Double Jeopardy & Process Hazard Analysis

Hey guys, hope you are doing well. Today we are discussing "Double Jeopardy" which creates regular dilemma and stirs up arguments during PHA sessions. If you have participated as a team member or facilitated or scribed in a PHA session, you would be aware of the term "Double Jeopardy". When someone declares, “That’s double jeopardy,” during a PHA, they are definitely not fighting a legal case in court where double jeopardy prevents a person from being tried in court twice for the same offense. Instead, they are arguing that because two things have to go wrong to cause a scenario, the likelihood is so low that it is not credible and there is no need to consider the scenario.

Strategy to define risk reduction measures in PHA

Hope you and your families are keeping safe from COVID. I have been away from writing for some time now as I took up a new professional role in July and had a lot going on. But one of my new year resolutions was to again start writing the blog and share valuable information with you all. Today I am writing about a strategy one can opt for while providing recommendations in a PHA in order to ensure the provision of effective safeguards.

Process Hazard Analysis (PHA) identifies and evaluates hazardous scenarios forming an initiating event - consequence of interest pair. Evaluating a hazardous scenario helps to determine the adequacy of safeguards for a scenario and to establish requirements for improvement of existing safeguards or installation of new safeguards. 

The need for risk reduction measures is defined based on risk assessment usually utilizing predefined risk matrices. Risk reduction measures fall in either of the two categories “Preventative” and “Mitigative”. Preventative is a category that focuses on preventing the hazard while Mitigative is a category that focuses on minimizing the consequences of an event. 

In order to define risk reduction measures, one of the useful strategies is to employ the hierarchy of controls:

Recent incidents in Indian Industry creating turmoil

Yesterday's fire and explosion incident in Yashashvi Rasayan has made me ponder upon the prevention and protection measures taken by the manufacturing plants.

The incident has been said to be in the tank farm area. As per the initial reports, the fire in the tank farm has lead to an explosion of solvent storage tank/ tanks. In multiple images, damaged tanks, hydrogen trolley and multiple other plant units could be seen in the near vicinity of the tank. The other images of the incident are quite disturbing with charred bodies lying on the ground. There is a disturbing video of a charred man asking for help outside the plant that is being circulated in social media. The root cause of the incident still needs to be confirmed by the authorities. 

This incident combined with Vizag Styrene release and Tarapur surfactant factory explosion has put multiple questions in my mind. 

• Do you think that the understanding of Indian industry to process safety has improved? Do you think enough measures are taken in a plant to prevent unsafe acts and unsafe conditions? 

• Do you think that management of your plant or the neighbouring plant is seriously implementing measures and filling gaps identified in audits and PHA studies? 

• Do you think that government authorities are seriously making proactive reviews of the sites? 

• Do you think our laws and regulations related to industries are stringent enough to make the industries realise that they have more to lose in an accident than to gain in the normal operation of the plant? 

In my opinion, some industries have a better understanding of the importance of process safety in their plant and they implement preventive and protective measures as well. But several of them lack resources and knowledge related to process safety and how to prevent unsafe conditions and acts in their plants. They are still limited to hard hat and steel toe shoes safety which is important, but there is so much more to safety.

Many do not understand the importance of a good PHA study and how it can help in preventing and safeguarding against incidents. For example, I have worked with companies representatives who have asked me "why are you taking a scenario of external fire in a tank farm as I have enough fire monitors and hydrant points available in plant to fight such a scenario?" or "Why are you recommending a dump tank for a PSV release as I have high-pressure alarm and interlocks for my vessel?"

Although we have many existing guidelines, laws and regulations. Also, frequent inspections keep on going on in our plants. But it is high time to bend our perspective towards Process Safety along with general safety. It is high time that we understand and focus on topics like chemical reaction and thermal runaway hazards, facility siting, the importance of Management of Change and quality PHAs, risk of Dust Explosion, risk of fire/ explosion due to electrostatic discharges, the importance of QRA (Quantitative Risk Assessment) and LOPA (Layer of Protection Analysis) studies for the major accident hazard scenarios, the importance of Process Safety Management (PSM), etc.

These incidents leave us and our families devastated and in turmoil. We need to learn from these incidents and improve our facilities. At the end of the day, we all should return to our families safe and sound.

Remote HAZOP & LOPA Workshops

Hope you and your families are keeping safe and following the safety guidelines. During these tough times of COVID-19, face-to-face meetings have become a major challenge. To avoid any project delays and missed deadlines, many of my clients have asked me to host HAZOP and LOPA workshops via video conferencing while working from home.

