Lessons Learned Bulletin - Special Issue #1

Special Issue
May 2020
JRC 120768

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Chemical Accident Prevention & Preparedness

Pandemic measures and chemical process safety

The aim of the bulletin is to provide insights on lessons learned from accidents reported in the European Major Accident Reporting System (eMARS) and other accident sources for both industry operators and government regulators. JRC produces at least one CAPP Lessons Learned Bulletin each year. Each issue of the Bulletin focuses on a particular theme.

Explosion at a plastics factory, Ottaviano, Italy, 5th May 2020

An explosion at a plastics factory near Naples, Italy killed one person and injured two others on May 5. Local media reported that the blast could be heard from several kilometres away, while witnesses reported seeing a large plume of black smoke rising from the factory premises. The explosion occurred in the vicinity of the process ovens, destroying buildings and burying one of the employees in the rubble. The employee was freed, but died almost immediately of his injuries. The local population was recommended to close doors and windows and to avoid any unnecessary movement of people, particularly in the area close to the site. The factory had only reopened on May 4th after the Italian government eased the lockdown in the country following the coronavirus pandemic.

Shut down and start-up of facilities handling hazardous substances

Shut down and start-up of operations are dynamic processes that have particular hazards associated with them. In particular, shut down and start-up in connection with the Covid-19 pandemic brings specific issues, which need to be considered.

Shut down needs to be carried out in an organised and structured manner. If the shutdown is for a longer or undetermined period of time then the operator needs to be aware of measures which need to be taken to maintain a high level of safety over this period. For example:

• Some hazardous materials degrade over time. These inventories need to be minimised and their situation monitored.
• Nitrogen blanketing to protect against explosive atmospheres needs to be maintained.
• Any loss of electrical power during the period of shut down will affect any systems that need to be maintained in operation (cooling, ventilation, pumping, stirring, etc.).
• Some processes, such as the storage of refrigerated gases, depend on a regular rate of consumption to maintain safe operating pressures (e.g., LNG, cryogenic ammonia). Reduced consumption due to a shutdown must be assessed and appropriate measures taken. If tanks containing such gases are emptied and not refilled with cold gas during a temporary shutdown, the operator must ensure that a cooling procedure is effected before refilling the tank.
• Warehouses that are not opened regularly, and thus ventilated through the transfer operations, may heat up due to external temperatures and absorption of solar radiation. This can lead to the release of hazardous materials or the build-up of hazardous atmospheres within the warehouse.

Start-up also needs to be carried out in an organised and structured manner. The operator should not assume that everything has remained unchanged throughout the shutdown. Temperature and pressure changes in the process systems may mean that hazardous atmospheres have been created, where they previously did not exist. If it is unclear whether the electrical power supply has been uninterrupted, then the conditions in some parts of the facility may not be well known. It is important that the plant is inspected and tested before restarting and that the start-up process is monitored.

Both shutdown and start-up in relation to the Covid-19 pandemic have the risk that management may become distracted. The priority of keeping the establishment safe may compete with other priorities. In particular, in the shutdown phase the management will need to demonstrate compliance with the requirements of the authorities. In doing so, they will have to ensure that all measures are in place to prevent infection of employees and the public, including possibly reducing the number of staff involved in the shutdown.

Moreover, the business interests of management will be a high priority during this time, potentially taking focus off plant safety. Operating under intense economic pressure can be detrimental to safety goals. Management may be more concerned about maintaining the supply chain, and the economic viability of the operation once restarting is possible. These concerns may influence the start-up phase, where the need to return to market may take precedence over starting the plant safely. In this case, the management may risk taking shortcuts in starting up operations such that they fail to do routine checks, e.g., ensuring critical safety equipment is intact, that substances are stable and in the right place, and conducting tests to confirm that safe process conditions are met before start-up, etc.

The competent authorities can also help support safe operation of hazardous facilities during a pandemic crisis. In particular, they can promote awareness of the potential risks through various types of communications. For example, competent authorities can consider conducting inspections at a distance, and asking questions about production and maintenance activities continuing onsite during shutdown as well as staffing and supervision. Authorities may also wish to send out a bulletin or information letter or guidance noting the potential for elevated risk during this period. Communication may include recommendations for keeping their employees and the public safe from infection. The competent authorities may also need to pay particular attention to any sites that might have been undergoing maintenance turnarounds or other abnormal situations when the pandemic shutdown was imposed. It is also very important to develop emergency plans and communication with the relevant authorities so as to be able to respond to a chemical accident during the restrictions of the pandemic crisis. The authorities should develop their own strategies and priorities based on their own knowledge and experience with the sites under their authority And take account of pandemic impacts on the availability of medical resources.

For hazardous sites, especially chemical processing sites and petroleum oil refineries, safe shut down of operations, maintaining safety during the shutdown period, and safe start-up are all keys to surviving the pandemic. Good corporate governance and risk management are essential. The chances of avoiding an incident, especially a serious accident, can be considerably reduced if the operator has a conscious strategy to keep plant safety at the forefront while addressing other pandemic-related concerns. The competent authorities can give support by spreading awareness, establishing measures to monitor the situation, and ensuring appropriate preparedness measures are in place.