Debate over inherently safer technology (IST) at chemical plants intensifies
“The very best way to prevent an explosion is to simply replace the material that explodes with one that does not, or at least keep the stock down so low that it hardly matters if it all leaks out,” Keltz told C&EN in 2003.
In response to a New York Times editorial in which CSB head Rafael Moure-Eraso called for regulators to require IST, and for industry to adopt it, three industry trade groups — the American Chemistry Council, the Society of Chemical Manufacturers & Affiliates (SOCMA), and the American Fuel & Petrochemical Manufacturers — published a letter to the editor in the Times, claiming IST is “an engineering philosophy, not a technique,” adding that the United States “has some of the most stringent regulations in the world.”
The trade groups urged regulators to focus on fully enforcing current regulations instead of making new ones. According to industry officials, adopting IST could lead to the elimination of some hazardous yet essential chemicals. Reducing or eliminating storage of some chemicals “would prevent some companies from effectively meeting their customers’ needs,” adds Jennifer Gibson, vice president of regulatory affairs at the National Association of Chemical Distributors.
IST also calls for facilities to reduce the amount of materials or chemicals they store on-site; which would increase transportation of the materials or chemicals, thereby spreading the risk of chemical accidents to different points along the supply chain. “Inherent safety is a superficially simple but truthfully very complex concept, and one that is inherently unsuited to regulation,” adds William E. Allmond IV, SOCMA’s vice president of government and public relations.
One school of thought on the implementation of IST argues that IST will not prevent all facility incidents, but that it should be the first approach when considering ways to reduce risk at industrial facilities. The U.K.’s Health & Safety Executive (HSE), which regulates workplace safety in England, operates a program which aims to reduce facility risks “as low as reasonably practical.” According to Ian Travers, head of HSE’s chemical hazard division, under the regulatory program facilities must consider the cost-benefit analysis of IST implementation. New facilities are required to conduct an initial risk review, including IST options during design, and existing facilities must periodically review and revise their operations to reflect IST implementation or consideration.
For American facilities, the CSB suggests that the EPA could require IST testing through the General Duty Clause of the 1990 Clean Air Act, which requires companies which deal with toxic chemicals to identify hazards, design and maintain safe facilities, and minimize the consequences of potential chemical accidents. Industry officials argue that current regulations, and the interest of facility operators to maintain a safe workplace, are sufficient incentives for companies to consider and adopt safer alternatives, including IST.
In opposition, Christine Todd Whitman, former EPA administrator, insist that companies cannot be left to adopt IST methodologies themselves. “People’s lives are at stake. That’s why we need to have action at the federal level,” Whitman says. A mandate to require facilities to adopt some IST concepts “when they’re available, effective, and affordable is common sense.”
— Read more in Trevor Kletz and Paul Amyotte, Process Plants: A Handbook for Inherently Safer Design, 2nd ed. (CRC Press, 17 May 2010); and Inherently Safer Chemical Processes: A Life Cycle Approach, 2nd ed. (Wiley, December 2008)
