In its final report on a chemical fire and toxic gas release at a Westlake, Louisiana, chemical facility, the U.S. Chemical Safety and Hazard Investigation Board (CSB) suggested that the Occupational Safety and Health Administration (OSHA) and EPA revise their regulations for reactive chemical hazards.
On August 27, 2020, over 1 million pounds of trichloroisocyanuric acid (TCCA) were on-site at the Bio-Lab Lake Charles facility. TCCA is used throughout the country in pool care and, when put in large bodies of water such as a pool, breaks down slowly, releasing chlorine in the water.
That day, Hurricane Laura, a Category 4 hurricane, made landfall, and strong winds damaged buildings at the facility, including tearing off roofs. Rainwater contacted the TCCA stored inside the buildings, starting a chemical reaction and subsequent decomposition.
A fire started, and a large plume of hazardous gases, including toxic chlorine, escaped the facility. A portion of Interstate 10 was closed for over 28 hours, and local officials issued a shelter-in-place order for the surrounding community because of the release of hazardous gases.
“With powerful storms and other extreme weather occurring more frequently, companies and regulators must take action to prevent weather-related releases of hazardous chemicals that can cause substantial damage to facilities and threaten surrounding communities,” CSB Chairperson Steve Owens said in an April 24 board statement.
The CSB reiterated two of its earlier recommendations to OSHA and the EPA related to reactive chemicals. The CSB called on OSHA to amend its Process Safety Management (PSM) standard to mandate more comprehensive control of reactive hazards, such as TCCA, that could have catastrophic consequences. The board called on the EPA to revise its Accidental Release Prevention Requirements to cover additional reactive hazards that have the potential to seriously impact the public.
In its investigation of the fire and toxic gas release in Westlake, the board identified five safety issues:
- Extreme weather preparation: Bio-Lab didn’t learn the importance of preparing for extreme weather after the August 2017 organic peroxide decomposition incident at the Arkema facility in Crosby, Texas, following extensive flooding caused by Category 4 Hurricane Harvey. Bio-Lab didn’t implement industry guidance for extreme weather preparation that was updated and published after the Arkema incident.
- Process hazard analysis (PHA) implementation: TCCA isn’t covered by OSHA’s PSM standard. Bio-Lab voluntarily implemented some elements of the PSM standard and even conducted a 2010 PHA but didn’t implement a PHA recommendation to determine whether buildings at the facility, including their roofs, could withstand damage from hurricane-strength winds.
- Emergency preparedness and response: Bio-Lab experienced an approximately five-and-a-half-hour delay in responding to the event, which likely increased the severity of the incident.
- Adherence to applicable industry consensus codes for hazardous materials: The Lake Charles plant didn’t adhere to the National Fire Protection Association’s (NFPA) codes for high-hazard industry occupancies, which include safety precautions such as automatic extinguishing systems or other protections to minimize danger to occupants before they have time to evacuate.
- Regulatory coverage of reactive chemical hazards: TCCA isn’t covered by OSHA’s PSM standard or the EPA’s Risk Management Program rule. Under existing regulations, the facility wasn’t required to implement baseline PSM elements of its TCCA-related operations.
The board’s recommendations to Bio-Lab include:
- Constructing new buildings and maintaining existing buildings and structures to withstand hurricane winds and flooding;
- Implementing safeguards and processes to ensure hazardous chemicals don’t get released during extreme weather events;
- Improving the company’s PHA action item management system;
- Performing PHAs on all buildings and units processing or storing TCCA; and
- Improving its emergency response capabilities.