Manny Ehrlich has championed the cause of emergency response and planning in the hazardous chemical industry for more than 30 years.
"That's my bailiwick," said Ehrlich, a member of the U.S. Chemical Safety Board (CSB). "We constantly look at and talk about preventative maintenance issues. It's very important and very critical. We see a lot going on in that arena that doesn't need to happen."
While the chemical and petrochemical industries have done "a phenomenal job" in personnel safety, Ehrlich said more attention needs to be paid to process safety and activities.
In his presentation, "The Consequences of Not Knowing What You Don't Know," at the Operational Excellence in Refining and Petrochemicals Summit held recently in Houston, Ehrlich discussed how the safety board drives chemical safety change through dependent investigations to protect people and the environment, with the objective of preventing chemical disasters from occurring.
"It's been my position over a number of years that nobody can know everything, although I have to tell you, in my career in the chemical industry, I've run across a lot of people who think they do," Ehrlich said. "Those people who think they know everything are the ones to watch out for."
No one can know everything about a specific topic, issue or activity, Ehrlich reasoned.
"When I ran the Emergency Response Training Center in Pueblo, Colorado, there were people who swore after 40 hours of training they were crack Haz-Mat responders," he said. "I've had over 4,000 hours of training, and there's still a lot left for me to know.
"People don't get it."
Uncertain future for safety regulations
Ehrlich's ultimate objective is a simple one: that people "go home the way they left."
The CSB's "Drivers of Critical Safety Change" addresses topics to help meet that objective. Those drivers include OSHA's combustible dust standard, modernization of the U.S. process safety management regulations, emergency response, preventative maintenance and hot work.
Ehrlich noted workers often fall short of taking the proper precautions to ensure safety when performing tasks related to hot work.
"I just read a report about a pulp and paper facility where folks were doing hot work near a tank that had turpentine and some other chemicals in it, and the tank blew up," Ehrlich said. "Three people were killed. That didn't have to be."
Ehrlich outlined seven factors in need of constant attention in the emergency response and planning arena: inadequate or poor training, poor or inadequate planning, improper use of notifications, no Incident Command System (ICS) or National Incident Management System (NIMS) compliance, lack of emergency response exercises, lack of communications ability, and no community or responder facility ties.
"I went back and matched these against 14 investigations where clearly the lack of emergency response, planning, incident command or adherence to NIMS was responsible for major issues," Ehrlich said.
Referring to the 2013 chemical explosion at West Fertilizer in West, Texas, that left 14 people dead, he said the company had no structure or training in place.
"They had a devastating event," Ehrlich said.
Ehrlich noted OSHA's combustible dust standard is also a priority.
"God only knows what's going to happen with that," Ehrlich continued. "In fact, God only knows what's going to happen with any regulation related to the EPA and OSHA for the next three or three-and-a-half years, except that a lot of them are going to go away. I don't have any sense that we're going to get any new regulations for at least the first half of the administration that's currently in place."
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