The U.S. Chemical Safety Board (CSB) released its report and recommendations yesterday on the December 19, 2007 explosion at the T2 laboratory in Jacksonville, Florida.  The violent explosion took the lives of four individuals: Charles Budds Bolchoz, 48, Karey Renard Henry, 35, Parish Lamar Ashley36, and Robert Scott Gallagher, 49.  The CSB compared to blast to one from 1,400 pounds of TNT, and one “capable of flinging a one-ton chunk of the steel reactor onto a set of railroad tracks, then into a building 400 feet from where it had stood.”   At the time of the disaster, the company described its Florida facility as state-of-the art, and using a “novel, safe and efficient process.”   Obviously, something went terribly wrong with their supposed state-of-the-art safe process. 

What’s puzzling (and troubling) to me are the toothless recommendations contained in CSB’s report (PDF 71 pages).   This is an agency that I’ve applauded in the past for its bold demands on individual firms to make robust operational improvements, AND for broad regulatory and enforcement change at OSHA and EPA.  After reading the recommendations stemming from the CSB’s T2 Laboratories investigation, I shook my head, flipped the report pages back and forth, asking outloud, “that’s it?”  Two lousy toothless recommendations to non-governmental organizations??  

This is the second day in a row that the CSB’s action is disappointing, and forcing me to wonder again, what would Carolyn Merritt say?

The CSB Board failed miserably to use its authority to repeat, reiterate and urge OSHA to amend its process safety management (PSM) so that it explicitly addresses reactive chemicals.  This would include how reactive compounds should be stored and handled to prevent explosions, fires and releases.   Instead, the CSB’s report contains only two recommendations:

1. To the American Institute of Chemical Engineers, asking them to work with the Accreditation Board for Engineering and Technology, Inc. to add reactive hazard awareness to baccalaureate chemical engineering curricula requirements.
2. To the Accreditation Board for Engineering and Technology, Inc, asking them to work with the American Institute of Chemical Engineers to add reactive awareness to baccalaureate chemical engineering curricula requirements.
3. Baccalaureate = undergrad students

Now, there’s nothing particularly wrong with these recommendations, except that they are the ONLY ones made by the CSB in this report.  Had the two been part of a larger, more comprehensively list of recommendations directed at all the entities with current or proposed responsiblities for reactives, they would be appropriate.   But, that’s it?  These are the only recommendations the CSB could muster after a 20-month investigation?  It’s hard for me to believe this is all they could come up with.

I don’t have a problem with undergraduate students who are studying chemical engineering to learn something about reactive chemicals.   (I’d bet many of them already do.)  Or even for there to be some required curriculum on this topic in chemical engineering degree programs.  But, how are these supposed to comprehensively address the largely unregulated hazard of reactive chemicals?  At a minimum, it would have made strong public policy sense to repeat previous applicable recommendations from the CSB on reactives, especially those that have NOT been implemented by the responsible parties.  But the CSB didn’t use its authority—and the pulpit that accompanies it—-to do so.

Does the CSB really believe that these two recommendations, adding a lecture or homework assignment on reactives for 19- or 20-year old chemical engineering students [which might be all that would eventually result by implementing the recommendation] is enough to solve this deadly unaddressed hazard to workers and communities?  The  recommendation makes me wonder if anyone at the CSB has ever been involved in undergraduate education, curriculum requirements (say nothing of the kabuki dance that goes on between these educational accreditating bodies and the universities’ and colleges’ programs themselves.)

At my own eduational institution, our program is accredited by the Council on Education for Public Health (CEPH).  The organization has a long list of criteria designed to assess the quality of our graduate degree programs, such as student-to-teacher ratio, and coursework in epidemiology and biostatistics.  One CEPH requirement, for example, is to:

“develop skills in basic public health concepts and demonstrate the application of these concepts through a practice experience.” 

Our students fulfill this requirement by working at a local health department, or federal agency, or non-profit organization to see first-hand the practice of public health.  Does that mean as a country, we should depend solely on these individuals and this experience to be the answer to addressing our nation’s great public health problems?   Certainly not.   Their practical experience adds to the cadre of individuals who recognize the role of public health prevention, but we certainly don’t rely solely on student-centered efforts to tackle the whole problem.   Likewise, when Trust for America’s Health released last year its Blueprint for a Healthier America it identified roles and responsibilities for dozens of agencies, NGO’s, universities, and others to address our nation’s public health infrastructure, regulations, training and research.  

So it should have been with the CSB’s report on the T2 Laboratories investigation—-addressing the dangers to workers and communities from reactives needs much more than superficial changes in curriculum for undergraduate chemical engineering students.   I’m not alone in my assessment.

The United Steelworkers, International Chemical Workers Union Council of the United Food and Commerical Workers Union, and Change to Win, issued a statement today lambasting the CSB’s recommendations in the T2 Laboratories’ report.  The Charleston Gazette’s Ken Ward in “Chemical safety: Board backing off tough standards?” reports on the reaction of these labor groups and their criticism of the CSB for “abrogating its mandate,” and calling for new leadership at the CSB.   Ward explains why readers in his West Virginia backyard are paying close attention to the CSB’s behavior and commitment to public protection.

This is not the first time the CSB has warned about the potentially catastrophic hazards of reactive chemicals.  In 2002 the CSB completed a study of reactive chemical hazards, which identified 167 accidents over a two-decade period and made recommendations to improve reactive chemical safety.  It would have been wholely appropriate for the CSB to use the T2 report to recount the status of its 2002 recommendations.   Now, 7 years after that report came out, CSB should have made some headlines about recommendations unfilled, disregarded or ignored.   If the CSB is acting cautious about throwing the book at agencies, NGO’s, companies, and others with mere RECOMMENDATIONS, is it any wonder that our regulatory agencies are so guarded in their action??