I thought it would be helpful to share some tips for remote facilitation based on my experiences:

St 1 dust - Dangerous or not?

Hope all of you readers are doing well. It is the time of Diwali here in India and everywhere one can see people in the festival mood. Be careful and safe & have a wonderful Diwali.

Today I am trying to clear another misconception which I have come across while talking about St 1 dust. Many of our clients have told me that we are handling St 1 dust which is also the so-called "WEAK EXPLOSION" hence the risk is low. 

I always give them the example of Imperial Sugar Explosion in 2008 where a St 1 Sugar dust lead to 14 fatalities or Didion Milling Co. explosion in 2017 where St 1 grain dust was to blame for 5 fatalities, a dozen injuries and $1.8 million fine.

Combustible dusts are ranked into one of four classes i.e. St 0, St 1, St 2 and St 3. The level of explosion violence increases as we go from St 0 to St 3. The only dust that has zero risks of the explosion is a St 0 dust. However, all other dusts have an explosion hazard including the St 1 dust which can compromise containment on a piece of equipment, or blow out the walls of a building. Grains, Sugar, Fluor, etc. all fall in St class 1 dust.

Importance of Facility Siting

Is the control room in your facility located close to the tank farm? Is any occupied or functionally significant buildings close to a Maximum Credible Loss Scenario? Is your cylinder storage shed close to the drum filling area?

If you have wondered about this ever, then you should read this article to understand Facility Siting. Some incidents from the past have cleared the importance of facility siting in a plant.

The Flixborough explosion in 1974, where cyclohexane explosion shattered control room windows, collapsed its roof and demolished the brick-constructed main office block. Twenty­ eight people died, and thirty-six were injured in this accident out of which Eighteen of the fatalities were in the control room. Fortunately, over 200 fatalities were averted as the incident took place on Saturday when the main office block was unoccupied.

The Phillips disaster of 1989, where 40000 kg (85000 lbs) of a mixture of ethylene, isobutane, hexene and hydrogen was released and exploded. The second explosion involved BLEVEs of two isobutene storage tanks and the third explosion was the catastrophic failure of the ethylene plant reactor. The explosions killed 23 employees and injured 314.

ATEX - Compulsion, Option or Need of the hour?

Let us talk about another misconception which is rooting in the minds of some people.

If my company is not in Europe, why should we perform an ATEX risk assessment? It's not applicable in my country, why should I perform modification to the existing equipment and fittings?

All risk assessments should follow the simple hierarchical ‘Three Rules of ATEX/DSEAR’ approach:

1. Do not have a flammable atmosphere, but if you do...
2. Do not ignite it, but if you do…
3. Do not hurt anyone.

ATEX intentions are simply to provide a coherent focus for controlling risks from:

1. Substances with flammable, explosive and oxidising properties. ATEX also covers Corrosives and compressed gases.
2. Substances which can create potentially explosive atmospheres
3. Controlling work activities involving other substances that could create a fire or an explosion

If you are in a country where ATEX/ DSEAR is not applicable, then you can consider this as a good engineering practice that you are reviewing your plants' operations to establish a Basis of Safety for each and every operation.

Dust Explosion in Equalizer 2 - Have you seen it yet?

I am sure if you are a movie enthusiast, you would have already seen Equalizer 2. 

Did you happen to notice Denzel Washington creating a flammable dust cloud? 

The movie market was too saturated with Gas Explosions, so here comes a new type of explosion. The director took full advantage of the shot inside a bakery. 

Process Safety Strategy - Chemical Reaction Hazard

It has been some time since I wrote my last post. I was on leave for my marriage. I have returned to the office now and I am back with another post on Chemical Reaction Hazards. Many times, I have come across people asking us what steps should be followed for identifying and mitigating the chemical reaction hazards. Today we will be talking on the same.

First, of all, I would like to thank Fauske & Associates LLC (FAI) for their continuous support and for publishing my last blog post on their website. If you have missed the same, you can access it by clicking on the link below

https://www.fauske.com/blog/should-set-point-for-pressure-relieving-device-be-equivalent-to-design-pressure

As per the research conducted by Dr Phil Nolan (South Bank University, UK) and Dr John Barton (UK Health and Safety Executive) and graduate students based on data analysis, the following four gaps have contributed equally i.e. 25% each to thermal runaway reactions leading to multiple incidents in past:

1. Lack of proper understanding of the thermochemistry (heat of reaction) and chemistry (balanced chemical equation)
2. Insufficient engineering design for reactor heat transfer system
3. Inadequate control and safety back-up systems including emergency relief systems, process vent, and other engineering controls
4. Poorly written batch procedures and insufficient operator training.

