Hazard Identification
The hazard identified with this particular chemical manufacturing operation involved asbestos exposure to employees working near the Atmospheric Distillation Tower, which contained asbestos insulation that was in exceedingly poor condition. Once the tower cooled down the insulation would come off and large pieces of asbestos would fall and strike employees working in the area. Severe weather was also of concern because during heavy rain the asbestos would become saturated, increasing the weight by 3-4 times the original weight.
Hazard Intervention
The company identified the asbestos hazard as a chemical exposure to employees. The abatement approach involved a change in the engineering controls. Four abatement options were considered by the company. The option chosen entailed abating the remaining asbestos during the turnaround (TAR) period by requiring a full enclosure of the tower, using a methodical, step-by-step approach. Repairing the insulation was not an option due to the poor condition the insulation was already in and the work schedule conflicted for the upcoming TAR. Previously, a partial enclosure method, using metal jacketing had been attempted, but it was not effective in abating the asbestos.
Impacts of the Intervention
There were many positive health, business and risk management results due to the implementation of the hazard abatement intervention. Health improvements resulted from the intervention because employees were not directly exposed to falling asbestos. The business process was improved since there was no impact to the length of the TAR period, which allowed for no margin loss and essentially suspended over $6 million unit shutdown costs. Residual risks did not result from the TAR because it was easy to reduce the remaining asbestos. The full enclosure of the tower with fire-resistant material did have a higher cost than other options such as partial enclosure methods that were considered. Some negative financial impact resulted to the business process because it required supplied air, A/C systems, air movers, PPE, and other equipment. However, many positive benefits resulted from the intervention.
The company was able to avoid the potential for heavy litigation costs related to asbestos exposure and contamination. The intervention represented a new process that could be used not only in other facilities, but also in other such vessels within the plant. Since the hazard was eliminated, the effects of the intervention were felt over time, fundamentally reducing risk and operating expenses plant-wide. The emergency response processes were also greatly simplified and associated costs were saved. The company also avoided many environmental costs, including asbestos cleanup and regulatory costs associated with “willful” incidents. Safety issues concerning the process of abating the asbestos were extensively reviewed by company industrial hygienists.
Lessons Learned
Integrating industrial hygienists into the planning of operations at the right time is of key importance. Early communication of the hazards by industrial hygienists to the management level will allow for the interventions to be more efficient and less risky.