better process design, engineering, and hazard analysis would likely have prevented the 2004 runaway chemical reaction and toxic vapor cloud releaseThe plant was starting its first attempt to produce triallyl cyanurate (TAC), a chemical used in rubber manufacturing, faulty procedures produced a runaway reaction, releasing toxic allyl alcohol and allyl chloride into the atmosphere.
More than 200 families were forced to evacuate from their homes and 154 people had to be decontaminated. One MFG worker suffered chemical burns and thirteen police and ambulance personnel were exposed to high concentrations of the vapors and decontaminated.
In addition to the company's failure to follow to take steps that would have controlled the reaction, the report also faulted the city of Dalton and Whitfield Country for inadequate emergency reponse, and found that the state of Georgia was not effectively overseeing emergency response planning.
Inadequate emergency response planning by the City of Dalton and Whitfield County was a contributing cause of the injuries and exposures among the public and responders, the CSB said. None of the responding police officers had the proper training or protective equipment to safely enter the toxic vapor cloud. The city had no automated emergency notification system or evacuation plan, and police officers were instructed to drive into the chemical cloud to alert neighborhood residents to evacuate. After the toxic vapor forced the unprotected police officers to retreat, firefighters wearing special breathing apparatus were eventually called in to complete the evacuation.The CSB issued a major report addressing reactive hazards in 2002. According to CSB chairman Carolyn Merritt,
The report noted that the federal Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 requires the establishment of Local Emergency Planning Committees (LEPCs) throughout the country. Under the statute, LEPCs are responsible for helping develop comprehensive emergency response plans that identify hazardous chemical facilities and describe emergency notification, response, and evacuation procedures. The Board found that the State of Georgia has not defined clear responsibilities for implementing important requirements of EPCRA, and that Whitfield County does not have an LEPC.
As the CSB pointed out in its 2002 study of reactive chemical hazards, these accidents often occur when companies do not effectively research the available literature, conduct thorough process hazard analyses, examine possible accident scenarios, and implement appropriate safety controls. The 2004 accident in Dalton underscores the vital role of communities in preparing for chemical accidents and minimizing the harm to the public. Effective prevention and effective emergency planning go hand-in-hand.
The CSB made a number of recommendations in the 2002 report, incuding a recommendation that OSHA amend the Process Safety Management standard to more effectively address reactive hazards. OSHA has not agreed to modify the standard and in 2004, the CSB notified OSHA that it finds OSHA's response to be "unacceptable." Instead of addressing the problem through the PSM regulation, OSHA has established a reactives Alliance and enhanced its reactive chemicals website.
City of Dalton officials were not pleased with the CSB's MFG report, although they are already taking actions to address some of the problems:
Officials in Dalton took issue with the inclusion of the city’s police and fire response as a contributing cause to the scope of the incident. City Administrator Butch Sanders said the city had done everything it could have done to prepare.Recommendations resulting from the MFG investigation incuded the following:
Money was approved last year for an emergency notification system that would automatically notify residents by phone of any emergencies, according to Dalton Police Lt. Jason Parker. That system could be operational by June, he said.
- MFG Chemical improve its process safety programs and emergency response planning;
- The City of Dalton establish, equip, and train a hazardous materials response team and improve its emergency operations planning and fire and police department procedures and training;
- Whitfield County form a Local Emergency Planning Committee (LEPC);
- The Governor of Georgia clearly designate responsible agencies for implementing federal emergency planning and risk management requirements;
- Lyondell Chemical Co., which supplied MFG with the toxic allyl alcohol, more closely examine the chemical process safety programs of potential new customers;
- The Synthetic Organic Chemical Manufacturers Association (SOCMA), of which MFG Chemical is a member, develop new safety guidance for "tolling" - the practice of contracting out the production of specific chemicals.