Concept Sciences Inc. Explosion

Hence, it is imperative to develop a process safety strategy to address these four gaps. A process safety strategy should include the following:

Should set point for Pressure Relieving Device be equivalent to Design Pressure?

Hope all of you are doing well. Today's topic is focusing on the general practice sometimes followed in industry related to the set point of Pressure Relief Devices of process equipment. Many times during PHA, I have come across a general philosophy of keeping the set point of the reactor's pressure relieving devices equivalent to its design pressure. This might be adequate for a non-reactive system. But the question is, is it adequate for a reactive system?

Here, the reactive system is one where there are hazards due to a chemical reaction, including the possibility of decomposition or polymerization or some side reaction, etc. We know based on normal kinetics that the rate of reaction is directly proportional to the temperature which in turn is proportional to pressure. In simple terms, it is said that the rate of a chemical reaction doubles with every 10 deg C rise in the reaction temperature. Hence it can be said that:

Higher set pressure leads to a correspondingly higher "set" temperature (i.e. the relieving temperature).  This, in turn, leads to a higher rate of reaction which results in higher self-heating or higher temperature rise rate (dT/dt i.e. deg C/min) and a higher pressure generation rate (dP/dt i.e. bar/min). This is very important because for a chemically reactive system the required pressure relief area depends directly on the self-heating and pressure rise rates at the relief conditions.

Dust Flash Fire in a hostel - Who said that they don't see a dust explosion at home?

Happy New Year 2019 to all of you!

The Dust Flash Fire incident in Baptist University of Hong Kong has left all of us in shock with immense sadness and a heavy heart. Birthday party went wrong and ended in burning and injuring 12 students.

Five students were having a collective birthday party and were singing around the birthday cake. Someone in the group started throwing flour around, which probably got ignited by the burning candle and the flames reached the ceiling height leaving students with first and second degree burns on arms, legs and face.

Insights of a Dust Hazard Assessment (DHA)

Thank you all for your continuing support on my blog posts. Keep sharing with your friends and colleagues.

We have discussed a lot about dust explosion hazards and the risk to plant. The next question which stands is "How to carry out Dust Hazard Assessment (DHA)?" The intent of this post is for making you aware of how you can carry out a dust hazard assessment or if you have a third party doing it for you, then how to review the DHA report?

Risk Ranking:Essence of any Hazard Analysis

Recently, I was giving training on HAZOP and I got a question "Why do you say that our HAZOP is incomplete without risk ranking? We are doing the study since so long and no auditor or authorities have ever questioned us for the same." 

So this question has made me think about the situation Process Safety is facing. We know that oil & gas has developed more than other sectors including FMCG, Pharmaceutical, Chemical (Bulk & Speciality), etc. with far better standards for performing safety studies including PHAs. So, here I am writing this post to share the importance of risk ranking in any hazard analysis technique.

When is risk low enough : Risk Acceptance and ALARP

I would like to thank you all for continued interest in the blog posts. Keep reading and do like, share and comment. In this blog, we will be discussing what is the risk acceptance criteria and what is ALARP to define When is the risk low enough.

No activity is entirely free of risk in an industrial plant and hence it is imperative that safety risks are reduced to acceptable levels. The key question that remains is what level of risk is considered to be acceptable? 

Are you aware of the Dust Explosion Hazards in your facility?

I have written some blogs answering questions which I have received during training sessions or by email from our clients. Today I am sharing my experience related to the awareness level of manufacturing companies related to Dust Explosion. 

I made a recent visit as part of a non-profitable project to one of the most widely used Detergent and soap brands in India. As soon as I reached the gate of the plant, it was clear that I have entered a plant which hasn't been too serious about safe operations or safety of employees, as I could see the workers moving without any footwear leaving their feet marks in the raw materials spilled on the floor. There was so much dust and detergent in the air that I could taste detergent on my tongue till the next day of my visit.

Safe Practices for Sulphur Handling

Thanks for overwhelming responses on the recent blog post on Housekeeping and Secondary Dust Explosion & Relief Device Sizing.

I have recently published one of my articles in an Indian Magazine called "Chemical Weekly" in 10th July Edition. Attached below is a copy of the article.

