“More often than not, to blame someone else is to play ‘hot potato’ with something that’s neither hot nor a potato.”  — Craig D. Lounsbrough

Imagine you work at a plant that makes a polymer. One of the raw materials is the monomer and it is toxic, reactive, and flammable. It contains an inhibitor to keep it from reacting prematurely.

Now imagine that a truckload arrives at your plant for delivery. Your procedure for receiving loads requires that the QC department check the certificate of analysis and that the unloader checks the temperature of the load. If the temperature is too high, your procedure is to reject the load and send it back to the shipper.

Then while the QC department is reviewing the certificate of analysis, the unloader checks the temperature.  It is one degree below the rejection temperature.

The QC department completes its review during shift change. Not realizing that the temperature has already been checked, the unloader on the new shift checks it again. It is three degrees over the rejection temperature. Per procedure, the unloader tells the driver that he has to reject the load and send it back.

The driver protests. Either one of the temperatures is wrong or the temperature has climbed four degrees in a half hour.

Now what?

Accept the Load?

If the material was already being unloaded when the increasing temperature was discovered, the plant would rely on the protection on the monomer storage tank. Applied cooling, addition of quench agent, evacuation from the vicinity of the storage tank. But what about the material still in the tank truck? Send it away and let the driver deal with it?

If unloading hadn’t started yet, there is no question that it shouldn’t start. But what to do with the load?

Send it Away and Let the Driver Deal with It?

Sending the truck away would get it out of the plant. Would that absolve the plant of responsibility for what happened to the truck while it was out on the highway, or parked at a truck stop? I don’t know; that’s a question for lawyers, judges, and juries. But the driver would know that there was something seriously wrong. Ethically, morally, should the plant send the driver to his fate?

And what is the driver going to do? Drive down a busy highway hauling a ticking time bomb. Pull into a truck stop, a rest stop, or a parking lot and walk away from the truck? Call dispatch or the highway patrol and ask for guidance?

Deal With It at the Plant?

Whatever happens with the load, the sooner it is dealt with the better. Is there anything that could be done at the plant? Apply external cooling? Park in a remote corner of the plant? Add inhibitor or some kind of neutralizing agent? Discharge the contents of the tank truck to the ground so its impact will be less severe?

All of these options pose some liability for the consequences on the plant. Are they less than the other consequences? Do they relieve the supplier of any responsibility? The trucking firm?

The Aftermath

If the emergency turns out badly, there will be lots of time for a post-mortem. The public will weigh in, armchair experts will share their opinions, and most importantly, lawyers, judges and juries will decide what should have happened. They will assign blame, which unfortunately will do little to prevent a reoccurrence.

Plan For Emergencies

The time to plan for emergencies is before the emergency, in the calm, cool light of day. Not during the emergency. It’s true, Dwight D. Eisenhower said, “Plans are worthless,” but he added, “but planning is everything.” Any incident, choices will be made by people forced to make them. Even the choice to do nothing and just let things play out is a choice. In the course of planning, questions can be asked and as much time as necessary utilized to develop an answer to those questions taken by the people most qualified to answer the questions. If we wait for the emergency to begin asking the questions, the answers we come up with during the incident are not likely to be the ones that survive the scrutiny of an incident investigation.

Author

  • Mike Schmidt

    With a career in the CPI that began in 1977 with Union Carbide, Mike was profoundly impacted by the 1984 tragedy in Bhopal and has been working on process safety ever since.

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