CHEMICAL SAFETY AND HAZARD
On March 23, 2005, the BP Texas City refinery experienced a severe explosion
fire accident involving a raffinate splitter tower within the isomerization
unit and associated blowdown system that resulted in 15 deaths, 170
and significant economic losses; the accident was one of the most serious
workplace disasters of the past two decades.
All of the fatalities and many of the serious injuries occurred in or around the
contractor trailers that were sited near process areas and as close as
121 feet from
the isom unit. This unit contained large quantities of flammable
and had a history of releases, fires, and other safety incidents
over the previous
Workers in adjacent units were injured in trailers as far as 480 feet from the
blowdown drum. A number of trailers as far as 600 feet from the blowdown
were heavily damaged.
At the Texas City refinery, trailers had been periodically sited in and around
process areas for reasons of convenience such as ready access to work
The trailers did not need to be located as close as they were to the process
in order for workers to perform their job duties.
Trailers had been sited periodically in the same location near the isomerization
for a number of years. On September 1, 2004, and prior to a safety
BP placed the trailer where 12 workers died near the isomerization
month later BP applied a siting policy to approve the location. The eight
trailers placed nearby were not analyzed for hazards related to their location,
was the impact of the total occupancy of multiple trailers in close proximity
Under BPs siting policy, trailers used for short periods of time such as
trailers were considered as posing little or no danger to occupants.
conforms with the guidance provided in American Petroleum
Institute (API) Recommended
Practice 752, Management of Hazards Associated
with Location of Process
Plant Buildings. API 752 states that each company
may define its own
risk and occupancy criteria.
API 752 is a widely recognized practice for complying with facility siting
under the Process Hazard Analysis element of OSHAs Process
Standard (29 CFR 1910.119).
8. API 752 provides no minimum safe
distances from hazardous areas for trailers
used in refineries and other chemical
facilities. Trailers are not generally designed
to protect the occupants from
the fire and explosion hazards present in refineries.
In contrast, occupied
buildings (e.g. control rooms, operator shelters) located
within a process
unit are typically permanent and constructed to be blast and fire
Trailers can be easily relocated to less hazardous sites. Subsequent to the March
incident, BP America Inc. announced that it would move trailers at least 500
from hazardous process areas. A number of contractor offices were moved to
In 1995, another serious process plant incident involved occupied trailers placed
close to hazardous areas, resulting in significant deaths and injuries. At the
Refinery in Rouseville, Pennsylvania, a hydrocarbon fire that resulted
the bursting of two storage tanks led to five fatalities, including two
who were in trailers sited near the tanks. A 1998 EPA investigation
determined that if the trailers had been isolated from the storage tank area
casualties may have been prevented.
Under 42 U.S.C. §7412(r)(6)(C) (ii), the Board is charged with recommending
to reduce the likelihood or the consequences of accidental releases and
corrective steps to make chemical production, processing, handling and
as safe and free from risk of injury as is possible
Board procedures authorize the issuance of an urgent safety recommendation
a final investigation report is completed where there is a likelihood that a
issue is widespread at a number of sites.
to its authority under 42 U.S.C. §7412(r)(6)(C)(i) and (ii), and in the interest
promoting safer operations at U.S. petrochemical facilities and protecting
communities from future accidents, the Board makes the following
In light of the above findings concerning the March
23rd incident at BPs Texas City
refinery, revise your Recommended Practice
752, Management of Hazards
Associated with Location of Process Plant
Buildings or issue a new Recommended
Practice to ensure the safe placement
of occupied trailers and similar temporary
structures away from hazardous areas
of process plants. Ensure that the new
occupants from accident hazards such as heat, blast overpressure, and
Establishes minimum safe distances for trailers and similar temporary
away from hazardous areas of process plants;
* Evaluates the siting of
trailers under a separate methodology from permanent
structures, since trailers
are more susceptible to damage, are more readily
relocated, and likely do not
need to be placed near hazardous areas.
Petroleum Institute and the National Petrochemical and Refiners
a safety alert to your membership to take prompt action to ensure the safe
of occupied trailers away from hazardous areas of process plants.