Supercritical CO2: Employer Draws HAZMAT Citations for Nontoxic, Nonflammable Chemical

Following the death of 53-year-old Steven Reyna in a carbon dioxide (CO₂) release at Atlantic Coffee Industrial Solutions in Houston, Texas, OSHA issued nine serious citations against the facility. How exactly did the employer fail to protect its worker from the hazards of a nontoxic, noncorrosive, nonflammable chemical?

Here’s what the employer missed.

Compressed Gas Hazards

Supercritical carbon dioxide is not a compressed gas—not exactly—but it poses many of the same hazards as compressed gases, and consequently it requires much of the same type of preparation and training. But Atlantic had essentially treated the process and the chemical as nonhazardous—they had not made any preparations for a release.

So, when you have a process that uses supercritical carbon dioxide, or any other supercritical fluid, make sure that you don’t make these mistakes:

• Inadequate engineering controls. Under normal conditions of use, a supercritical fluid is contained in an enclosed system. There should be no exposure and no need for anything more than general ventilation. However, in the event of a leak, ventilation becomes an immediate and critical need. Atlantic should have had an interlocked leak-detection and emergency ventilation system to protect workers.
• No emergency response procedures. Atlantic did not have an emergency response plan in place to address carbon dioxide releases. No one had answered the questions “What could go wrong? And what will we do if it does?”
• No coordination with local first responders. Because Atlantic had not prepared to respond to a carbon dioxide release, it had also failed to coordinate with local emergency response agencies. Your local fire department is hypothetically prepared for anything at any time, but they can respond more quickly and more effectively if they know in advance how to get to your facility, where to go once they get there, and what sort of specialized equipment they might need.
• No emergency response training. Again, because Atlantic had not prepared for a release of CO₂, its employees did not know what to do. There was no emergency response plan, so there had been no training at the facility on emergency response procedures.
• No HAZMAT compliance. When the carbon dioxide release occurred, employees at Atlantic suddenly found themselves in a hazardous materials (HAZMAT) response situation for which they were completely unprepared. Atlantic was cited for having failed to provide them with 24-hour first responder level and incident commander HAZMAT training as a result. Atlantic was also cited for failing to have a site-specific Incident Command System.
• Inadequate first-aid preparation. The facility was not prepared to respond to injuries resulting from a release of carbon dioxide.
• No follow-up evaluation. Not only did Atlantic have no procedures in place to respond to an emergency; it had no procedures in place to evaluate and improve its emergency response.
• A noncompliant fire brigade. OSHA cited Atlantic for designating a fire brigade … without meeting any of the conditions for establishing a fire brigade, including equipment and training requirements.

Do you need help updating your HAZMAT and emergency response procedures? Safety.BLR.com^® can help you be prepared.