Planning for emergencies—lessons from the chemical industry

Planning for emergencies—lessons from the chemical industry

Long Range Planning, Vol. 22, No. Printed in Great Britain 1, pp. 83 to 89, 1989 0024-6301/89 $3.00 + .OO Pergamon Press plc 83 Planning for Emerg...

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Long Range Planning, Vol. 22, No. Printed in Great Britain

1, pp. 83 to 89, 1989

0024-6301/89 $3.00 + .OO Pergamon Press plc

83

Planning for Emergencies Lessons From the Chemical Industry Om P. Kharbanda

and Ernest A. Stallworthy

Safety, an area of crucialand overriding importance in industry, is a concept covering hazard identification, risk assessment The problem of awareness of risk can and accident prevention. be seen as one of failure of communication and of mismanagement. It is fundamental that for the avoidance of risk, the risk must first be known. Then its significance must be determined. The expert may seek to quantify it, but the public perception of risk is highly subjective and has nothing to do with statistics. This introduces a communication gap which should be closed. Communication becomes crucial when planning for emergencies. This has two main areas of responsibility.. planning within the plant or industrial complex, developed by the companies themselves, and emergency planning for the locality, developed by the authorities in cooperation with the manufacturers concerned. Typical internal emergency planning arrangements are described and emergency plans for the community at large, and the need to be prepared for the unforeseen are discussed in the light of the U.S. Environmental Agency’s Chemical Emergency Preparedness Plan.

We all face risks and hazards all the time. There are risks in the home, on the roads, around the shops and in the factory. In our book Safety in the Chemical Industry, Dr Kharbanda and I seek to draw a number of lessons from major disasters involving chemicals that have reached the headlines over the years, but the fact remains that despite the notoriety resulting from such dramatic events, the chemical process industry has an excellent safety record. This despite the fact that many of the materials it handles are extremely hazardous. However, the public image of the chemical industry sustained a severe blow 0.

Kharbanda

book Safety in the Chemical Industry: Lessons from Major Disasters, has recently been published by Heinemann, price E25.00. After 30 years in industry in the United States, United Kingdom and India, Dr 0. P. Kharbanda now runs his own management consultancy. Mr Ernest Stallworthy has his own management consultancy, Dolphin Project Management Services, and he is Honorary Visiting Lecturer in the Department of Chemical Engineering at the University of Aston, Birmingham. P.

and E. A. Stallworthy’s

following a series of disasters in 1984, culminating in the nightmare of Bhopal. Yet it remains true, and can be substantiated by detailed statistics, that the chemical industry is one of the safest of industries.

Learning From the Past From the study and analysis of actual disasters we can learn valuable lessons that can help us to avoid similar accidents. Table 1 lists major disasters in the chemical and allied industries in the present century.’ The chemical industry is seen by the general public as an industry that handles highly dangerous materials in ways which the public does not understand, and is therefore suspect. It is unfortunately true that the public’s perception of industrial disasters, their causes and their frequency, depends wholly on the publicity given them in the media; some of which sensationalize and distort the truth, a phenomenon dealt with in a recent book, The Good News is the Bad News is Wrong. 2 Although the public impression seems to be that things are getting steadily worse, in fact the opposite is the case. For instance:3 By almost every type of societal indicator, except one, hazardous events have been increasing. the one exception is the statistical record of hazard consequences there frequently appears to be an enormous divergence between this record and the perception of hazards by the scientist, the public and officialdom.

There is indeed a very considerable gap between the real risk (so far as that can be precisely assessed) and the risk as perceived either by the technologist directly concerned or the general public. Both, and particularly the public, tend to believe the risk to be far greater than it actually is. There is no doubt that the safety record of the chemical industry is much better than that of most other industries. According

Long

84 Table

Range

1. Maior

Planning

Vol.

22

disasters in the chemical

Year

February industry

since 1920

Site

1921

Oppau

1942 1944

Honkeiko Cleveland

1947

Texas

1948

Ludwigshafen

1956 1974 1975 1976

Cali (Colombia) Flixborough (U.K.) Chasnala (India) Seveso (Italy)

1978

San Carlos

1979

Novosibirsk

1984

Cuhato

1984

San Junico

1984

Bhopal

Nature

(Germany) (China) (U.S.A.)

(U.S.A.)

(West

(Spain) (U.S.S.R.)

