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Unintended consequences
JCHAS 728 1–2
[1_TD$IF]Unintended consequences News & Views
T
he legalization of marijuana has opened the door to home-brewing of hash oil. A drop of hash oil is shown in the attached black and white picture. For the record, I personally do not choose to use marijuana, but prohibition and criminalization have not worked, so moving it into the legal realm of ethanol makes some sense. That said, like many initiatives, unanticipated and unintended consequences are occurring. To date, 31 fires/explosions in Colorado have been traced to home conversion of marijuana to hash oil. The most common home brew method is to place chopped leaves in a tube and flow butane (think BICTM lighters) through the leaves. The butane extracts the cannabis from the leaves and the psychoactive chemical [3_TD$IF]crystallizes in the cold butane. The liquid is collected and the butane flashes off (boiling point [4_TD$IF] 1 8C). There is usually another purification step, but the flash-off is what produces the invisible dense cloud of flammable gas. Since this is often done in a garage or kitchen, there are abundant ignition sources, and eventually, the fire department is responding. Corbin Braithwaite is one of 31 persons who have discovered that home brewing can cause substantial problems. While experimenting on how to make hash oil, in his townhouse kitchen, he caused an explosion that blew out windows, cracked walls, and threatened an infant sleeping in the adjacent unit. Braithwaite was burned and singed, but avoided serious injury. He now faces a slew of felony charges including arson and child endangerment. Since Colorado legalized marijuana, there have been 31 similar incidents with 21 injuries. Interestingly, the voter-approved Colorado constitutional amendment allows the ‘‘possession and processing’’ of marijuana, so the home brew of hash oil is not illegal. In another incident, the home brewer successfully made his hash oil, but the refrigerator
1871-5532 http://dx.doi.org/10.1016/j.jchas.2014.05.005
he was storing it in exploded. Butane is soluble in hash oil and will slowly outgas, and accumulate in the closed space. This story is very similar to the biodiesel story. Explosions such as the January 2014 incident near New Albany, Mississippi have become all too frequent. The feedstock itself is not flammable; the problem is that its hydrolysis by sodium hydroxide produces methanol which must be separated from the oil. The home brewers and some production facilities do not engineer for handling a flammable liquid. In one instance, the production area used common industrial electrical wiring. The National Electrical Code requires that the entire production area be Class 1, Division 2. This 1 million gallon per year facility destroyed three other businesses as it burned. No one was hurt. West, Texas is another example of unintended consequences. The political leadership of Texas has decided to place the regulatory constraints on business at the lowest possible level. The result is occasional, but repeated mayhem. When asked, this is not the outcome the leadership desires, but it is real. It is an unintended consequence. The Process Safety Management procedure called ‘‘Management of Change’’ is designed to identify unanticipated consequences and make certain that all risks associated with them are minimized. This is a well-established and well[5_TD$IF]documented process. Is it too much to ask that the leadership at all levels of our country – Federal to local – use these concepts? Professionally, I am pretty good at anticipating what is likely to happen and offering mitigation to minimize it. We pay the ‘‘yo-yo’s’’ in government high salaries to provide professional, well-reasoned leadership. Either they get their act together or we should fire them.
UNANIMOUS BOARD APPROVAL OF ‘‘LANDMARK’’ TESORO REFINERY ACCIDENT INVESTIGATION
[6_TD$IF]I spent several nights in a camp ground across the channel from the Tesoro Refinery in Anacortes, Washington. This is the refinery that was the subject of the 1 May 2014 incident report by the U.S. Chemical Safety and Hazard Investigation Board (CSB). (As an aside, my overview images of the refinery are much more artistic and creative than those published on
ß Division of Chemical Health and Safety of the American Chemical Society Elsevier Inc. All rights reserved.
