Be Aware of Dangers
26 ASK THE FACILITIES GUY
Richard Bilodeau, PE
Director of Engineering, SMRT
The residents of Bhopal, India will never forget early December, 1984 when a cloud of methyl isocyanate (MIC) gas seeped from the Union Carbide chemical plant. The government pegs the immediate death toll at
3,787, with more than 500,000 injured, disrupting health, the
community, and the economy for decades. It’s estimated 8,000
died within two weeks, while another 8,000 deaths followed later
from related diseases. The Indian government estimates almost
4,000 of those injured struggle with permanent disabilities.
What was behind this mass disaster? The list of contributing causes reads like a course book in Facilities Negligence
101: non-functioning safety systems and vent gas scrubbers, an
out-of-order steam boiler that cleaned pipes, MIC stored tanks
filled well above regulated levels, and corroding non-stainless
steel pipelines producing rust that, in the end, only accelerated the toxic reaction. Bottom line: a side pipe missing its
slip-blind plate allowed water to enter a tank overfilled with
42-tons of MIC, creating a chain reaction. Inside an hour, 30
metric tons of MIC escaped into the atmosphere.
For a controlled environments facilities engineer, hazardous production materials are not the things that dreams are
made of—but proper regulatory compliance and handling
during the production process are cornerstones of the job.
HPM management—and the plant maintenance that supports HPM—require constant attention.
The International Code Council (ICC) defines hazardous
production materials as, “A solid, liquid or gas that has a
degree of hazard rating in health, flammability or reactivity
of Class 3 or 4 as ranked by NFPA 704 listed in Chapter 44
and which is utilized directly in research, laboratory or pro-
duction processes that have, as their end product, materials
that are not hazardous.”
The responsibilities of the facilities engineer regarding HPM
extend from materials ordering and storage through internal
distribution, manufacture, disposal, and reporting. HPMs
are among the most highly regulated substances in the world,
with Federal, state, and local regulations producing a puzzle of
ever-changing and sometimes conflicting requirements.
Depending on your organizational structure, the facilities group may be responsible for the complete range of
HPM management, or the responsibilities may be segregated
between procurement, purchasing, legal, health & safety,
manufacturing, and facilities. While segregating responsibilities can ensure that highly focused specialists are in control
of the HPMs throughout the chain of use, it’s critical that
seamless and constant attention be given to coordination
between the individuals along the chain of responsibility.
Some key considerations
The role and proper handling of HPMs are among the most
complex challenges any facilities engineer will face—and
failure to properly execute can result in injury, death, your
organization’s loss of reputation, tremendous financial loss
and, if a publicly traded company, a black mark on the organization’s reputation that is impossible to recover from.
There is no clear cut “recipe for success” when dealing
with HPMs, but here are a few rules for the road gleaned
from my experiences handling these substances both as a
facilities engineer in manufacturing and as a consulting engineer at SMRT Architects and Engineers:
1. Regulations rule
The world of HPM is governed by rules that are complicated, convoluted, and constantly changing. And if your facilities exist in different cities, states, or countries, you should
expect different regulatory requirements for each facility.
Regulations cover every aspect of HPM usage, from limitations placed on quantities that can be ordered by your
purchasing group to disposal. Regulations will vary for different chemicals, and also floor-by-floor for the same chemical depending on whether its storage and/or use will take
place on the ground floor or three stories up. Regulations
will vary depending upon the manufacturing process.
It may feel like there are more regulations for HPMs than
stars in the universe, but there are compelling reasons for
this: Hazardous Production Materials kill. Pay attention.
2. What you know is true today, won’t be true tomorrow
As new production processes are developed, new pro-
Could you provide some thoughts
on Hazardous Production Materials
“Our technological powers increase,
but the side effects and potential
hazards also escalate.”
Hazardous gas and
from storage bunkers
to cleanroom process