(Brazil) (Mexico)

(India)

This list is typical rather than exhaustive.

1989

Germany)

No. of deaths

of disaster

Warehouse explosion. Dynamite was being used to pry loose caked ammonium nitrate Coal dust explosion LNG storage tank exploded, due to structural weakness Ship carrying ammonium nitrate exploded and nearby styrene plant exploded as a result. There were fires in city Railway car containing dimethylether exploded on siding inside factory gate Dynamite truck explosion Explosion in caprolactum plant due to a pipe rupture Mine explosion Explosion released poisonous dioxin vapour into the atmosphere Propylene gas truck exploded, having crashed into a wall Accident in chemical warfare plant (details not available) Gasoline from a leaky pipeline caught fire and there was then an explosion Explosion in a LNG storage tank in a LPG distribution plant Storage tank containing MIC exploded due to exothermic reaction with water that leaked into tank

The details regarding

deaths are approximations

to Alvin M. Natkin, a distinguished Fellow of the World Resources Institute and a former manager of Environmental Affairs for the Exxon Corporati,on : Ironically, the U.S. chemical industry’s accident prevention history is one of the best of all U.S. manufacturing industries. In the most serious accident category-those involving death and days away from work-chemical manufacturers rank highest, with the lowest accident rate among the 42 reporting manufacturing industries.

This is demonstrated by Figure 1 which relates to the U.K. It will be seen that in terms of both incidence and severity the rate for the chemical industry is not only well below the all-industry average, but displays a tendency to fall that is also not shown by the all-industry average. There is no doubt that a similar situation prevails in all the countries of the developed world, and most of the countries in the developing world, although the statistics are not always available to demonstrate that this is so. The disaster at Flixborough in 1974 (see Table 1) has been one of the best documented in the chemical industry anywhere. The Court of Inquiry’s report was most comprehensive and so provides many lessons for the industry world-wide. Though the number of deaths was much lower than for many other disasters listed in Table 1, the tragedy was considered to be extremely serious. Awareness of the problem spread from the U.K. to Europe following three more serious accidents, one in The Netherlands and the other two in Italy. These further incidents, and the fact that there was great

developed

from available

561 1572 131 576

207 1100 28 431 Not known Over 500 Some

300

Over 500 Over 500 More

than

2500

data

disparity in the relevant regulations amongst the several member countries of the EEC, led to the preparation of a draft directive in 1980 on Major Accident Hazards.4 After protracted negotiations, the Directive was finally implemented in phases as from 8 January 1984. This directive requires disclosure of relevant information and the drawing up of emergency plans to cope with the ‘if’ situation. It is anticipated that the implementation of this directive will help to reduce not only the frequency of disastrous accidents, but also their consequential damage. It is indeed this directive that governs the planning for emergencies that we discuss later, so far as the EEC is concerned.

Management is Held Both Responsible and Accountable Alvin M. Natkin (quoted above) having corporate responsibility in the aftermath comes to the following conclusion:

considered of Bhopal,

Accidents will happen, but industry and governments can take steps to reduce the likelihood and severity of tragedies like the one that rocked the world on 3 December 1984. use of the best new safety Preventive maintenance, technologies, careful monitoring and worker education are all corporate responsibilities.

The emphasis is ours, since the foolish actions of employees can never be an excuse for management. For instance, U.K. law recognizes the ‘vicarious responsibility’ of employers for actions by their employees. Acceptance of this responsibility should

Planning

for Emergencies

85

maxim that ‘Safety is everyones business’ has to be both proclaimed and put into practice. Safety considerations should have proper prominence at boardroom level, with the recognition that expenditure on safety provisions cannot be subject to the normal rigid financial review in terms of the rate of return on investment. Cost-benefit considerations are applied to some of this expenditure, but there will always be situations where such an evaluation cannot be appropriate. Human life, for example, is precious but its value is highly subjective.

(a) Incidence

n ” 1977 1978 1979 19801981

1982 198319841985

Year The lost-time injury incidence rate per 100 full-time employees in the chemical industry compared with the all-industry average. Source: Accident Facts, National Safety Council, U.K. (1978 - 1986). (b) Severity

How can both management and workers be motivated to make safety a prime consideration? Let us see what happens as a result of accidents. There are both humane and economic considerations, as set out in Table 2, which we can summarize as follows : (a) Humane considerations: physical harm as the result of injury, illness and death, with the related impact on family and friends, including workmates. (b) Economic considerations: property damage to plant and buildings, loss of production and profits, some of which can be insured against, but much cannot. These considerations should inspire management to do all that they can to ensure safety all the time. But they have to do more than that: they have to plan. In particular, they have to plan the way in which they are going to tackle disaster, if it ever comes.