1
[7_TD$IF]8csb.gov.) This report calls for increased and improved regulatory oversight of the refining industry and significant improvements in the methodology of Process Hazard Analysis, as implemented by the industry. The CSB also faults Tesoro for inadequate safety leadership and awareness – that is, for having a poor safety culture. If all of this sounds familiar, it is. While the details vary, the CSB recommendations invariably focus on inadequate regulation of the affected facility (or industry) and ineffective management leadership in the area of safety. Indeed, these are the findings about laboratory safety in the CSB Case Study published in 2010 which addressed the Texas Tech explosion. The refining industry has a special obligation to be aggressive in reducing the risks associated with refining. Refineries are part of the national energy infrastructure and benefit in many ways from the taxes U.S. citizens pay. The industry is poorly thought of by many people, and incidents such as the recent Richmond, California fire or the Anacortes, Washington explosion only further erode public confidence. The chemical enterprise has developed a strong tool set for preventing incidents, the formal structure of Process Safety Management, which provides a framework for hazard analysis and risk mitigation. The current CSB
2
report, however, strongly suggests that these hazard assessment methods are inadequate and that the regulator (the EPA) has failed to require inherently safer processes. In the Anacortes case, the cause of the incident was High Temperature Hydrogen Attack (HTHA) of the steel equipment. This is a known hazard in certain refining processes and can be mitigated by appropriate material selection at the unit design level. This material substitution is an example of inherently safer design. It costs more to construct the unit, but significantly reduces the potential for HTHA. Similar examples can be cited from the many CSB studies of refinery incidents. The CSB again calls for the U.S. EPA to implement ‘‘sweeping changes’’ in the regulatory process and to require, in addition to Inherently Safer Processes, significant ‘‘Layers of Protection’’. Both of these topics are extensively documented in publications found in the Center for Chemical Process Safety library and many other resources. The process safety management construct can also be scaled directly to laboratories. The ‘‘regulator’’, that is, the facility EH&S department, can work with the lab to implement inherently safer lab practices and layers of protection. Thermal distillation can be replaced by column purification.
Hydrogenations can be moved into flow systems, such as the ThalesNano H-CubeTM. Oil baths can be replaced with heating blocks such as the Asynt Dry-SynTM system. Labs can implement layers of protection by combining administrative review procedures for proposed work with formal hazard analysis, as recently recommended by the ACS Committee on Chemical Safety. Principal Investigators can easily include safety as part of discussions of experimental design. These activities in conjunction with well-designed and maintained apparatus and standard laboratory engineering will provide increased safety with limited impact on research productivity. The American public is losing patience with repeated industrial failures. Academic administrators are recognizing that they must provide more oversight of the research environment, even if such oversight intrudes on traditional academic freedom. The goal in industry and research must be zero failures. A fire or explosion or an injury or fatality are unacceptable outcomes. Incidents are preventable and the cost of prevention is minor absolutely and in comparison to the cost of cleaning up post incident. Improved safety behavior across the entire chemical enterprise makes economic sense and community sense. Now is the time to improve!
Journal of Chemical Health & Safety, July/August 2014
[1_TD$IF]Unintended consequences News & Views
T
he legalization of marijuana has opened the door to home-brewing of hash oil. A drop of hash oil is shown in the attached black and white picture. For the record, I personally do not choose to use marijuana, but prohibition and criminalization have not worked, so moving it into the legal realm of ethanol makes some sense. That said, like many initiatives, unanticipated and unintended consequences are occurring. To date, 31 fires/explosions in Colorado have been traced to home conversion of marijuana to hash oil. The most common home brew method is to place chopped leaves in a tube and flow butane (think BICTM lighters) through the leaves. The butane extracts the cannabis from the leaves and the psychoactive chemical [3_TD$IF]crystallizes in the cold butane. The liquid is collected and the butane flashes off (boiling point [4_TD$IF] 1 8C). There is usually another purification step, but the flash-off is what produces the invisible dense cloud of flammable gas. Since this is often done in a garage or kitchen, there are abundant ignition sources, and eventually, the fire department is responding. Corbin Braithwaite is one of 31 persons who have discovered that home brewing can cause substantial problems. While experimenting on how to make hash oil, in his townhouse kitchen, he caused an explosion that blew out windows, cracked walls, and threatened an infant sleeping in the adjacent unit. Braithwaite was burned and singed, but avoided serious injury. He now faces a slew of felony charges including arson and child endangerment. Since Colorado legalized marijuana, there have been 31 similar incidents with 21 injuries. Interestingly, the voter-approved Colorado constitutional amendment allows the ‘‘possession and processing’’ of marijuana, so the home brew of hash oil is not illegal. In another incident, the home brewer successfully made his hash oil, but the refrigerator
1871-5532 http://dx.doi.org/10.1016/j.jchas.2014.05.005
he was storing it in exploded. Butane is soluble in hash oil and will slowly outgas, and accumulate in the closed space. This story is very similar to the biodiesel story. Explosions such as the January 2014 incident near New Albany, Mississippi have become all too frequent. The feedstock itself is not flammable; the problem is that its hydrolysis by sodium hydroxide produces methanol which must be separated from the oil. The home brewers and some production facilities do not engineer for handling a flammable liquid. In one instance, the production area used common industrial electrical wiring. The National Electrical Code requires that the entire production area be Class 1, Division 2. This 1 million gallon per year facility destroyed three other businesses as it burned. No one was hurt. West, Texas is another example of unintended consequences. The political leadership of Texas has decided to place the regulatory constraints on business at the lowest possible level. The result is occasional, but repeated mayhem. When asked, this is not the outcome the leadership desires, but it is real. It is an unintended consequence. The Process Safety Management procedure called ‘‘Management of Change’’ is designed to identify unanticipated consequences and make certain that all risks associated with them are minimized. This is a well-established and well[5_TD$IF]documented process. Is it too much to ask that the leadership at all levels of our country – Federal to local – use these concepts? Professionally, I am pretty good at anticipating what is likely to happen and offering mitigation to minimize it. We pay the ‘‘yo-yo’s’’ in government high salaries to provide professional, well-reasoned leadership. Either they get their act together or we should fire them.
