West Texas and Ammonium Nitrate: Part 2

Ignorance that drives opinion that drives policy is what always needs to be fought against.  West Texas is a good case study for this.  I am wanting to answer "the inevitable questions about whether this tragedy could have been prevented."

First, though, I need to get some bad information out of the way and clear up some misunderstanding of how things work.  I do not claim to be an expert on all things environmental, but I have spent over 28 years of my life working in this industry dealing with these chemicals and the regulations that go with them.  When I write about what a particular regulation or laws states or requires I will back it up with a citation.

Here is what the organization "ProPublica" wrote on April 26, 2013:

Here’s what we do know: The fertilizer plant hadn't been inspected by the Occupational Safety and Health Administration since 1985. Its owners do not seem to have told the Department of Homeland Security that they were storing large quantities of potentially explosive fertilizer, as regulations require. And the most recent partial safety inspection of the facility in 2011 led to $5,250 in fines.

Notice all the synonyms they have for conjecture?  One of them is "assumption."  So let us start there and look at the assumption that had the facility been inspected more often, Mr. Ohman and ProPublica "surmise,"  this accident would have been prevented.

Maybe, but most likely not.

First, we have to assume that this explosion was the result of process management that would have been noticed during an inspection.  As of this posting date, we do not know what caused the fire that led to the explosion.  Even ProPublica acknowledges that:

"authorities still don’t know exactly why the West Chemical and Fertilizer Company plant exploded."

To make a statement that it was Gov. Perry's "gamble with the lives of families by not pushing for the strongest safety regulations" is to imply that Gov. Perry has prevented said inspectors and therefore assumes that an inspector would have seen the root cause for this explosion.

Maybe, but most likely not.

In 2009, a little less than 100 miles South from West, Texas, ammonium nitrate in a warehouse at the El Dorado Chemical Co. was involved in a fire.

That fire was the result of this:

The incident that put Bryan on national TV started with a worker welding at the plant, which blends and packages fertilizer and other chemicals. The worker told authorities that a spark caught nearby ammonium nitrate on fire, prompting a call to emergency crews at 11:41 a.m.

Even if the inspector had been there one hour before the welder started, they would not have been able to stop the root cause - the spark from welding - from coming in contact with the ammonium nitrate unless they witnessed the welding that was to take place.  Inspections are designed to make sure regulations are being followed, policy is in place, and to correct those things that are visible and apparent at the time of the inspection.

The inspector might - might - have been able to reiterate safety, but that's only if the inspector was there from OSHA or the TDSHS.  A TCEQ inspector only looks at the parameter relevant to the environmental issue they are there to inspect for.  Would more frequent safety and environment inspections have stopped the el Dorado fire involving the ammonium nitrate?

Maybe, but most likely not.

So, to answer the "inevitable questions about whether this tragedy (El Dorado Chemical fire) could have been prevented," I say, yes it could have.

How?  By making sure that the welder understood the need for a Hot Work Permit and the enforcement of that permit by the company.

The simple use of a Hot work Permit by the welder and the company would have - most likely - most assuredly - prevented a spark from coming in contact with the ammonium nitrate.  Its simple really; no spark, no fire.

Here is why a Hot Work Permit would have worked at the El Dorado Chemical Co. OSHA Regulations, 29 CFR 1910.252 Welding, Cutting, and Brazing:

Before cutting or welding is permitted, the area shall be inspected by the individual responsible for authorizing cutting and welding operations. He shall designate precautions to be followed in granting authorization to proceed preferably in the form of a written permit.

Source

Had that been done, had the welder and the company put two and two together - spark and ammonium nitrate = bad - this fire in Bryan would most likely - most assuredly - not have taken place.

The simple use of a Hot Work Permit, which you can found on the internet using a Google search, asks the following question:

Source

Had these questions been asked and addressed it is unlikely that a fire in the El Dorado chemical Company warehouse would have taken place.  I am going to speculate that this was not done.

See how simple it is?  All it takes is two people understanding why we "make" you do burdensome things like filling out a Hot work Permit.  the welder needs to understand what is going on around him/her and the company needs to make sure that the welder understands what the hazards are in the area they work.

Simple...

So what can we derive from the West Texas situation based on the fact that we do not know what caused the fire?  We can still answer the "inevitable questions about whether this tragedy could have been prevented."  There are two factors in play.  Preventing the fire from starting in the first place and protecting the responders when a fire does take place.

Let's focus on the latter, since that's where the lives were lost.  Once there was a fire in a fertilizer plant that uses ammonium nitrate, could the deaths of 12 responders been prevented?

Maybe not...but most likely yes.

That's what bothers me about all this.  It was a simple matter of understanding what was in the building where the fire was taking place.


Next post: West Texas and Ammonium Nitrate: Part 3

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