On June 25th the Chemical Safety and Hazard Investigation Board (CSB) published an Advance Notice of Proposed Rule Making with the intent to fulfill a legislative requirement levied on the Board during its authorization almost 20 years ago. Comments made in response to this ANPRM may be emailed to anpr@csb.gov; the subject line of the email must include the CSB Docket Number (CSB-09-01). Comments should be submitted prior to August 4^th, 2009.

The ANPRM notes that “the CSB has argued that the sole purpose of a reporting regulation is to inform the CSB of major incidents warranting the deployment of investigators” (74 FR 30260). This seems to ignore the second part of the Board’s mission, making ‘chemical production, processing, handling and storage’ as safe as possible.

It is a well established principal in the chemical process industry that the investigation of ‘near-miss’ incidents can result in identifying steps to be taken to prevent more serious incidents from occurring. If the CSB continues to concentrate their data collection efforts on accidents and incidents resulting in ‘a fatality, serious injury or substantial property damage’, the Board will be hard pressed to identify trends, developments and situations that would be predictive of future serious incidents.

It is true, of course, that the current staffing and funding levels at the CSB already prevent the CSB from conducting active investigations of all chemical incidents that result in ‘a fatality, serious injury, or substantial property damages’. Full-scale investigations of near-miss incidents would be difficult to justify when the Board cannot investigate all chemical releases resulting in deaths.

Statistical analysis of trends, however, could allow the Board to call attention to insipient problems and recommend in-depth research to be conducted by appropriate industry and academic organizations. For example it would seem that the recent spate of news reports about industrial accidents related to low-volume releases of anhydrous ammonia in food processing facilities because of valve or piping failures cries out for investigation of the adequacy of the design, installation and maintenance standards for these types of refrigeration systems.

Investigative Response

Again, a full-scale investigation of one or more of these incidents would be hard to justify under the current funding and staffing constraints placed upon the Board. Assigning an investigator to collect information from local investigative agencies and providing the authority to compel submission of such reports about a class of incidents like this could allow the CSB to define the extent of the problem. Then the Board could suggest detailed research programs for organizations like the Center for Chemical Process Safety (CCPS) or a variety on industry standard setting organizations.

Ideally, the Board should be able to commission its own research from a wide variety of academic institutions. CSB does not currently have any grant making authority that would allow it to fund such research. This is something that the agency should certainly take-up with Congress.

There is an interesting article over on RedOrbit.com. It takes a look at some research being done by the Marine Biological Laboratory (MBL) and Dartmouth Medical School on the health affects of arsenic in drinking water. The researchers, who had been looking at the endocrine effects of drinking arsenic contaminated water, decided to take a look at arsenic’s effects on the progress of flu, the recent strain of H1N1 in particular.

Low levels of arsenic (10 to 100 ppb) are commonly found in drinking water in many parts of the world, including a variety of areas within the United States. The 10 ppb level is considered ‘safe’ by the US EPA, but according to the article, levels as high as 100 ppb and even higher can be found naturally in well water. In the western United States in many areas water with higher concentrations of arsenic are known as ‘sweet water’ or ‘agua dulce’, referring to the sweet taste imparted to the water.

These low doses of arsenic have been generally considered to be sub-clinical, that is of no real concern to doctors; this is because arsenic does not bio-accumulate like most other heavy metal contaminants. These researchers have shown that even in the 10 to 100 ppb range there are measurable, if conflicting, effects on a wide variety of hormone systems.

These researchers have found similar conflicting effects on the progress of the flu infection by these low doses of arsenic. They found, in mice, that in the early stages of the infection low doses of arsenic in drinking water impeded the bodies response to the H1N1 flu virus, making the initial response ‘feeble’. Later the immune response became more aggressive, causing “a massive inflammatory response, which led to bleeding and damage in the lung”.

If the same thing happens in humans, and that has not yet been established, it might explain why some areas see more of a severe problem with this strain of the flu virus. It might lead to additional efforts to remove these relatively low levels of arsenic from the water supply.

Actually it would be kind of ironic. Over the last decade or so there has been a lot of work being done by a number of water activist groups to find cheap and effective methods for removing arsenic from drinking water. There are some areas of the world where the natural levels of arsenic in drinking wells are much higher than 100 ppb. Many of these groups have complained about the level of financial support they have been able to get for their research. Now the results of that research may benefit people in developed countries like the United States.