UNANIMOUS BOARD APPROVAL OF ‘‘LANDMARK’’ TESORO REFINERY ACCIDENT INVESTIGATION
[6_TD$IF]I spent several nights in a camp ground across the channel from the Tesoro Refinery in Anacortes, Washington. This is the refinery that was the subject of the 1 May 2014 incident report by the U.S. Chemical Safety and Hazard Investigation Board (CSB). (As an aside, my overview images of the refinery are much more artistic and creative than those published on
ß Division of Chemical Health and Safety of the American Chemical Society Elsevier Inc. All rights reserved.
1
[7_TD$IF]8csb.gov.) This report calls for increased and improved regulatory oversight of the refining industry and significant improvements in the methodology of Process Hazard Analysis, as implemented by the industry. The CSB also faults Tesoro for inadequate safety leadership and awareness – that is, for having a poor safety culture. If all of this sounds familiar, it is. While the details vary, the CSB recommendations invariably focus on inadequate regulation of the affected facility (or industry) and ineffective management leadership in the area of safety. Indeed, these are the findings about laboratory safety in the CSB Case Study published in 2010 which addressed the Texas Tech explosion. The refining industry has a special obligation to be aggressive in reducing the risks associated with refining. Refineries are part of the national energy infrastructure and benefit in many ways from the taxes U.S. citizens pay. The industry is poorly thought of by many people, and incidents such as the recent Richmond, California fire or the Anacortes, Washington explosion only further erode public confidence. The chemical enterprise has developed a strong tool set for preventing incidents, the formal structure of Process Safety Management, which provides a framework for hazard analysis and risk mitigation. The current CSB
2
report, however, strongly suggests that these hazard assessment methods are inadequate and that the regulator (the EPA) has failed to require inherently safer processes. In the Anacortes case, the cause of the incident was High Temperature Hydrogen Attack (HTHA) of the steel equipment. This is a known hazard in certain refining processes and can be mitigated by appropriate material selection at the unit design level. This material substitution is an example of inherently safer design. It costs more to construct the unit, but significantly reduces the potential for HTHA. Similar examples can be cited from the many CSB studies of refinery incidents. The CSB again calls for the U.S. EPA to implement ‘‘sweeping changes’’ in the regulatory process and to require, in addition to Inherently Safer Processes, significant ‘‘Layers of Protection’’. Both of these topics are extensively documented in publications found in the Center for Chemical Process Safety library and many other resources. The process safety management construct can also be scaled directly to laboratories. The ‘‘regulator’’, that is, the facility EH&S department, can work with the lab to implement inherently safer lab practices and layers of protection. Thermal distillation can be replaced by column purification.
Hydrogenations can be moved into flow systems, such as the ThalesNano H-CubeTM. Oil baths can be replaced with heating blocks such as the Asynt Dry-SynTM system. Labs can implement layers of protection by combining administrative review procedures for proposed work with formal hazard analysis, as recently recommended by the ACS Committee on Chemical Safety. Principal Investigators can easily include safety as part of discussions of experimental design. These activities in conjunction with well-designed and maintained apparatus and standard laboratory engineering will provide increased safety with limited impact on research productivity. The American public is losing patience with repeated industrial failures. Academic administrators are recognizing that they must provide more oversight of the research environment, even if such oversight intrudes on traditional academic freedom. The goal in industry and research must be zero failures. A fire or explosion or an injury or fatality are unacceptable outcomes. Incidents are preventable and the cost of prevention is minor absolutely and in comparison to the cost of cleaning up post incident. Improved safety behavior across the entire chemical enterprise makes economic sense and community sense. Now is the time to improve!
Journal of Chemical Health & Safety, July/August 2014