Year The industrial injury severity rate, measured by the days away from work per 100 full-time employees in the chemical industry, compared with the all-industry average. Source: Accident Facts, National Safety Council, U.K. (1978 - 1986)

Figure 1. Accident chemical industry.

prevention in the U.K. (a) Incidence, (b) Severity

pervade management and its procedures throughout. Safety cannot be pursued in isolation, nor is it the peculiar province of the safety officer. The Table

Risk and the Community

Before we come to consider the way in which we should tackle disaster, it is helpful to consider the community attitude to risk. We are all aware of the multitude of accidents and deaths that occur on the roads. This is a familiar risk which everyone understands. But there are other risks, especially those associated with the workplace, of which the average person knows very little. The public can take care on the roads, but they cannot ‘take care’ in the same way when it comes to the risks and the

2. The results of accidents

Personal

harm

Injury or illness trivial minor serious reportable rating compensation disabling, with lost time fatal catastrophic (multiple deaths)

Humane

considerations

sorrow hardship physical pain and discomfort psychological problems

at Large

Damage

to property

To plant and buildings minor serious major catastrophic

Economic

considerations

insured costs uninsured property damage uninsured miscellaneous costs loss of production third party liability costs of accident investigation loss of sales

86

Long

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Planning

Vol.

22

February

hazards presented by an industrial plant. Then they rarely have any idea as to what they should do-if indeed, they should do anything at all. Yet it is fundamental that, for the avoidance of risk, the risk must first be known and appreciated. Vincent T. Covcllo, in an exhaustive review of risk analysis and risk management, points out that both experts and the lay person are over-confident about their risk estimates.’ It is suggested that this explains the reluctance of many drivers to wear seat belts. The concept of risk is difficult to grasp: to give a scientific perspective to the subject is even more so. It is the ‘principle of uncertainty’ that makes the mischief. For instance, when one starts talking about the probability of death, which is part of risk analysis, people arc not reassured: they are scared. What is the objective ? We are trying to get people to appreciate the risks they run, and as soon as we put it in this way the problem is perceived as real. We would like to tell people the risks they don’t YWZ, but the scientist and technician do not put it that way. Alvin Reinberg defines the subject as a ‘transscience’ : a question which one may ask of science but which cannot be answered.h All too frequently the hazard, that is the possibility ofa harmful event, is confused with the probability that the event will actually materialize. When talking to the public one wants to present the idea of risk as an improbability: it is very unlikely that this, or that, will actually happen. How unlikely? Well, thcrc is only one chance in a million that it will happen. But now we are talking in terms of a probability, about something that can happen -however unlikely the event. What is an acceptable risk? The answer to that is largely subjective. It has been said that the risk of one death per year in a million is thought worth taking by the general public. Workers, it seems, are prepared to take a greater risk: one death per year in 100,000 is tolerated by them. Those involved in assessing risk, however (not taking it!) seem to consider that the probability of one death per year in 10,000 is on the border lint of acceptability.’ What do these figures actually mean? To get the concept in some sort of framework, the probability of being killed in a car accident, for a city dweller, is said to be 1 in 7500 per year. This means that in a city of 300,000 inhabitants, 40 people are going to die every year as a result of car accidents. If the risk were one in a million, only one person would die every 3 years on that account. This is what WC arc talking about when we discuss probability. It was Lord Rothschild who in 1978 actually suggested that since the probability of death on the road was about 1 in 7500 per year, this could be seen as the limit for an acceptable risk.” He pointed out that the public stem quite ready to take it: there is no public outcry against death on the road. Unfortunately, may be, people