I found a copy of an AP news story on Examiner.com this weekend about a case of H1N1 flu at the Rikers Island jail in the Queens, NY. While the report only notes a single case has been detected, it does explain that the inmate in question had been in the facility for about a month. Unless he has had close personal contact with someone from outside of the facility, someone within the facility, either another inmate or a member of the jail staff, infected the individual.

If you think about it, a large jail like Rikers Island is an ideal facility for spreading a disease like the flu. Personal hygiene is less than rigorous with few opportunities for frequent hand washing or sanitizing. Coughing and sneezing are associated with many diseases and medical conditions that are endemic in many of the populations over represented in jails and those same conditions lower natural immunity. Finally, the fact that people can spread the flu before they show symptoms guarantee that there will be multiple exposures before the facility management is aware that it has a problem.

While many people will have little sympathy for the inmates at such facilities and most cases to date have been relatively mild, there should be a community concern for the spread of potentially serious pandemic diseases in such facilities. These facilities can act as a reservoir for these diseases, exiting the facility with released inmates, visitors and staff. A close watch needs to be maintained at these facilities and quick prophylactic treatments with anti-viral medications needs to be used to prevent the spread of the disease.

For about the last year now I have been receiving emailed articles from StratFor.com about important global political issues. They have a knack for delving into the source issues of a wide variety of topics that are only indifferently covered in normal news outlets. Earlier this week I received a report on the geopolitics of pandemics. It was a very good discussion of the root causes of the recent flu outbreak.

What was most interesting was their final analysis of the real potential harm of a truly deadly flu pandemic; a large number of dead people, but life and society would go on as they had before. And the actual number of dead people would probably be less than the infamous 1918 pandemic because of general advances in medical science. Then they casually dropped the ‘oh, by the way’ bomb:

“However, should a disease arise that is as deadly as HIV, that spreads through casual contact, about which there is little knowledge and for which there is no cure, the medical capabilities of humanity would be virtually useless.”

If we think back to the beginning of the Aids Epidemic, it was a mysterious disease. Actually the term Aids (Acquired Immune Deficiency) was more a description of the symptoms of the disease rather than the cause of the disease. It took a long time for the medical community to identify the actual virus that caused the disease and even longer to get a consensus in the medical community that the identified virus actually caused the disease.

Fortunately for humanity, if not for those infected, HIV is actually a relatively difficult virus to spread. It does not survive long outside of the human body, so you have to have an actual exchange of significant quantities of bodily fluids to transfer the disease. Now that medical transmission of the disease through blood transfusions has been almost eliminated, the only significant source of transmission is through sex. A faithful monogamous relationship provides virtual protection from the virus.

Flu, on the other hand, is very easy to spread. Flu viruses can live on survive for significant periods of time on surfaces not exposed to direct sunlight. The body sheds live virus through coughing, sneezing, and mucal membrane leaking (sniffles). Contact with any of these discharges, even minute amounts found in the fine spray from coughing or sneezing, provides a route for disease transmission as long as the virus particles are introduced into the mouth, nose or eyes. What’s worse is that people can shed virus particles before they exhibit symptoms of the disease and after they are apparently recovered from the disease.

If a new virus were to come along (and new viruses come along frequently) that survived as well outside the body as the flu, but were as deadly as AIDS there would be a serious problem. First off, the virus would have to be isolated and identified. Existing anti-viral medications would be tried, but it is unlikely that a uniquely new virus (like the HIV was uniquely new) would respond to existing medications. It would take 10 to 20 years to develop a safe and somewhat effective medicating scheme, if AIDS is a decent example of how the process would proceed.

The effects on society would depend on a number of factors. By definition an easily transmissible virus has a high infection rate. Without previous exposure to the virus or a viable vaccine (and we are just now starting to test vaccines for HIV) the only way to prevent the spread of the virus is to isolate those people that are infected from those that are not. If an infected person starts to shed virus before symptoms appear (as in both HIV and flu) isolation of infected patients is ineffective. The only effective method to prevent the spread would be to isolate the uninfected. This is essentially what Mexico tried to do over the last week.

