October 2015

Reflecting on “Extremely Profound Lessons”

topicsThe terrible tragedy that occurred last August in Tianjin, China highlights the need for companies to take a critical (but careful) look at the storage and handling of hazardous materials within their manufacturing sites and warehouses. Rapid growth, lack of oversight and lax safety procedures are being blamed for the blasts that killed more than 150 people and injured hundreds of others. Additionally, there are growing concerns regarding the extent and level of soil and water contamination that may have long lasting negative consequences for the environment.

A number of reports suggest that hundreds of metric tons of flammable gas, water reactive chemicals, toxic solids, strong acids, flammable liquids and perhaps even high explosives may have been stored in the port complex. Calcium carbide, which was reported to have been stored in large quantities at the Rui Hai International Logistics warehouse, is water-reactive and produces highly flammable acetylene gas. The facility also stored as much as 700 tons of sodium cyanide, a highly toxic solid which, when mixed with strong acids, reacts rapidly to create hydrogen cyanide, an extremely toxic gas.

Although the exact cause of the initial and subsequent blasts are not known, chemical incompatibility, coupled with an excessive quantity of dangerous substances stored in the warehouses and port facilities, may be the culprit. If not the cause, it certainly worsened the disaster.

Rui Hai International Logistics warehouse“Extremely Profound Lessons”
China’s President Xi Jinping has urged Chinese safety officials to learn “extremely profound lessons” from this and other accidents. Perhaps we should heed his advice as well.

The loss of so many lives should cause us to reflect on the lessons to be learned. Unfortunately, many of these lessons are learned the hard way. Do you remember the Bhopal Incident or what happened on board ValuJet Flight 592? How about more obscure incidents such as the 1982 K-Mart fire in Falls Township, NJ?

Granted, the readers of this article are probably not shipping or storing highly toxic solids, water-reactive materials or even corrosive liquids. More likely than not, however, readers will use or store highly flammable liquids or flammable gases under pressure. As such, an accident of this magnitude is extremely unlikely, but aerosols and flammable liquids can be dangerous nonetheless.

Therefore, I suggest that aerosol manufacturers, distributors and storage facilities take a hard look at their operations, equipment and practices. Are you prepared? Are you properly equipped? Do you store quantities of compressed gases and flammable liquids in excess of that amount allowed by the fire marshal? Do you have adequate fire protection? Are incompatible materials stored in close proximity to your goods?  Have your fire alarms, equipment and gas house protection devices been properly inspected and calibrated?

Companies are urged to closely review their Tier II chemical inventory, review and exercise their Emergency Response Plans, conduct a detailed fire and life safety audit of their facility and draft a Housekeeping Plan or Chemical Management Plan if not done already. Readers are also urged to review the requirements of National Fire Protection Association (NFPA) 30B as well. For example, NFPA 30B requires segregated storage of Level Two and Three aerosols in general purpose warehouses, special fencing around these materials, separation from other combustible materials, sprinkler systems that extend beyond the storage area, automatic self-closing doors and other requirements to prevent a dangerous chemical reaction or fire and to control it, if one does occur.

State fire codes, the International Building Code and NFPA 30B include provisions for the storage and display of aerosols. Chapter 28, Section 2806.3.3 of the Oregon Fire Code, for example, states that “Level Two and Level Three aerosol display and merchandising areas shall be separated from each other by not less than 25 feet,” and that Level Two and Level Three aerosol display and merchandising areas shall be separated from flammable and combustible liquids storage and display areas by a minimum distance of 25 feet horizontally, or separated by a noncombustible partition that extends 18 inches above the merchandise.

Unfortunately, however, these codes do not include detailed instructions on the separation required from oxidizers, acids or other incompatible dangerous goods. A facility might then look to the U.S. Dept. of Transportation’s (DOT) Hazardous Materials Regulations (HMR) for guidance. Although the HMR governs transportation, the term “transportation” is defined as including “storage incident to transportation.” Consequently, the wise safety manager should consider reviewing the segregation requirements outlined within this important reference. A quick review of the segregation table in 49 CFR §177.848 reveals that flammable gases of Class 2.1 (which includes most Level Two and Level Three aerosols) may not be loaded, transported or stored together in the same transport vehicle or storage facility during the course of transportation with high explosives of Divisions 1.1, 1.2 or 1.3; Blasting Agents of Division 1.5; and certain toxic gases of Class 2.3. Additionally, these materials may not be loaded, transported or stored together in the same transport vehicle or storage facility during the course of transportation unless separated in a manner that, in the event of leakage from packages under conditions normally incident to transportation, commingling of hazardous materials would not occur.

Sounds easy enough. However, when you review the requirements of 49 CFR §176.83(b), the segregation requirements for ocean transport are a bit more restrictive. Class 2.1 flammable gases must be stowed “away from” or three meters (10 feet) from dangerous goods of Class 4.1 (flammable solids) and Class eight (corrosive liquids and solids). These articles must be stowed “separated from or six meters (20 feet) from dangerous goods of Classes 1.4, 1.6 (low explosives), 4.2 (spontaneously combustibles), 4.3 (water reactive materials), 5.2 (organic peroxides), and radioactive materials of Class seven. Flammable gases must be stowed 24 meters (80 feet) from incompatible dangerous goods in Classes 1.1, 1.2, 1.3 and 1.5 (high explosives and blasting agents), and 6.2 (infectious substances).

The use of the more restrictive segregation table in 49 CFR §176.83(b) may offer some good guidance on separating incompatible goods, thereby preventing dangerous interactions and possible catastrophes like the one that so unfortunately occurred in August.

For questions regarding the segregation of dangerous goods in storage or transit, or to receive a copy of these segregation tables, contact the author by e-mail: [email protected] or by phone at (310) 370-3600.