Atlantic hurricane season doesn’t officially end until Nov. 30. This season has been relatively quiet for the chemical sector, but past storms and other natural disasters have shown that facilities can face serious consequences when they aren’t prepared.

The threats are not going away, even if the Trump-led U.S. Environmental Protection Agency (EPA) administrator rolls back Risk Management Program requirements enacted under the Biden administration. The ruling included new emergency-planning mandates for extreme weather events due to climate change. 

Past incidents related to extreme weather have led to fines, criminal charges, deaths and major plant disruptions.

Christina Baxter, CEO of Emergency Response TIPS, a company that develops tools and training for hazardous materials and CBRNE (chemical, biological, radiological, nuclear and high-yield explosives) response, says preparedness has to be built around cascading failures rather than isolated events.

Chemical Processing recently asked Baxter five questions about vulnerabilities, planning gaps and practical steps. Her responses, lightly edited, are below.

Natural disasters are becoming more frequent and severe in many regions. What are the biggest vulnerabilities you're hearing about from chemical manufacturers as they assess their preparedness?

From my perspective, the biggest vulnerabilities relate to the power-grid dependency and the lack of redundant backup systems to maintain critical process controls, such as refrigeration.  While this is not a big issue on the smaller weather events, it does become critical when the events are larger in scale and longer in duration. Have they planned for the maintenance of the backup generators if they are required to run for long periods? Refueling options when fuel is scarce or hard to find? What about when the automatic transfer switches fail? All these things can create a nightmare situation when the manufacturer potentially loses visibility over chemical reactions and storage situations.

It is also important to remember that a lot of facilities are in areas that would be considered floodplains. The land is cheaper and less prone to being overdeveloped. This also means that it is far more at risk from flooding following a natural disaster, such as a hurricane, and there may not be a high spot in which to move critical assets.

When a chemical facility experiences a major weather-related disruption, what are the most common gaps in emergency planning or response that tend to emerge?

The biggest gap that I often see is a failure to plan outside of their own ecosystem. Weather-related disasters tend to affect a larger community, making backup materials, supplies and personnel at a shortage. Most plants operate on the just-in-time principles where they receive raw materials and ship byproducts quickly. What is the plan for longer-term storage of final hazardous products if they cannot be shipped due to these logistics disruptions?  Critical staffing shortages can increase the likelihood of human error during potential high-stress intervention steps. This is when closer coordination with the emergency-response community is helpful.  If they know that there is a specific piece of the infrastructure that they must get working faster than others, they will try everything to do so.

Many chemical plants have legacy infrastructure, complex supply chains and hazardous materials on site. How are those factors changing the way companies think about disaster preparedness compared to even five or 10 years ago?

This one is a loaded question! For the legacy infrastructure, we must focus on resilience, meaning will it be able to withstand the impact of the natural disaster safely and securely? In this case, it will be critically important to have knowledgeable maintenance staff on a quick call-back/back-up as part of the emergency plan. Most emergency plans assume that these people will be fresh, alert and readily accessible when, in fact, the disaster may be affecting their homes and families as well, resulting in personnel working [during] emergencies under extreme personal duress. This cannot wait until after the disaster moves through as it might be too late to minimize damage or too difficult to get on site. Thankfully, with many natural disasters, there is a time component involved for pre-staging.

For the complex supply chains, there must be a plan in place to bring all operations to a stopping point safely. Regardless of the size of a natural disaster, there will be cascading effects on the local and regional supply chains. This needs to be planned for both materials into the plant and away from the plant. If the plant cannot be safely shut down, where will the byproducts and any final products be stored? Does the facility have redundant systems in place for this to occur?

What lessons are chemical manufacturers drawing from recent natural disasters, and where do you still see organizations struggling to translate those lessons into meaningful action?

I believe companies are starting to do a better job of including the local emergency response community in their planning process. This was going far better with the Local Emergency Planning Committees (LEPC) program was more active. If you don’t have an active LEPC, work with your local emergency management department to get one active again.

Part of the issue often comes down to wanting to share with the emergency-response community but not wanting to go as far as sharing exact information, especially if it relates to trade secrets. It is also critically important to start overhauling the quantitative risk assessments for compound hazards versus singular events. For example, if floodwaters are rising, you are likely to lose both facility power and potentially backup generators based upon placement. What is the next step?  Can you move the materials to a higher point on the facility for safety? Are the generators movable? If you must go to a “vent-and-burn” type approach for some chemicals, what will be the effects on the nearby community, especially if evacuation is no longer an option?  It’s these cascading events that need to be planned for more realistically.

For chemical companies looking to strengthen resilience, what practical steps tend to make the biggest difference before a disaster occurs, and what barriers often prevent organizations from implementing them?

First, I would say to get an updated QRA (quantitative risk assessment) for your facility, which looks at compounding hazards instead of evaluation of risks in isolation. Next, develop a plan in coordination with your local community emergency planners and response personnel. Ensure that they are not planning to do an evacuation route directly through the area where you might be moving chemicals.

Consider hardening your infrastructure before the need arises; consider the impact of hardening and elevating critical infrastructure support (relocate, elevate or shield emergency generator fuel pumps, electrical switchgear, etc.); minimize the potential impact of line shearing by installing flexible piping and mechanical breakaways designed to snap cleanly without releasing product due to ground shifting, structural settling or tank buoyancy; consider redesigning secondary containment for dilution and overtopping with automated diversion valves, high-capacity draining pumps or increased volumetric capacity to cover both the tank contents as well as the potential for torrential rainfall.

Finally, practice executing the plan to make sure it works before it is needed during a real event. Try executing the plan without several of your available top response personnel. Assume that they cannot get back to the plant due to the disaster. This will test the resilience of your plan. If possible, go digital with your planning to ensure that you have the best chance of access to all your personnel, whether that be onsite or remote during a potential emergency.

Unfortunately, to do any of these things, you must first break down the internal barriers of capital bias toward direct-production assets and siloed organizational structures where the environmental health and safety teams don’t work directly with their partner in engineering, supply chain logistics and plan operations.