Safety Alerts, Recommendations In Wake of Crude Oil Rail Accidents

Source: BakerHostetler via Mondaq | 14 March 2014

Recent accidents involving rail cars transporting crude oil from the Bakken shale region have resulted in the heightened interest of rail industry regulators and other federal agencies, including the Pipeline and Hazardous Material Safety Administration (PHMSA), the Federal Railroad Administration (FRA), and the National Transportation Safety Board (NTSB). In January 2014 alone, PHMSA issued a safety alert addressing the flammability characteristics of crude oil originating from the Bakken shale formations and the NTSB issued two letters containing safety recommendations to both FRA and PHMSA.

The PHMSA safety alert and NTSB’s safety recommendations arrived on the heels of (a) FRA’s 2 August 2013 Emergency Order 28, which addresses safety issues related to unattended rail cars carrying Bakken crude oil; (b) FRA and PHMSA’s 2 August 2013 joint safety advisory 2013-06, which contains additional recommendations for railroads and shippers to implement improved safety measures for the transport of Bakken crude oil; and (c) FRA and PHSMA’s second joint safety advisory, published on 20 November 2013, which discusses the importance of proper characterization, classification, and selection of a packing group for Class 3 materials and the corresponding requirements in the Federal hazardous materials regulations for safety and security planning.

The purpose of this article is thus threefold: first, to examine the impetus underlying industry regulator’s piqued interest in the transport of Bakken crude oil and describe the factual background surrounding recent rail incidents (for the purpose of placing NTSB, FRA, and PHMSA’s safety-related communications in context); second, to summarize the NTSB’s recent, though nonbinding, recommendations to FRA and PHMSA; and third, to summarize the recent safety alert issued by PHMSA in January 2014 as well as similar safety alerts that predate it.

Column: Systems Thinking Can Help Get to the Root of Accidents

Source: Chemical Processing | 6 March 2014

An often-claimed “fact” is that operators or maintenance workers cause 70–90% of accidents. It is certainly true that operators are blamed for 70–90%. Are we limiting what we learn from accident investigations by limiting the scope of the inquiry? By applying systems thinking to process safety, we may enhance what we learn from accidents and incidents and, in the long run, prevent more of them.

Systems thinking is an approach to problem solving that suggests the behavior of a system’s components only can be understood by examining the context in which that behavior occurs. Viewing operator behavior in isolation from the surrounding system prevents full understanding of why an accident occurred—and thus the opportunity to learn from it.

We do not want to depend upon simply learning from the past to improve safety. Yet learning as much as possible from adverse events is an important tool in the safety engineering tool kit. Unfortunately, too narrow a perspective in accident and incident investigation often destroys the opportunity to improve and learn. At times, some causes are identified but not recorded because of filtering and subjectivity in accident reports, frequently for reasons involving organizational politics. In other cases, the fault lies in our approach to pinpointing causes, including root cause seduction and oversimplification, focusing on blame, and hindsight bias.

Newspaper Investigation Questions Oilfield Safety

Source: Washington Post | 3 March 2014

Injury claims, government data, and public records of oilfield accidents since the start of the onshore drilling and hydraulic fracturing boom in 2007 show the federal government failed to implement safety standards and procedures, according to a Houston Chronicle investigation.

The examination also shows a lack of government inspections and shoddy practices by many oil and gas companies. The newspaper says the result is a toll of badly injured or killed workers.

Texas accounted for about 40% of the 663 workers the US Bureau of Labor Statistics said were killed nationwide in oilfield-related industries between 2007 and 2012, the Houston Chronicle reported.

In 2012 alone, the newspaper found 79 people lost limbs, 82 were crushed, 92 suffered burns, and 675 broke bones in work-related accidents reported to insurance carriers. The same year, the 65 deaths were a 10-year high and almost 60% more fatalities than in 2011.

Railroads, Transportation Department Agree on Measures To Make Crude Shipments Safer

Source: Platts | 24 February 2014

US railroads on 21 February announced several voluntary steps they will take to boost crude-by-rail safety, including lower speed limits in urban areas and the use of rail traffic routing technology, under an agreement reached with the US Department of Transportation.

The Association of American Railroads said that, beginning 1July, trains with 20 or more tank cars carrying crude that include at least one older DOT-111 car will travel no faster than 40 mph in 46 federally designated high-threat urban areas.

The industry currently voluntarily restricts speeds of trains with 20 or more carloads of hazardous materials, including crude oil, to 50 mph.

