The U.S. Chemical Safety and Hazard Investigation Board released its final investigation report into a chemical fire and toxic gas release at the Bio-Lab Lake Charles facility in Westlake, La., in August 2020 following extreme weather during Hurricane Laura.
In addition to recommending steps that the company and Louisiana state officials should take to prevent chemical releases during future hurricanes, CSB’s report calls on federal regulators to increase their oversight of hazards associated with reactive chemicals.
CSB Chairperson Steve Owens said, “The CSB has investigated several incidents related to hurricanes and other extreme weather events. With powerful storms and other extreme weather occurring more frequently, companies and regulators must take action to prevent weather-related releases of hazardous chemicals that can cause substantial damage to facilities and threaten surrounding communities.”
The Lake Charles facility manufactures and supplies pool and spa chemicals containing trichloroisocyanuric acid (TCCA). TCCA is used throughout the country in pool care and, when put in large bodies of water such as a pool, breaks down slowly, releasing chlorine in the water.
However, when TCCA comes into contact with small amounts of water and does not dissolve, it can undergo a chemical reaction that generates heat, causing the decomposition of TCCA, which produces toxic chlorine gas.
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On Aug. 27, 2020, more than 1 million pounds of TCCA were on-site at the Lake Charles facility. As the Category 4 Hurricane Laura made landfall, its strong winds damaged buildings at the facility, including tearing off roofs. Rainwater from the storm contacted the TCCA stored inside the buildings, initiating a chemical reaction and subsequent decomposition. The heat initiated a fire.
A large plume of hazardous gasses, including toxic chlorine, traveled from the facility. A portion of nearby Interstate 10 was closed for over 28 hours, and local officials issued a shelter-in-place order for the surrounding community due to the release of hazardous gasses.
As a result of its investigation into the incident, CSB’s final report identifies five safety issues:
Extreme Weather Preparation
Bio-Lab did not learn the importance of preparing for extreme weather after the 2017 Arkema incident in Crosby, Texas, which also occurred following a Category 4 hurricane. Bio-Lab did not implement industry guidance for extreme weather preparation that was updated and published after the Arkema incident.
Process Hazard Analyses Implementation
TCCA is not covered by the Occupational Safety and Health Administration’s Process Safety Management (PSM) standard. Bio-Lab voluntarily implemented some elements of the PSM standard and even conducted a 2010 Process Hazard Analysis (PHA) but did not implement a PHA recommendation to determine whether buildings at the facility (including their roofs) could withstand damage from hurricane-strength winds.
Emergency Preparedness and Response
Bio-Lab’ response to the event was delayed by approximately 5.5 hours, which likely increased the event’s severity.
Adherence to Applicable Hazardous Materials Codes
The Lake Charles plant did not adhere to the existing National Fire Protection Association’s codes for high-hazard industry occupancies, which include safety precautions such as automatic extinguishing systems or other protections to minimize danger to occupants before they have time to evacuate.
Regulatory Coverage of Reactive Chemical Hazards
TCCA is not covered by OSHA’s PSM standard or the Environmental Protection Agency’s Risk Management Program Rule. Consequently, the facility was not required to implement baseline process safety management elements of its TCCA-related operations under these regulations.
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The CSB is issuing several recommendations to Bio-Lab Lake Charles, including constructing new buildings — and maintaining existing buildings and structures — to withstand hurricane winds and flooding; implementing safeguards and processes to ensure that hazardous chemicals are not released during extreme weather events; improving its process hazard analysis action item management system; performing process hazard analyses on all buildings and units processing or storing TCCA; and improving its emergency response capabilities.
Board Member Sylvia Johnson said, “As severe hurricanes and other weather-related events continue to happen, the CSB calls on industry, state and federal officials, and corporations do their part in developing ways to address these events before they occur. When workplaces are destroyed, that has a direct negative impact on workers’ physical health as well as their ability to earn a living.”
The CSB is also reiterating two recommendations related to reactive chemicals that it previously has made to OSHA and EPA. The CSB is calling on OSHA to amend its PSM regulation to achieve more comprehensive control of reactive hazards, such as TCCA, that could have catastrophic consequences, and is calling on EPA to revise its Accidental Release Prevention Requirements to cover additional reactive hazards that have the potential to seriously impact the public.
Board Member Catherine Sandoval said, “The CSB’s recommendations should serve as a road map for companies, regulators, and industry. The CSB has seen these types of events before, and companies must be prepared for the hazards that extreme weather can present at their facilities utilizing industry resources. Had Bio-Lab followed the available guidance, the incident could have been prevented.”
Additionally, the CSB is recommending that Louisiana officials require chemical facility operators to evaluate the hazards from hurricanes and accompanying wind, rainwater, floodwater, or storm surge forces and implement safeguards against those hazards. The CSB also is urging EPA to implement recommendations made by the U.S. Government Accountability Office to address risks to chemical facilities presented by natural hazards and climate change.
An appendix to the CSB’s report also includes a summary of two additional incidents at another Bio-Lab facility in Conyers, Ga. On Sept. 14, 2020, a TCCA reaction and decomposition resulted in the release of a plume of hazardous chemicals, exposing Bio-Lab Conyers personnel and nine firefighters to dangerous fumes, and caused a portion of Interstate 20 near the facility to be closed for approximately six hours. Surrounding businesses in the area were evacuated. Four days later, a second decomposition involving TCCA occurred with no reported injuries.
The CSB is an independent federal agency charged with investigating incidents and hazards that result, or may result, in the catastrophic release of extremely hazardous substances. The agency’s core mission activities include conducting incident investigations; formulating preventive or mitigative recommendations based on investigation findings and advocating for their implementation; issuing reports containing the findings, conclusions, and recommendations arising from incident investigations; and conducting studies on chemical hazards.
The agency’s board members are appointed by the president subject to Senate confirmation. The Board does not issue citations or fines but makes safety recommendations to companies, industry organizations, labor groups, and regulatory agencies such as OSHA and EPA.
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