however scientific the in general are unwilling

approach to take a

1989 purely statistical view of risk. Why? They worry far more about involuntary risks such as carcinogens in food, than about voluntary risks (risks they can avoid), such as rock climbing, although statistically speaking the risk is far greater with the second than with the first. Similarly, the public is far more concerned about major industrial disasters than the multitude of minor accidents that occur, even although their probability is far less. This may be considered to be irrational, but it is true. Thus there is a very wide gap between the real risk and the perceived risk, so far as the general public is concerned. De$zing Risk in a Way That is Understood It is evident that there are degrees of risk: we have just cited practical examples. Risk can be assessed scientifically, but there is a margin of error in such assessments, and the answers may not be completely reliable. However, this elusiveness of certainty in science is seen by the public as cvasiveness.6 This means, then, that in matters of risk the scientific finding must be explained in clear, accurate and positive language if it is to be understood. This point can perhaps be best appreciated by considering the weather forecast. WC may be told that there is a ‘10 per cent chance of rain’. If we were told it was going to rain all day we would know very well what to do. We would take our umbrella. But a ‘10 per cent chance . . .‘. Do we take our umbrella with us, or don’t WC? Most of us, hearing that forecast, might take the risk and leave the umbrella behind, yet we could still get caught in a shower. We take the risk because the consequences of being drenched, while uncomfortable, are not tragic. Were the consequence death, we would not dream of taking the risk: not even if it was as low as 1 in 10,000, a thousand times less. This shows that we take into account not only the degree of risk, but its nature. We are prepared to take the risk of getting wet if it is as high as 1 in 10, but not of dying, even if it is only 1 in 10,000. Risk Perception is Subjective and Inconsistent People react differently, even to the same risk. Their reaction depends on their background and upbringing, since it is this that governs their perception of risk. The rock climber who enjoys the sport feels safe enough, whilst the non-climber trembles at the thought. How then are we going to convey a sense of risk run to the average householder or the worker in contact, for instance, with asbestos? We believe that people are more aware than the scientist thinks and also that they wish to know the facts, even if these are unpalatable. But what arc ‘the facts’? Part of the problem here is that scientists often disagree. Nevertheless, the public should be told and ways must be found of telling them clearly and explicitly, even if their reaction is found to be variable and inconsistent. The lack of consistency in the public perception of risk can be demonstrated by its reaction to the

Planning building of an industrial facility. So far as chemical plants are concerned, we have no data, except the general and universal reaction: ‘Build it if you want, but not in my backyard’. When it comes to electric power plants, however, we do have some statistical data.’ It appears that the number of people who are willing to live near a nuclear power plant is smaller than those who think that such plants should be vary according to the built. The proportions background of the persons asked. For instance, the percentages expressing willingness to live within 16 km of a nuclear power plant were: Environmentalists Chemical engineers Nuclear engineers

40.1% 73.7% 58.1%

What conclusions can we draw from such figures? Dare we say that the perception of risk is greater with nuclear engineers than with chemical engineers, because they know more about it? Have the environmentalists really got it right? Or is their fear generated by misunderstanding and misconceptions? Closing the Communication Gap It is clear that ignorance can lead people to think that a risk is greater than it really is, and this of course results in unreasonable reactions. This is one area where ignorance is not ‘bliss’. Ignorance of the risk also means that it is an unknown risk. The message has to be brought home in non-technical terms if it is to be understood. Even though, statistically speaking, it may well be much more dangerous to ride in a car than to fly in an aeroplane, the public perceives the risk differently and considers flying to be more dangerous than driving. Statistics-the numbers game-just does not carry any weight. It is feelings that count: the perceived risk, not the actual risk. Dr Robert DuPont, President of the Center for Behavioural Medicine, puts it thus: The public decides risk on the basis of feelings . what scares people is often not the same thing that is really threatening them.

Paul Slavic, a psychologist and an expert on risk analysis at Decision Research in Eugene, Oregon, says : People tend not to worry about automobile risks or smoking and tend to be very concerned about very small amounts of toxic material or chemicals in food or water.