The next factor to consider would be the death rate. A highly transmissible virus with a high death rate could devastate modern society. Extremely high death rates like those seen with the Ebola virus would completely destroy civilization if the virus was highly transmissible and shed before symptoms like the flu. Catastrophic affects on society would be felt at much lower death rates. Even combined infection/death rates as low as 10% (10% of the population dead from the virus) could destroy modern society because of the cascading effects on critical services. This is especially true if significant portions of the society self-isolated to prevent becoming infected.

Another factor to consider would be the degree and duration of the disability during the illness. If large portions of the population required extensive medical care, this could severely disrupt society even if the death rate is relatively low. Not only would hospital services be quickly overwhelmed, but there would be a severe shortage of trained medical personnel. At some point the shortage of trained personnel, equipment and medications will lead to an unavoidable increase in the death rate.

With all of these considerations in their minds, it is no wonder that public officials in the US initially took actions like closing schools and making extensive efforts to inform people how to avoid contracting the swine/H1N1 flue. In hind sight it currently looks like many of their actions were an over reaction. In the long run, however, over reaction is much better than a failure to act. Early actions to limit the spread of a potentially pandemic infection may be the only efforts that can make a difference.

There is a brief article on the WOWKTv.com web site about a potential RCRA (pronounced REC-RA; the federal Resource Conservation and Recovery Act) violation involved in the Bayer CropScience explosion. I say ‘potential’ violation because there is a disagreement on the issue. The West Virginia Department of Environmental Protection (WVDEP) says that the facility did not have a hazardous waste permit for the operation that was taking place in the tank that exploded in last year’s fatal accident. Bayer says that a permit was not required since there was no hazwaste treatment involved in the operation.

This is one of the grey areas in EPA regulations that have plagued chemical companies since the rules were first put into place. The RCRA regulations establish the rules for handling, shipping and disposing of hazardous waste. One of the key components of those regulations is that only a permitted facility may dispose of or destroy hazardous waste. This ensures that the permitting agency, normally the US EPA or an EPA approved state agency, knows who is handling hazardous wastes. This should enable regulators to ensure hazwaste handlers are taking appropriate precautions and handling hazwaste in ways that protect the environment.

Neutralization vs Waste Treatment

The loophole in the law is the provision that chemical manufacturers are allowed to ‘neutralize’ byproduct streams from their manufacturing process as long as that neutralization is an integral part of the manufacturing process. What is meant by ‘neutralize’ is very broadly defined in the regulations. Most observers believe that this was designed to allow simple chemical neutralizations like pH adjustments, but the broad definition provides wiggle room for a number of operations.

In the Bayer CropScience case their manufacturing process produced a byproduct that consisted of a solvent contaminated with methyl isocyanate (MIC). Now the solvent stream would probably be hazwaste in its own right because of its flammability; it would be disposed of in some sort of incinerator or cement kiln operation. Both of these are relatively inexpensive hazwaste disposal options. Without the MIC contaminant it might even be re-useable or recyclable back into the original process.

The presence of MIC changes things. MIC is both toxic and reactive. A number of additional precautions would have to be taken to safely handle and dispose of the MIC contaminated solvent. It would also require special handling at the Bayer facility and specialized hazmat shipping requirements. All of this would increase the disposal cost; the higher the MIC concentration the higher the additional cost.

What Bayer has apparently opted to do is to ‘neutralize’ the MIC contaminant by heating the solvent-MIC mixture to above the decomposition temperature of the MIC. The MIC decomposes into a variety of less hazardous byproducts and the disposal risk/cost is lowered. It is even possible that the resulting solvent is ‘clean’ enough to be recycled back into the process stream, eliminating the hazwaste and further reducing costs.

Legal Arguments

What the WVDEP is arguing in this case is that the MIC decomposition process goes beyond the description of ‘neutralizing’ found in RCRA. Thus it becomes hazwaste treatment and requires permitting. Bayer will maintain that the neutralization takes place in equipment that is contiguous with the rest of the manufacturing process and thus falls within the RCRA description of ‘neutralizing’.

There is one telling argument that might be employed by WVDEP in this case. They might be able to better argue that the unusually high concentration of MIC in the process equipment that led to the runaway reaction resulted in a fundamental change in their process and procedures. They could argue that the higher concentration would be too large for a reasonable person to maintain that Bayer was simply neutralizing the solvent solution.