Railroads will also begin using the Rail Corridor Risk Management System (RCRMS) to determine the safest routes for trains with 20 or more cars of crude. RCRMS, developed with the US Homeland Security Department and other federal agencies, is currently used for the routing of security-sensitive materials.

Oil & Gas UK Welcomes Helicopter Safety Report

Source: Rigzone | 20 February 2014

Industry body Oil & Gas UK has welcomed recommendations made by the UK’s Civil Aviation Authority (CAA) as part of the organization’s safety review of offshore public transport helicopter operations in support of oil and gas recovery.

The CAA announced on 20 February a series of measures designed to increase the safety of offshore helicopter flights. The changes are the result of what the organization described as “a comprehensive review of offshore helicopter operations” undertaken in conjunction with the Norwegian CAA and the European Aviation Safety Agency (EASA). The review followed a series of helicopter ditchings in the UK North Sea in recent years, including last August’s fatal incident involving a Super Puma in which four offshore workers died.

Exxon Awards First License for Remote Gas Leak Detection System

Source: OilVoice | 19 February 2014

ExxonMobil Upstream Research Company has awarded the first commercial license for its InteliRed remote gas detection system to codeveloper Providence Photonics.

The InteliRed system is designed to improve process safety and environmental performance at oil refineries, chemical plants, liquefied natural gas (LNG) facilities and other gas-processing facilities. The system employs a specially developed computer algorithm to analyze infrared camera images autonomously to detect escaping hydrocarbon gases. The InteliRed system provides an early warning alert of hydrocarbon leaks with minimal false alarms.

Providence Photonics is an affiliate of Providence Engineering headquartered in Baton Rouge, Louisiana. ExxonMobil and Providence scientists codeveloped the InteliRed system over a 4-year period culminating in field tests of the system that began last year at an LNG liquefaction plant in Qatar.


Using Smart Field Devices To Improve Safety System Performance

Source: International Society of Automation | 11 February 2014

Safety monitoring software can use data from smart field devices to improve safety system performance and operation.

  • Many process plants have smart sensors, instruments, and valves installed as part of their safety systems.
  • These smart field devices can provide a host of useful information to the safety system.
  • Safety monitoring software helps make sense of the information from smart field devices by turning their raw data into actionable information.

Any process plant that handles products, feedstock, or fuels that are the least bit hazardous (flammable, toxic, or otherwise environmentally dangerous) has safety concerns. Operating in compliance with regulations and standards is a way of life for oil, gas, petrochemical, biofuel, and many commodity chemical producers. But beyond compliance, companies want and need to protect their people, equipment, and the surrounding environment.

Applicable standards include ANSI/ISA-84.00.01-2004 Parts 1–3 (IEC 61511 Mod) and IEC 61508, along with facility-recognized best procedures and practices. Compliance with these standards ensures that the plant is not simply within the letter of the law; it helps the plant operate with minimal potential for incidents and injuries.

Undertaking this effort begins with plant hazard and operability studies and the layer of protection analysis (LOPA) methodology. Some situations may call for a quantitative risk analysis, as provided by the Center for Chemical Process Safety and indicated by ANSI/ISA-84.00.01-2004 Part 3, Appendix F.

Performing a LOPA helps identify which identified hazards require safety instrumented functions (SIFs) and the required probability of failure on demand for each to lower the risk to a tolerable level. Performing a LOPA is a main step toward ensuring that requirements under ANSI/ISA-84.00.01-2004 Parts 1–3 (IEC 61511 Mod) are met.

Once the safety instrumented system (SIS) is designed and implemented according to the safety requirement specification, its operation must be maintained and monitored to ensure integrity of the SIF and to ensure ongoing compliance with standards. Any changes to the hardware, such as new equipment, new field devices, different products, or different specified operations and processes must be taken into account using a management of change procedure. Any malfunctions or other process issues must also be accounted for, typically by proof testing and monitoring the SIS along with its associated field devices, such as sensors, instruments, valves, and logic solvers.


Report Claims Oil Trains Could Cause More Deaths Without Keystone

Source: Reuters | 4 February 2014

Replacing the Keystone XL pipeline with oil-laden freight trains from Canada may result in an average of six additional rail-related deaths per year, according to a US State Department report that is adding to pressure for President Barack Obama to approve the line.