Safe Practices for Sulphur Handling

The purpose of this document is to enable companies to establish reasonable prevention and protection measures, to eliminate or reduce the risks of fire and explosion inherent to handling of sulphur. This document is primarily concerned with the hazards arising from processing of solid sulphur, but also considers the major risks associated with handling sulphur in liquid form.

Hope you will find it useful. Do share the same with your friends and colleagues. Do follow the blog and keep writing to me for any questions and issues on himanshuchichra@gmail.com.

Housekeeping and Secondary Dust Explosions

Thanks for such brilliant response to my past blog on Relief Sizing. It really feels satisfying when it gives food for thought to people about their own plants. It is a much wider subject, hence all of us can hold different opinions on what is already there in terms of regulations and what is practically being done at the grass root level. In the end, my objective is simple and that is to make the community aware of some process safety aspects which can help them make their operations safer.

For this blog, I will be discussing the importance of housekeeping to prevent Dust Explosion or should I say Secondary Dust Explosions.

How many companies out there still utilise compressed air for cleaning of equipment surfaces and to blow off the settled dust from surface/ floor/ clothing?

How many of them still dry broom dust settled on the shop floor?

How many of you still don't know that the powder which is settled on equipment surface, shop floor, electrical fitting, etc., is combustible in nature and can result in fire/ explosion hazard in the plant?

How many of your plants have false ceilings and that hidden area is not being reviewed for any powder accumulation?

How many of you still use non-rated vacuum cleaners in plant areas to remove the spilt dust?

Relief Device Sizing and worst case scenario of Over-Pressurisation

Thanks to all for overwhelming responses to the recent update on Partial Inerting and Operator Earthing.

Looking at recent incidents that have happened in India, this topic was long due to being covered here on my blog. If we look at the Hyderabad Reactor Explosion or Tarapur Explosion or the more recent Moosapet Explosion, all have been suspected to be reactor explosion because of overpressurization.

The companies who are into manufacturing sector usually size their relief devices in the designing stage, when the process to be followed is not finalized and hence they assume a base solvent and size the relief devices for its vaporization in case of an external fire.

Now if we consider the T2 Laboratories accident where MCMT (Methylcyclopentadienyl Manganese Tricarbonyl) was being manufactured, an explosion which was equivalent to 1400 pounds of TNT was a case of a runaway reaction and killed 4 employees of T2 laboratories and injured 32 others. The impact was heard till 15 miles, the debris was found up to one mile away & buildings were damaged till one-quarter of a mile.

Operator Earthing - Are you doing it correctly?

Thank you guys for such an awesome response to my last blog post on Partial Inerting. It was made clear from the responses, that it is rather an unexplored topic in many parts of the world. Keep sharing your thoughts and keep sharing the blog with your colleagues, friends and students.

For today's blog post, I am picking up a basic concept of OPERATOR GROUNDING and what is the correct way to actually do it. There are many industries who provide Safety Shoes (maybe antistatic/ static dissipative) to their employees working on the shop floor, however, a substantial misconception regarding grounding practices exist in the industries that "If I have provided my operator dissipative shoes he has been grounded adequately." Also, there are many who purchase shoes with higher resistance to the ground then what is recommended by the standards.

Partial Inerting - A Cost Efficient weapon against Dust Explosion

Hey everybody, hope you are enjoying my blog and finding the information useful in your field of work. Today we are talking about a topic which is rather less explored and understood in many industries as of now i.e. "Partial Inerting".

Let's start first with understanding Inerting. Inerting is defined as the replacement of "oxidant" in a system by a non-reactive, non-flammable gas, to make the atmosphere within the system unable to propagate flame. Inerting may be achieved by using a non-flammable gas, which will neither react with the fuel nor with the oxidant. There are many gases used for inerting such as Nitrogen, Carbon Dioxide, Flue Gases, Noble Gases (Argon, Helium), etc.

P.S: Some material may react with these inert gases under some conditions. Hence, correct selection of gases is critical.

Now let's discuss the concept of PARTIAL INERTING to prevent dust fire and explosion. Partial Inerting means dilution of oxidising atmosphere with an inert gas but not up to the extent of LOC i.e. oxidant concentration lies between LOC and atmospheric concentrations. In other words, for partial inerting, the oxidising atmosphere (most often air) in which the explosible dust is dispersed is mixed with a fraction of inert gas (e.g. nitrogen) considerably smaller than that required for complete inerting (i.e. below LOC).