How Risk Assessment Fails—Again. This time at DuPont.

This entry is part 6 of 8 in the series Risk Assessment

A recent report released by the US Chemical Safety Board (CSB) looks at a series of accidents that occurred over a 33-hour period on January 22 and 23, 2010 at the DuPont Corporation’s Belle, West Virginia, chemical manufacturing plant.

A number of significant failures occurred, but I want to focus on one passage from the press release that is telling, particularly considering that DuPont is seen as a class leader when it comes to worker safety. I would encourage you to read the entire release. You can also have a look at the DuPont investigation details on the CSB site. CSB also produced a video discussing the investigation.

From the press release:

“Internal DuPont documents released with the CSB report indicate that in the 1980’s, company officials considered increasing the safety of the area of the plant where phosgene is handled by enclosing the area and venting the enclosure through  a scrubber system to destroy any toxic phosgene gas before it entered the atmosphere. The analysis concluded that an enclosure was the safest option for both workers and the public.  However, the documents indicate the company was concerned with containing costs and decided not to make the safety improvements. A DuPont employee  wrote in 1988,  “It may be that in the present circumstances the business can afford $2 million for an enclosure; however, in the long run can we afford to take such action which has such a small impact on safety and yet sets a precedent for all highly toxic material activities.[sic]”

The need for an enclosure was reiterated in a 2004 process hazard analysis conducted by DuPont, but four extensions were granted by DuPont management between 2004 and 2009, and at the time of the January 2010 release, no safety enclosure or scrubber system had been constructed. CSB investigators concluded that an enclosure, scrubber system, and routine requirement for protective breathing equipment before personnel entered the enclosure would have prevented any personnel exposures or injuries.”

The highlighted passage above shows one of the key failure modes in risk assessment: failure to act on the results. So what’s the point of conducting risk assessments if they are going to be ignored? In a presentation in 2010, a colleague of mine made this statement:

“The risk assessment process is intended to be used as a decision making tool that will help to protect workers.” — Tom Doyle, 2010

This is a fundamental truth. The risk assessment paperwork cannot protect a worker from a hazard, only action based on the report can do that.

When decision makers receive the results from a risk assessment process and choose to ignore it, or as the press release stated, “…extensions were granted by DuPont management…”, management is making a fundamentally flawed decision. The risk assessment process intentionally exposes the hazards in the scope of the analysis, and explicitly analyzes the probable severity of injury and occurrence. Once the analysis is complete, choosing to ignore the results, presuming that there is no evidence that the results are incorrect, amounts to negligence in my opinion.

Does this mean that we should not conduct risk assessments? Absolutely not! In the Western world, we are obligated to protect the safety of workers, including our colleagues and employees, as well as anyone else that may intentionally or unintentionally be exposed to the hazards created by our activities. We are morally and ethically, as well as legally, obligated.

Used correctly, risk assessment in any of its many forms provides a powerful tool to protect people. Like any other powerful tool, it also takes significant courage and skill to use correctly. Defaulting to the cost argument alone, as it appears that DuPont did in this case, results in the type of fatal failures seen in this tragic series of events.

Special thanks to my colleague Bryan Hayward, the Safety Engineering Network Group on LinkedIn, and SafTEng.net.

What is your experience with implementing risk assessment? Have you experienced this kind of result in your work? Share your experiences by commenting on this post!

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CSA Z1002 Public Review – Last Day!

Last Chance!

Today is Thursday, 17-Mar-2011, marking 60 days into the public review period for CSA Z1002 — Occupational Health and Safety Hazard Identification and Elimination and Risk Assessment and Control.

If you downloaded the draft from the CSA web site, remember that the PDF will lock on 18-Mar, and you will no longer be able to do anything with it. If you haven’t looked at it yet, NOW IS THE TIME! Comments must also be submitted by midnight on the 17th, so please submit them as soon as possible. No submissions will be accepted after the 17th of March!

If you don’t have the draft already, get it here. Comments can be submitted in the same place as you download the draft. DO NOT SUBMIT COMMENTS TO THIS BLOG.

If you need more information on the draft or on submission of comments, please contact the CSA Project Manager, Ms. Elizabeth Rankin, elizabeth.rankin’at’csa.ca, +1 (416) 747-2011.

CSA Z1002 Public Review – 5 Days to Go!

Today is Sunday, 13-Mar-2011, marking 55 days into the public review period for CSA Z1002 — Occupational Health and Safety Hazard Identification and Elimination and Risk Assessment and Control.

If you downloaded the draft from the CSA web site, remember that the PDF will lock on 18-Mar, and you will no longer be able to do anything with it. If you haven’t looked at it yet, NOW IS THE TIME! Comments must also be submitted by midnight on the 17th, so please submit them as soon as possible. No submissions will be accepted after the 17th of March!

If you don’t have the draft already, get it here. Comments can be submitted in the same place as you download the draft. DO NOT SUBMIT COMMENTS TO THIS BLOG.

If you need more information on the draft or on submission of comments, please contact the CSA Project Manager, Ms. Elizabeth Rankin, elizabeth.rankin’at’csa.ca, +1 (416) 747-2011.