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Safety Recommendation Details

Safety Recommendation R-85-070
Details
Synopsis: AT 3:45 A.M., ON JULY 30, 1983, VINYL CHLORIDE MONOMER (VCM) UNDER PRESSURE ESCAPED FROM A RAILROAD TANK CAR AT THE LOADING FACILITY WITHIN THE FORMOSA PLASTICS CORPORATION (FORMOSA) CHEMICAL MANUFACTURING PLANT AT BATON ROUGE, LOUISIANA. THE RELEASED VCM WAS IGNITED BY AN UNDETERMINED SOURCE, AND A LARGE BILLOWING FIRE ENSUED. AN ADJACENT TANK CAR CONTAINING VCM WAS INVOLVED IN THE FIRE BUT DID NOT RUPTURE VIOLENTLY. TWO PERSONS WERE INJURED SERIOUSLY, TWO TANK CARS WERE DESTROYED, THREE TANK CARS WERE DAMAGED MODERATELY, AND THE LOADING FACILITY WAS DAMAGED EXTENSIVE LY. DAMAGE WAS ESTIMATED TO BE $1 MILLION.
Recommendation: THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION: ESTABLISH SAFETY STANDARDS AND INSPECTION PROCEDURES FOR LOADING FACILITIES AT PETROCHEMICAL PLANTS.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Alternate Action
Mode: Railroad
Location: Baton Rouge, LA, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA83AZ006
Accident Reports: Vinyl Chloride Monomer Release from a Railroad Tank Car and Fire, Formosa Plastics Corporation Plant
Report #: RAR-85-08
Accident Date: 7/30/1983
Issue Date: 6/17/1985
Date Closed: 12/20/1993
Addressee(s) and Addressee Status: RSPA (Closed - Acceptable Alternate Action)
Keyword(s): Tank Car Loading and Unloading, Hazmat

Safety Recommendation History
From: NTSB
To: RSPA
Date: 12/20/1993
Response: THE BOARD NOTES THAT RSPA PUBLISHED REGULATIONS UNDER DOCKET HM-126F THAT REQUIRE TRAINING FOR ANY EMPLOYEE INVOLVED IN ANY ASPECT OF THE TRANSPORTATION OF HAZARDOUS MATERIALS, INCLUDING CARGO TRANSFER OPERATIONS, UNDER THESE REGULATIONS, EMPLOYEES MUST RECEIVE TRAINING ABOUT ANY JOB-RELATED ACTIVITIES INVOLVING THE TRANSPORTATION OF HAZARDOUS MATERIALS. ALSO, THE REGULATIONS OF THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION CITED IN YOUR LETTER SHOULD PROVIDE A FRAMEWORK TO ENHANCE THE DEVELOPMENT AND IMPLEMENTATION OF SAFETY STANDARDS FOR LOADING AND OFFLOADING OPERATIONS. THE BOARD AGREES THAT THESE REGULATIONS MEET THE OBJECTIVE OF RECOMMENDATION R-85-70, AND THEREFORE IT IS CLASSIFIED AS "CLOSED--ACCEPTABLE ALTERNATE ACTION.