One wonders to what extent the dismissal of the risks associated with driving and smoking is governed by an intense urge to do those things. It is these considerations that lead us to believe that those who are seeking to get the message across should relate the risk to the benefits. People still fly, even though they believe that they are at greater risk than when they drive. Why? They are prepared to take what they believe to be the greater risk because they wish to enjoy the benefit-the time they save. So let us not worry so much about conveying the magnitude

for Emergencies

87

of the risk: the implications of that are almost impossible to bring home to the average person. Let us rather emphasize the benefits that accompany the risk, while explaining as clearly as possible the ways in which it is controlled and minimized. Some of the reasons for the difficulty in closing the communication gap between the assessment of risk and its perception are already apparent. There arc other reasons which are equally powerful, about which it may be possible to do something. William Ruckelshaus, speaking from vast experience (he was an EPA administrator for two terms and earlier a director of several major chemical corporations, including Monsanto) says that trust is the crux of the matter.‘” Events such as Watergate have eroded trust in the government and its assertions. However, the way is open, particularly in the United States under the Freedom of Information Act. More and more countries are introducing legislation that gives their citizens the ‘right to know’ in matters which affect them and even to participate in the making of decisions that concern them. if this spreads and grows, trust will be cultivated. As we shall see, the ‘right to know’ is crucial in the development of plans for coping with potential disaster.

Who Plans for Emergency

Action?

Despite the best preventive measures possible, an undesired event, such as a fire, an explosion, or the dangerous emission of a toxic chemical, can still occur. There are four basic reasons why such things happen : 12 Human

error

A Equipment *

Defective

*

Poor

failure operation

maintenance

Plans should be laid to meet an emergency arising from such causes, the objective of such plans being to minimize their effects. It will be appreciated that it is assumed that all the appropriate safety regulations are being enforced and that the plant and equipment has been designed with safety continually in mind. Nevertheless, accidents will happen. So now we turn to consider how we should deal with them when they do indeed happen. Such plans fall into four broad areas: a

Internal

emergency

*

Emergency

*

Emergency complex

planning planning

planning for a single plant for

an

~2 Hazard and disaster prevention authorities

entire planning

industrial by local

Internal emergency planning is largely administrative; a typical example of emergency planning for a

88

Long

Range

Planning

Vol.

22

February

single plant would be an evacuation procedure in the case of a fire. Although the emergency planning for an industrial complex would involve not only the companies concerned, but the local authorities. This can be regarded as internal planning, since the initiative would still rest with the company itself. There are books and manuals available that provide guidance.“~‘* Over and above this, local authorities should have prevention planning, involving their own facilities and personnel. This should, of course, be related to and integrated with country-wide plans, established on a national and sometimes even on an international basis, as for instance occurs in Western Europe. A good example of the last type of planning is the arrangements set up by the several countries bordering the River Rhine-Switzerland, Germany, France, Luxembourg, Belgium and The Netherlands-to cope with disasters on its banks, usually involving spillage into the Rhine. Internal Emergency Planning The internal emergency plan involving three major steps:

should

be seen

*

The need to alert (by way of alarm systems,

*

The need to rescue

*

The need to contend

(with

the accident

as

etc.)

itself)

These three needs raise a number of questions: for instance, what and who will raise an alarm, whom should we alert, what will we have to rescue people from, what sort of incident are we likely to have to deal with? All such questions need to be answered if a sound plan is to be developed. The only way to answer them is to develop a number of possible scenarios and assess their implications. For instance, the alarm plan should incorporate the following data: Important

telephone

numbers

Instructions stating : why the alarm is given who sets the alarm off what device is used to give the alarm what steps the personnel so alerted should take who should give the ‘all clear’ signal to whom, and how, the ‘all clear’ signal should be given. Plan showing

central

and peripheral

List of all plants located

in the central

Names of the key people telephone numbers Details

zones zone

for each plant,

with

of any special hazards

Indication as to which lead to an alarm

specific

plant

incidents

the normal course of events the firemen, police and other officials confronted with an emergency

1989 involving hazardous chemicals will know little or nothing of the chemistry of the process or the way in which the plant has been engineered. A book that provides a degree of initiation for those likely to be involved in this way, Hazardous Materials Emergencies-Response and Control’3 is a collection from the author’s Hazardous Materials Newsletter: on this account there is a lot of repetition, but the information presented is extremely valuable. It relates almost entirely to the chemical process industry and one chapter, written from the point of view of an industrial response team, describes the Emergency Reporting STERP (Shell T ransport Procedure) and DuPont’s TERP (Transport Emcrgency Reporting Procedure). Both these procedures are tied into the Chemical Manufacturer’s Association CHEMTREC information system.

