The recommendations stem from CSB's investigation of a March 23 explosion and fire at BP's Texas City, Texas, refinery that killed 15 workers and injured more than 170. The explosion took place in the refinery's isomerization unit, which was undergoing a restart at the time of the accident.
CSB says its investigation found that all of the fatalities occurred in and around a group of nine trailers involved in maintenance work unrelated to the restart. Some trailers were as close as 121 feet from the unit, and more than 40 trailers were damaged in the incident.
"We are calling on the industry to establish minimum safe distances for trailers to ensure the safety of occupants from fire and explosion hazards," CSB Chairman Carolyn Merritt said. "The tragedy at BP's Texas City refinery warrants changes in safe siting practices across the nation."
The urgent recommendations were announced in advance of a public meeting CSB will convene Oct. 27 in Texas City to discuss the findings of its investigation.
Recommendations Directed to Trade Organizations
CSB directed the urgent recommendations to two leading national trade organizations, the American Petroleum Institute (API) and the National Petrochemical & Refiners Association (NPRA), which represent most major domestic oil and petrochemical producers.
API develops recommended safety practices that influence operations at thousands of petrochemical facilities around the country. The first recommendation calls on API to develop new industry guidance "to ensure the safe placement of occupied trailers and similar temporary structures away from hazardous areas of process plants."
CSB noted that the existing safety guidance, API Recommended Practice (RP) 752, does not prohibit the placement of trailers in close proximity to hazardous process units. The guidance, titled "Management of Hazards Associated with Location of Process Plant Buildings," is widely used by U.S. oil and chemical companies to assess siting hazards, a regulatory requirement under OSHA's Process Safety Management standard.
As currently written, API 752 allows individual companies to define their own risk and occupancy criteria for trailers. Prior to March 23, BP had defined trailers used for short periods of time as posing little or no danger to occupants and approved the location of the trailers at the Texas City facility.
According to findings accompanying CSB's urgent recommendation, the explosions in Texas City injured workers in trailers as far as 480 feet from the source of the release, and trailers up to 600 feet away were heavily damaged. After the incident, BP announced it would relocate trailers at least 500 feet away from potential hazards and move nonessential workers into office space outside the refinery.
"In many cases, trailers are positioned for convenience during maintenance and are not essential for facility operations," Merritt said. "They can be easily relocated to safe distances." Merritt noted that the permanent buildings in refineries and chemical plants are often heavily reinforced to resist blast and fire damage, while most trailers and temporary structures provide little protection for occupants.
API Will Consider Developing New Industry Guidance
In a statement, an API spokesperson said that the organization will convene a task force to consider CSB's recommendation.
"All API recommended practices and guidance documents are the products of an extensive and open, deliberative process and are ultimately approved based on consensus within the industry," the spokesperson said.
There currently are no federal regulations or industry standards for establishing buildings' minimum safe distance from hazardous areas within refineries, according to API, and API RP 752 "is used by companies for guidance in assessing potential risks associated with process plant buildings."
"The purpose of API RP 752 is to assist companies' analysis efforts," the spokesperson said. "Companies then define their own risk and occupancy criteria for individual facilities. This recommended practice can be used by companies as a guide in addressing facility siting under [OSHA's] Process Safety Management requirements."
CSB Urges 'Prompt Action' Until API Guideline is Ready
A separate urgent recommendation from CSB, directed jointly to API and NPRA, called on the organizations to immediately contact their members urging "prompt action to ensure the safe placement of occupied trailers away from hazardous areas of process plants" before the new API safety guidance is completed.
Under CSB procedures, the requested measures should be completed within 12 months, at which time CSB will consider closing the recommendation based on acceptable or unacceptable actions by the recipients.
The recommendations were only the second and third designated as "urgent" of more than 300 issued in CSB's 8-year history.
CSB's first urgent recommendation, issued on Aug. 15, called on BP to form an independent panel to examine its safety culture and oversight of its five North American refineries. BP on Oct. 24 announced formation of the independent panel, chaired by former U.S. Secretary of State James A. Baker III.
CSB is an independent federal agency charged with investigating industrial chemical accidents. The agency does not issue citations or fines but instead makes safety recommendations to plants, industry organizations, labor groups and regulatory agencies such as OSHA and EPA.
The full text of CSB's resolution issuing the new recommendations is posted on the agency's Web site, www.csb.gov.