In any case, if the US EPA or the WVDEP decide to cite Bayer for a RCRA violation, there will certainly be a long drawn out court case to resolve the issue. Bayer CropScience has too much invested in the facility to allow the decision to be made by administrative fiat. There would also be liability ramifications if the two deaths that occurred were determined to have resulted from illegal acts. It will take quite some time to resolve this issue.

For those of you who are looking for a single location to find up to date information on the current Swine Flu Pandemic, I have found the site. It is the Pandemic Flu Web Portal run by the Texas A&M University Integrative Center for Homeland Security. The site has news links, resource links, and personal protection links. It is the one-stop-shop for swine flu information. I am adding it to my daily web search list.

With the current ‘swine flu outbreak’ only days old, it is too early to responsibly predict anything about the course of this disease except that we will be hearing and seeing lots of news on this story. Today, MSNBC.com titled their mid-day lead story as “U.S. swine flu cases climb to 40”. Earlier reports set the number at 20. In any case the number is sure to rise.

Early Information

The early news reports all seem to agree that this is another new version of the standard flu virus. It contains genetic material from swine, avian, and human strains. It is unique enough that any previous flu exposure is unlikely to provide a workable immune response to this H1N1 strain. This means that there will be few natural inhibitions to the spread of this strain and current vaccines will be of little use.

The death rate appears to be relatively low early in the epidemic. Results out of Mexico appear to show a 1% fatality rate; ‘appear’ is the operative word here. It is too early in the outbreak for anyone to have a good idea of how many people have actually been infected to date. There may be a significant number of illnesses that were not reported earlier in the disease cycle because they were not recognized as a unique flu strain.

It is clear that the disease is transmittable between humans. None of the cases in the US have had any exposure to live swine, nor have many of the cases in Mexico. This is what is causing so much concern. An easily transmissible form of the flu for which there is no natural/vaccine immunity in the population means that this has the potential to spread quickly, affecting large portions of the population.

The one bit of good news is that this outbreak is starting at the end of what is normally considered the ‘flu season’. The flu is typically a winter time, indoor season disease. This is because most people are inside for large portions of the day, allowing for the best transmission conditions. Going into the middle of spring and start of summer, more people are spending more time outside in the sunlight. UV radiation from the sun will kill most viruses on exposed surfaces, reducing the transmissibility.

Why the Concern?

The combination of a flu bug that is transmissible between humans and the lack of inherent disease response means that this swine flu variant has the potential to infect large portions of the world population. The speed with which it has already spread from Mexico to the US is a good example.

People are typically able to ‘shed’ the flu virus before they show serious symptoms or feel ill. This means that a person in the early stages of the infection does not feel the need to take precautions to prevent spreading the virus; nor do casual passersby see the need to protect themselves from the individual shedding the virus. Short of complete quarantines, it is extremely difficult to stop the spread of the virus.

The apparent low death rate is still high enough to be of concern because of the potentially huge number of people that will come down with the virus. Even if the 1% number holds up under close scrutiny, if 100 million people become infected (an easily achievable number globally), that means that there will be 1 million deaths.

Even with this relatively low death rate, this disease has the potential to seriously disrupt the world’s already fragile economy. First off the health care system is not adequately equipped to deal with the number of patients that could be demanding treatment for this disease. A large swath of the labor force could be out of work for extended periods of time, further disrupting an already damaged economy.

Finally, in today’s world political climate, there will inevitably be questions raised about the origin of the disease; asking if the unique genetic make-up of the virus was a natural occurrence or the result of genetic manipulation in a weapons lab. Already one reputable journalist is asking if this might not be a bio-weapon being used by the Mexican drug cartels.

Unfortunately, we will only be able to find the answers to these questions in time. While the doctors and researchers work hard to find the information necessary to protect us, we can only sit and wait for the answers. In the mean time we can wash our hands, avoid crowds of people, and worry about every sniffle, sneeze, and cough.

Jacksonville to Become Commercial Space Flight Center

Earlier this week the Federal Aviation Administration (FAA) published a notice in the Federal register that they were beginning an environmental assessment (EA) for issuing a Launch Site Operator License at Cecil Field, Jacksonville, Florida. This is one of the initial steps in establishing a commercial space port for suborbital manned reusable launch vehicles (RLVs).