It Can Happen Anytime,

Anywhere

Preparedness for accidents has to be sustained: a constant, unremitting watch at all times. There can be no let-up. Then, when an accident does occur, action must be swift, with instant reaction, to prevent the spread of damage. There is no time to look into or consider causes. Since the effect of an accident can be widespread, the communities in the locality need to know not only what to do, but also what is being done for their protection. They have every right to know and to demand that effective action be taken to save them from the consequences of accidents. That an accident can indeed happen anytime, anywhere, can be demonstrated by a multitude of examples from real life, and we see that often there is not time to explain and give details. For instance, in response to a knock on the front door, Susan-Marie Kelly was told by a State Trooper: ‘There’s been a train wreck. Some dangerous chemicals are leaking. You must evacuate the area now’.14 In such circumstances the official instructions should be followed immediately, without question. There is no time for discussion and no reason to argue. Above all, concern for property, however valuable, is beside the point, since nothing is more valuable than a human life. Planning Co-ordination The U.S. Environmental Protection Agency have developed a plan for the protection of the public. It is called the Chemical Emergency Preparedness Plan and is designed to help state and local governmental authorites respond to the emission of toxic chemicals. It deals with both routine and accidental releases. It is a two-part plan, designed to assist communities in : (1) obtaining information on the chemicals used in their neighbourhood, and (2) developing and improving their emergency planning.

Planning The whole set-up is voluntary: it has not yet been regulated by either Federal or State law. In this it differs, for instance, from a similar initiative in the U.K., which has the force of law.

for Emergencies

its own special problems, plan for emergencies.

89

but all industry

needs to

With the U.S. system, the community is advised to designate someone as co-ordinator for emergency situations and such a person should:

A have

a thorough operation

understanding

*

be able to react calmly

a

understand how an incident other areas.

of the plant’s

in an emergency

Where

fi

What

happens

ti

What

can go wrong

B. Bowonder et a/., Avoiding 27 (9), 61 (1985).

(2)

B. J. Wattenburg, The Good News is the Bad News Simon & Schuster, New York (1984).

(3)

R. W. Needs (1978).

(4)

L. Waldon, After Seveso, April (1984).

(5)

V. T. Covello, The perception of technological risks: a literature review, Technological Forecasting and Social Change, 16, 285297,23 August (1983).

(6)

F. Press, Speaking (1986).

(7)

M. Abraham, The Lessons of Bhopal-A Community Action Resource Manual on Hazardous Technologies, International Organization of Consumers Union, Penang, Malaysia (1985).

(8)

One man’s acceptable risk is another man’s accident, 294,77-78,19 January (1985).

(9)

M. K. Lindell and T. C. Earle, How close is close enough: public perceptions of the risk of industrial facilities, Risk Analysis, 3, 245253, December (1983).

in one area can affect

The co-ordinator must have what is called the ‘big picture’ in mind and should be able to ask and obtain answers to relevant questions, such as: fi

(1)

is the plant located? there? there?

The last question is of course crucial, and it is by asking the right questions that the appropriate solutions are found. Very similar steps have been taken in the U.K. We have sought at this point to present but a ‘broad brush’ view of the steps that must be taken both by the company and the community to tackle disaster as and when it occurs. We have seen that plans have to be laid and that there must be constant readiness if those plans are to be effective in action. Over the past few years, great strides have been made in many countries in the world to co-ordinate emergency planning, so that the steps taken by the company are soundly integrated with the actions that must be taken by the community in whose midst they are. But what we have said so far applies to almost any industrial activity: the chemical industry may have

(16)

Kates, Managing and Opportunities,

about

future

Bhopals,

Environment,

is Wrong,

Technological Hazards-Research University of Colorado, U.S.A.

Occupational

Safety

risk, Chemtech,

W. Ruckelshaus, Risk communication-Why discuss risk with the public?, Chemtech, tember (1986).

& Health,

16,

16,

336-338,

p. 10,

June

Economist,

is it so tough to 533-535, Sep-

(11)

D. H. Wilson and M. Flowers, Accident&Emergency Butterworth, MA (1985).

Handbook,

(12)

E. L. Quarantelli, Chemical Disasters: Preparations and sponses at the Local Level, Irvington, New York (1986).

(13)

J. Ft. Cashman, Hazardous Materials Emergencies-Response and Control, Technomic, Westport, CT (1983). See review by G. F. Bennett, Chemical Engineering, 91, 135-I 36, 17 September (1984).

(14)

S. M. Kelly, Plan for an emergency-You Safety and Health News, 133, 28-34,

Re-

could be next, National April (1986).