From: RSPA
To: NTSB
Date: 10/21/1993
Response: RSPA HAS LOOKED AT MANY OPTIONS TO IMPROVE SAFETY IN TANK CAR LOADING OPERATIONS AND BELIEVE THAT THE MOST EFFECTIVE STRATEGY IS TO 1) SPECIFY THE EMPLOYER AND EMPLOYEE TRAINING REQUIREMENTS FOR CRITICAL FUNCTIONS RELATING TO THE TRANSPORTATION OF HAZ MAT (INCLUDING THE LOADING PROCESS ) AND 2 UTILIZE SAFETY REGULATIONS PUBLISHED BY THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) WHICH REQUIRE HAZ MAT EMPLOYERS TO DEVELOP AND IMPLEMENT SPECIFIC SAFETY LOADING STANDARDS AND PROCEDURES. IN MAY 1992, ESPA PUBLISHED A FINAL RULE UNDER DOCKET HM-126F WHICH PLACES THE RESPONSIBILITY ON EACH HAZ MAT EMPLOYER TO TRAIN IT HAZ MAT EMPLOYEES REGARDING SAFE LOADING, UNLOADING, HANDLING, STORING, AND TRANSPORTING OF HAZARDOUS MATERIALS AND EMERGENCY PREPAREDNESS FOR RESPONDING TO ACCIDENT INVOLVING THE TRANSPORTATION OF HAZARDOUS MATERIALS. THE REGULATIONS (49 CFR 172.700) REQUIRE A SYSTEMATIC TRAINING PROGRAM THAT ENSURES THAT EACH HAZ MAT EMPLOYEE HAS FAMILIARITY WITH THE TRAINING REGULATIONS, IS ABLE TO RECOGNIZE AND IDENTIFY HAZARDOUS MATERIALS, HAS KNOWLEDGE OF THE SPECIFIC REGULATORY REQUIREMENTS APPLICABLE TO THE FUNCTIONS PERFORMED BY THE HAZ MAT EMPLOYEE, AND HAS KNOWLEDGE OF THE RELATED EMERGENCY RESPONSE INFORMATION. UNDER OSHA REGULATIONS (29 CFR 1910.119; PROCESS SAFETY MANAGEMENT OF HIGHLY HAZARDOUS MATERIALS), EMPLOYERS ARE REQUIRED TO PROVIDE WRITTEN REQUIREMENTS AND STANDARDS FOR CRITICAL PROCESSES, TO PREVENT OR MINIMIZE THE CONSEQUENCES OF CATASTROPHIC RELEASES OF TOXIC, REACTIVE FLAMMABLE, OR EXPLOSIVE CHEMICALS. UNDER THE REGULATIONS, THE EMPLOYERS MUST DEVELOP AND IMPLEMENT 1) WRITTEN OPERATING PROCEDURES FOR EQUIPMENT, 2) WRITTEN PROCEDURES TO MAINTAIN THE ONGOING INTEGRITY OF THE EQUIPMENT, 3) INSPECTION AND TESTING REQUIREMENTS, AND 4) A BLOCK FLOW DIAGRAM OF THE PROCESS INVOLVED (E.G., LOADING PROCESS).

From: NTSB
To: RSPA
Date: 6/21/1993
Response: OUR RECORDS SHOW THAT WE HAVE NOT RECEIVED ANY FURTHER RESPONSE FROM THE RSPA REGARDING THESE RECOMMENDATIONS. WE WOULD APPRECIATE BEING INFORMED ABOUT EFFORTS THAT HAVE BEEN OR ARE BEING MADE TO IMPLEMENT THESE RECOMMENDATIONS.

From: NTSB
To: RSPA
Date: 11/13/1987
Response:

