewed and investigated numerous chemical incidents where the consequences escalated dramatically following a loss of containment due to the lack of effective remote isolation equipment. These incidents resulted in serious injuries, fatalities, environmental contamination, and severe damage to facilities and put surrounding communities at great risk.  The CSB highlighted  the following investigations in the safety study:

• Formosa Plastics Propylene Explosion (2005) (Sixteen workers were injured, the process unit was heavily damaged, and a nearby school was evacuated.)
• Valero McKee Refinery Propane Fire (2007) (Four workers were injured and the refinery was evacuated and shut down for several months.)
• Intercontinental Terminals Company (ITC) Tank Fire (2019) (Estimated property damage exceeded $150 million, 21 million gallons of hazardous material and contaminated water were released into nearby waterways, shelter-in-place orders were issued for nearby communities due to benzene-related air quality concerns, and local schools and businesses either closed or operated under modified conditions.)
• KMCO Fatal Fire and Explosion (2019) (One fatality and two serious injuries resulted, portions of the facility were substantially damaged, and the explosion reportedly shook nearby homes and was heard throughout the surrounding community.)
• Philadelphia Energy Solutions (PES) Refinery Fire and Explosions (2019) (Roughly 676,000 pounds of hydrocarbons and over 5,200 pounds of highly toxic hydrofluoric acid were released, the estimated property damage loss was $750 million, and the refinery ultimately closed permanently.)
• TPC Group Port Neches Explosion and Fire (2019) (The explosion reportedly was felt up to 30 miles away, caused $450 million in on-site property damage and $153 million in off-site property damage to nearby homes and businesses, propelled a process tower at the facility into the air, and resulted in a fire that burned for more than a month within the facility.)

The CSB’s Safety Study is issuing three safety recommendations, one each to the American Petroleum Institute, the U.S. Environmental Protection Agency, and the U.S. Occupational Safety and Health Administration:

• American Petroleum Institute (API):  The CSB recommends that the American Petroleum Institute revise its industry guidance documents to apply to more facility types beyond refineries and include criteria for when remote isolation devices should be required that may be automatically activated or remotely activated from a safe location, for processes involving highly flammable or toxic materials and atmospheric storage tanks.
• U.S. Environmental Protection Agency (EPA): The CSB recommends that the U.S. Environmental Protection Agency incorporate requirements for an evaluation of the need for remote isolation capabilities into its Risk Management Program (RMP) Rule, which regulates processes involving highly flammable or toxic materials.
• U.S. Occupational Safety and Health Administration (OSHA): The CSB recommends that the U.S. Occupational Safety and Health Administration include requirements for an evaluation of the need for remote isolation capabilities into its Process Safety Management (PSM) standard, which regulates processes involving highly hazardous chemicals.

These recommendations are intended to enhance safety measures and mitigate the consequences of incidents like the explosions and fires at chemical facilities by ensuring that necessary and safe remote isolation capabilities are in place to prevent the escalation of releases of hazardous materials. 
In addition to the recommendations, the CSB is calling on chemical facilities to immediately assess whether remote isolation should be applied to major process equipment even before formal requirements are put in place in industry standards and federal regulations – and if so, install effective remote isolation equipment in a location that is safe for workers to activate.