“At the heart of the CSB's recommendations is the fact that trailers and similar temporary structures rarely, if ever, need to be placed near hazardous areas,” Gomez said in the letter. “We are concerned that, in its current form, the draft does not provide guidance that would effectively address this central issue.”
In the wake of the March 23, 2005, explosion at BP's Texas City, Texas, refinery, CSB urged API – which is the largest oil industry association – to develop new guidelines to ensure that mobile trailers and similar temporary structures are placed safely away from hazardous areas of process plants. According to CSB's final investigation report, all 15 of the fatalities in the Texas City blast occurred in or around mobile trailers that were sited too close to hazardous process equipment – the refinery's isomerization unit – during a startup.
“Our investigation clearly indicates that temporary structures can pose serious risks to occupants when they are sited near hazardous areas,” Gomez wrote. “Guidance for the industry in this matter, therefore, should explicitly seek to minimize the use of these structures in hazardous areas, and to provide a substantial degree of safety for the rare occasions when they might be used, because of their high potential to cause serious injury and death in the event of explosions.”
Gomez expressed concern that API's draft guidance – Recommended Practice 753, Management of Hazards Associated with Location of Plant Portable Buildings, First Edition, December 2006 – “would fall short of providing such guidance.”
"API Guidelines Carry a Great Deal of Weight"
Gomez, who is the director of CSB's Office of Recommendations, said that API has fallen short of the agency's trailer siting recommendations in three main areas:
- Minimum safe distances for trailers and similar temporary structures (“which is the explicit purpose of the CSB recommendation”).
- Explicit guidance to protect occupants from accident hazards when an analysis indicates a risk of fatality or injury.
- A separate methodology to ensure the safe placement of occupied trailers.
“The final API recommended practice in this area will have a substantial impact on the hazards related to trailers and similar temporary structures in the refinery industry and beyond,” Gomez wrote. “The CSB considers it very important, therefore, to ensure that the final version comprehensively address the issues raised by the recommendation.”
CSB board member William Wright, speaking at the 22nd Annual International Conference of the Center for Chemical Process Safety, noted that API is “an important organization” and that “API guidelines carry a great deal of weight.”
“Strong guidelines and recommended practices on temporary structures from the API could help save lives and prevent the kind of tragedy that occurred at BP in 2005,” Wright said.
API spokesperson Bill Bush told OccupationalHazards.com that API last year invited CSB and other stakeholders to comment on its draft guidelines. Bush said that "all of the comments received are being taken into consideration."
According to Bush, API "is close to completing the recommended practice" and expects to issue the final version "later this spring."