Copies of the draft EA can be found in public libraries in Jacksonville, FL and public comments must be submitted by May 20^th, 2009. A public meeting will be held on the evening of May 14^th at the Cecil Commerce Center in Jacksonville. The FAA will provide information on the Draft EA and describe the licensing process. Written and oral public comments will be accepted.

Only horizontal take off and landing operations are being considered for this facility. The type of sub-orbital craft utilizing the Jacksonville Aviation Authority (JAA) Launch Site would be similar to the type developed by Burt Rutan for Virgin Airways. Take offs would be made using conventional jet engines. Rocket engines would only be ignited in a designated off-shore area and landings would be un-powered. No new major facilities are currently being planned for the existing Cecil Field operations.

NOTE: I have a special interest in this as I was born at the Jacksonville NAS hospital a year or two ago.

Last week the town of St Charles, MN was empty except for fire fighters and other emergency response personnel for almost a full day. The local food processing plant was on fire and emergency personnel were afraid that the anhydrous ammonia storage tanks would explode. While concerted efforts were made to protect the tanks, the town of almost 4,000 people was evacuated.

Anhydrous Ammonia

Anhydrous ammonia is used in many food processing facilities as a heat-transfer fluid in the refrigeration systems. It is ideally suited for this use because of the low boiling point and low cost. As the liquid flows through the cooling system it picks up the heat from the system and turns into a gas. The gas moves back into the condenser where it is compressed back into a liquid to be fed back into the system.

These physical characteristics are also what make anhydrous ammonia and other refrigeration liquids so dangerous in a fire. Stored in pressure tanks as a liquid the material can be converted back to a gas by the heat of a fire near the tank. The conversion from liquid to gas soon increases the pressure to the point where the tank can no longer contain the pressures. The result is what the press calls an explosion, but what people in the industry call a pressure event because the expanding gasses are not burning. In any case the result is a catastrophic release of pressure with pieces of flying metal leaving the area at high speed.

Anhydrous ammonia has the additional problem is that the gas is a toxic inhalation hazard (TIH) chemical. This means that at relatively low concentrations the gas can kill people who breathe the contaminated air. At lower concentrations there are a number of other less than lethal medical effects from exposure to the chemical including chemical burns of the skin, eyes and mucous membranes and even temporary blindness.

Process Safety

Working in chemical plants I have taken part in process safety reviews for chemicals with comparable physical characteristics. Both OSHA and EPA regulations require that any chemical stored in a sealed tank is protected by a venting system that will prevent a catastrophic failure of the tank. This is typically accomplished by placing a pressure relief valve (PRV) on the tank. These valves automatically open when a preset pressure is reached, releasing material from the tank.

When a toxic chemical is involved, the vent line leading from the PRV is not allowed to go directly to the atmosphere. Instead it goes to some sort of system that either collects or destroys the hazardous chemicals. For anhydrous ammonia the typical system is a water scrubber. The vented gas is bubbled through a water solution where it is chemically converted to either aqueous ammonia or an ammonia salt. In either case the material is no longer a TIH chemical.

The size of the PRV, the size of the vent line and the size of the scrubber system are all carefully calculated. The size is very dependant on the amount of heat that one expects to be put into the system. In a chemical manufacturing vessel we calculate the maximum amount of heat that can be produced by the reaction and size accordingly. In a storage situation you look at the maximum amount of temperature change that can be expected in the vicinity of the tank.

The problem is that a fire directly adjacent to the storage tank is the worst possible case one can have for calculating the size of a relief system. For pressure tanks holding toxic chemicals it is impractical to design a system large enough for the ‘fire case’; adequately sized vents would quickly overwhelm a reasonable chemical destruction/adsorbtion system. Instead the normal safety response is to design the system so that it is not possible to have a fire that ‘impinges’ on the tank. This is done by keeping all combustible materials away from the tank and providing a water deluge system to keep the tank adequately cooled in the event of a nearby facility fire.

No Explosion in St. Charles

The five storage tanks at the St Charles, MN fire were still intact at the end of the fire. This was due to the efforts of the fire crews to keep water hoses trained on the tanks while the remaining facility fire was dealt with. Meanwhile, there were small controlled releases of anhydrous ammonia to the atmosphere. These releases reduced pressure in the tanks while ensuring that atmospheric concentrations of the chemical outside of the facility did not reach dangerous levels. These combined actions, along with the evacuation, ensured that no one was seriously injured in a potentially deadly situation.