A small correction. Mary Kay O'Connor, a Chemical engineer died in the Phillips 66 Pasadena explosion in 1989. MKOPSC was established in her memory in 1995. I have studied the Pasadena explosion report and visited College Station (MKOPSC campus) when I visited Texas in Dec 2013 (after Christmas and during New Year Jan 2014).Most people I have spoken to in the process safety field insist that US PSM regulations (OSHA 1910.119) are one of the most comprehensive regulations. Despite the fact that there are many ageing facilities in the region, with such comprehensive regulations why has been such an increase in incidents in the last 5 years? That is the question I am seeking an answer for. Thanks for taking the time to respond to my query. I was not aware that the GOM region is the oldest oil producing and processing area.Raj Sreenevasan
Raj,Dr. Roat is correct in terms of size, age and mix of oil/gas/transport/refining/basic-intermediate-specialty chemicals assets in Texas. It is a ChE dreamland. The Incident reporting/investigations also cover agriculture, transportation and any materials incident. That is as it should be. The regulations are comprehensive but regulations, in and of themselves, do not equate to safety. If the national speed limit was 120 kph (75 mph) then regulated down to 90 kph (~55 mph) to reduce traffic deaths, that might happen. But, if some drivers refuse to abide by the new limit, people will still be killed even if the vehicles are built to withstand 55 mph crashes.Culture matters at the work front and in the board rooms. The scale of growth in Texas industries with the ongoing shale oil boom, the number of varied size companies handling materials with not enough regard for the hazards and the cowboy nature of freedom loving Texans (from all over the world) adds to the issue. The boom-bust cycle of many industries and the economic drives for companies to survive the down turns (think Covid-19), unfortunately teaches operators of assets they can delay maintenance, skip critical training, postpone upgrades and such to save cost and get away with it. The delayed system feedback might take decades. This learning cycle is pervasive in shaping culture. Much like driving at or below the speed limit as noted above. If there are no police to issue a ticket, the drivers learn to get to the destination faster flaunting death at 80 mph or 100 mph.
Business opportunities abound in Texas and anyone with enough access to capital can own a business. Capital does not mean they have a moral, law abiding, knowledgeable commitment to process safety.
We must continue to learn from unfortunate people like May Kay O'Conner, so we do not participate in these tragedies personally. Learn from others not by personal experience.
I do agree that regulations by themselves are insufficient. Thta is exactly I was saying to process safety practitioners from US (who I met at conferences in Australia). Their argument was that you cannot interfere with company freedom and how it wants to operate.All I trying to point out is that on one hand you have MKOPSC trying to educate people all over the world about process safety, yet in Texas these accidents / incidents keep happeing at a more regular frequency (at least in the last 5 years that I have noticed).
Here in Australia, our regulators rely on performance based application of the regulation and they do regular inspections to ensure that what was promised by the operating company is adhered to. Recently we had a coal mine gas explosion in Queensland (after nearly 15 years). In response to public outcry, the government will be including resources industry (mining & oil and gas - which were exempt) in the manslughter legislation. Now mine managers and owners can be sent to jail if they endanger workers.