The long-awaited study, released on 31 January, focused on the environmental impact of TransCanada’s USD-5.4-billion pipeline but also spent several pages analyzing the potential human impact of various ways to transport oil, using historical injury and fatality statistics for railways and oil pipelines.

Although it excluded the runaway oil train derailment that killed 47 people in Lac Megantic, Quebec, last summer, the tragedy that first shone a critical light on the rapidly expanding trend in shipping crude by rail, the findings highlight the risks or railway transport vs. pipes.

Shipping another 830,000 B/D of crude “would result in an estimated 49 additional injuries and six additional fatalities for the No Action rail scenarios compared to one additional injury and no fatalities” per year if Keystone XL is built, according to the report.

Keystone XL would carry 830,000 B/D from Alberta’s oil sands to US refiners but has been awaiting a presidential permit for more than 5 years. The “No Action” options refer to the likely alternative outcomes if Obama rejects the permit or the project is not built for some other reason.

The report also showed that carrying crude by rail, instead of by pipeline, was likely to result in a higher number of oil spills and a larger amount of leakage over time.

Column: What Is Blocking Your Safety Communication?

Source: Workplace Communicator Blog | 28 January 2014

One of the major frustrations of being a safety leader is that it is often difficult to get your safety messages understood and acted upon correctly.

It can be very challenging when you have language and geography barriers, age differences, and people just not listening because they suffer from the highly contagious “it won”t happen to me” bias or “I’ve heard this all before” contagion.

Then, there is the issue of trying to get people to listen to what is said, not what they think is being said. So often, safety professionals feel so frustrated that their safety messages are being misinterpreted. Being able to create the right safety message that gets attention, that people can understand, remember, and then take the right action upon is crucial for successful safety leadership.

So what can you do to remove safety blocks that people put up to resist safety messaging?

Column: The Third Law and Perfect Safety

Source: The PSM Report | 22 January 2014

The Third Law of Thermodynamics states that it is impossible for any system to reduce its entropy to zero in a finite number of operations. A safety incident is an example of a system that is not in a zero entropy state—i.e., one that is not perfectly ordered. And it makes sense. No person is perfect, no organization is perfect. No matter how much time, effort, money and goodwill we spend on improving safety, incidents will occur. We live in the real world of Aristotle and Augustine—not that of Plato and his ideal forms.

Looked at in this light, perfect safety can never happen. Nevertheless, we should strive toward it because, otherwise, we accept that people will be injured—which is something that none of us want or accept and we certainly do not want to quantify.

Federal Board Rejects Safety Recommendations Stemming From Chevron Refinery Fire

Source: San Jose Mercury News | 22 January 2014

In a move described by agency officials as highly unusual, a divided US Chemical Safety Board refused to endorse the centerpiece recommendation from its staff’s 115-page report on the massive Chevron refinery fire in 2012.

At the heart of the split, made public in a packed Richmond City Council chamber, was whether the system for regulating oil refineries should be overhauled to mirror the European model that focuses on continually reducing accident risks, as proposed in the staff report, or whether more emphasis should be placed on strengthening the current oversight system.

The safety board recommendation, which would force the industry to demonstrate that it is operating as safely as possible through written reports reviewed by regulators, has come under fire from industry, the scientific community, and labor and political interests. Many of the concerns center on whether the so-called safety case regime would add unnecessary costs, complexity, and uncertainty to the monitoring of oil refineries and detract from efforts to enhance local and state laws and resources.

“There may be more immediate benefits from beefing up the current system,” said Kim Nibarger, a health and safety specialist for the United Steelworkers. “We don’t want the perfect to be the enemy of the good.”

Officials Call for More Regulations To Prevent Crude Train Accidents

Source: Rigzone | 22 January 2014

US government officials say the series of accidents over the past year involving railcars carrying crude oil highlights the need for greater regulations of crude transportation on railways and more pipeline infrastructure.

US Sen. John Hoeven (R-North Dakota) told Platts Energy Week on 12 January that more pipelines to move Bakken oil from North Dakota to refineries are needed to ease safety concerns after the 30 December rail accident near Casselton in eastern North Dakota, where a BNSF Railway train carrying crude collided with another train, setting off an explosion and fire that prompted the evacuation of 1,400 local residents.

On 13 January, the National Transportation and Safety Board (NTSB) reported that 18 of the 20 tank cars that derailed were punctured and more than 400,000 gallons of crude oil were estimated to have been released. Damage resulting from the accident is estimated at USD 6.1 million.