CSB Safety Study Calls for Remote Isolation Equipment at Chemical Facilities

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The U.S. Chemical Safety and Hazard Investigation Board (CSB) released a safety study on July 25, 2024, that calls for greater use of remote isolation equipment at chemical facilities. Such devices are designed to mitigate chemical releases remotely from a safe location. As a result, CSB believes that they will decrease the likelihood of serious injuries, fatalities, environmental contamination and facility damage following loss-of-containment incidents.

The safety study stemmed from CSB’s review and investigation of the November 2019 explosions and fires at the TPC Group chemical plant in Port Neches, Texas. The Port Neches incident occurred after a suction pipe carrying highly flammable butadiene — a building block in the production of a wide range of polymers and copolymers — ruptured and created a butadiene vapor cloud. The vapor cloud ignited, causing extensive facility damage and a fire that burned for more than a month. In its final report on the Port Neches incident, CSB recognized that the chemical plant was not equipped with remotely operated emergency isolation valves (ROEIVs). According to CSB, ROEIVs could have prevented some of the secondary explosions and fires and minimized facility damage. CSB’s investigations of several other catastrophic chemical incidents reached similar conclusions.

Notably, CSB’s safety study makes three separate recommendations: one each directed to the American Petroleum Institute (API), U.S. Environmental Protection Agency (EPA), and U.S. Occupational Safety and Health Administration (OSHA). CSB recommends that the API “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.” To the EPA, CSB suggests that it “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.” And for OSHA, CSB recommends that it “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.”

CSB also makes a plea to operators of chemical facilities, requesting that operators proactively assess whether remote isolation equipment should be installed on major process equipment even in the absence of new industry standards and federal regulations. According to CSB, doing so will save lives, protect the environment and safeguard critical infrastructure.

Only time will tell whether CSB’s recommendations will be implemented. In the meantime, the chemical industry should be aware of CSB’s warnings and calls for the industry to proactively install remote isolation equipment to help mitigate loss-of-containment incidents. CSB’s safety study may also signal to industry that CSB may be more likely to focus on investigating similar incidents in the future.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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