From: RSPA
To: NTSB
Date: 7/22/1987
Response: WE BELIEVE THAT OUR LETTER OF MARCH 27, 1987 WAS RESPONSIVE TO R-85-70 AS STATED AND ARE CONCERNED THAT YOU NOT ONLY CLASSIFIED OUR ACTION AS "OPEN--UNACCEPTABLE ACTION" BUT BROADENED THE SCOPE OF THE RECOMMENDATION TO INCLUDE MULTI MODAL ACTIVITIES. YOUR STATEMENT OF THE RECOMMENDATION IS VERY BROAD AND VAGUE AND WE DO NOT BELIEVE THAT IT CAN BE INTERPRETED TO INCLUDE WATERSIDE FACILITIES IN ORDER TO CLASSIFY IT AS A MULTIMODAL RECOMMENDATION. THE ACCIDENT AT THE FORMOSA PLASTICS FACILITY IN BATON ROUGE, LOUISIANA WAS COMPLETELY RAIL-RELATED AND YOUR INVESTIGATION REPORT WAS STRONGLY RAIL-ORIENTED. THE ONE BRIEF REFERNECE TO MARINE FACILITIES WAS AN EXAMPLE TO SHOW COAST GUARD AND OCCUPA TIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) COOPERATION IN YEARLY WATERSIDE FACILITY INSPECTION. YOU ALSO USED THE IDENTIFICATION CODE LETTER "R" WHICH IDENTIFIES A RAIL RE COMMENDATION INSTEAD OF THE LETTER "I" COMMONLY USED FOR INTERMODAL OR MULTIMODAL ACCIDENTS. THERE ALSO WAS NO IN DICATION IN YOUR LETTER THAT SAFETY CONDITIONS AND INSPEC TION PROCEDURES AT WATERSIDE PETROCHEMICAL LOADING FACILI TIES WERE A SERIOUS PROBLEM. ACCORDINGLY, WE FEEL THAT OUR RAIL FACILITY APPROACH TO THE RECOMMENDATION WAS CORRECT AND SHOULD NO BE BROADENED TO INCLUDE MULTIMODAL CONSIDERATIONS. IN ADDITION, OUR INVESTIGATION CONCERNING THE MULTIMODAL IS SUE CONCLUDES THAT EFFECTIVE AND RESPONSIVE SAFETY STANDARDS AND INSPECTION PROCEDURES FOR WATERFRONT LOADING FACILITIES AT PETROCHEMICAL PLANTS HAVE BEEN ESTABLISHED BY THE COAST GUARD. WE HAVE REVIEWED TITLE 33, PART 126 (HANDLING OF EXPLOSIVES OR OTHER DANGEROUS CARGOES WITHIN OR CONTIGUOUS TO WATERFRONT FACILITIES); PART 154 (OIL POLLUTION PREVEN TION REGULATIONS FOR MARINE OIL TRANSFER FACILITIES); AND PART 156 (OIL AND HAZARDOUS MATERIALS TRANSFER OPERATIONS) WHICH SET FORTH THE SAFETY REGULATIONS FOR LOADING AND UN LOADING WATERSIDE OPERATIONS. WE HAVE ALSO DISCUSSED THEIR ADEQUACY AND APPLICABILITY TO PRESENT TECHNOLOGY AND OPERAT ING PRACTICES WITH THE COAST GUARD AND ARE MORE THAN SATIS FIED THAT IT IS NOT NECESSARY TO CHANGE OR EXPAND THEM TO ACHIEVE THE GOALS OF YOUR RECOMMENDATION. INSPECTION PRO CEDURES FOR LOADING FACILITIES WERE ALSO DISCUSSED WITH THE COAST GUARD. THEIR "MARINE SAFETY MANUAL" HAS A SEPARATE CHAPTER WHICH COVERS ALL ASPECTS OF INSPECTION PROCEDURES AT WATERFRONT FACILITIES. IN ADDITION, THE COAST GUARD CON DUCTS A SEVEN-WEEK PORT OPERATIONS COURSE AND A FIVE-WEEK PETTY OFFICERS COURSE AT THEIR MARINE SAFETY SCHOOL IN YORKTOWN,VA, WHICH, AMONG OTHER THINGS, TRAINS INSPECTORS IN THE REGULATIONS AND INSPECTION PROCEDURES NECESSARY TO EN SURE THE SAFE OPERATION OF LOADING FACILITIES AT PETROCHEMI CAL PLANTS. THE COAST GUARD BELIEVES THAT THEIR MARINE SAFETY MANUAL AND THE RELATED INSPECTOR TRAINING PROGRAM ARE COMPREHENSIVE AND RESPONSIVE TO THE "REAL WORLD" OPERATIONS AT PETROCHEMICAL LOADING FACILITIES AND DO NOT NEED TO BE CHANGED OR EXPANDED. AS REGARDS SAFETY STANDARDS FOR RAIL TANK CAR LOADING FACILITIES AT PETROCHEMICAL PLANTS, THE FEDERAL RAILROAD ADMINISTRATION (FRA) HAS AN ONGOING PROJECT TO REWRITE 49 CFR, PART 174, "CARRIAGE BY RAIL," AS STATED IN OUR LETTER OF MARCH 27, 1987. THIS PROJECT, WHICH WAS INITIATED IN 1986, WILL LEAD TO PROPOSALS TO REVISE SUBSTAN TIAL PORTIONS OF PART 174. THE STANDARDS FOR TANK CAR LOAD ING AND UNLOADING WILL BE INTEGRATED INTO ONE SECTION AND MOVED TO PART 173.31. THESE PROPOSED REQUIREMENTS WILL BE PUBLISHED ALONG WITH THE OTHER PROPOSED REVISIONS BY THE END OF THE YEAR. FRA HAS PUBLISHED A HAZARDOUS MATERIALS EN FORCEMENT MANUAL, DATED 1983, WHICH ESTABLISHES ROUTINE IN SPECTION REQUIREMENTS AND SPECIFIES THAT THE "INSPECTOR SHOULD DETERMINE WHETHER...THE SHIPPER OR CONSIGNEE IS IN SPECTING, LOADING, UNLOADING, AND PLACARDING TANK CARS IN CONFORMITY WITH SECTIONS 173.31 AND 174.67" OF THE REGULA TIONS. WE WOULD ALSO LIKE TO POINT OUT THAT IT IS NOT WITH IN RSPA'S JURISIDICTION TO ESTABLISH INSPECTION PROCEDURES FOR OTHER FEDERAL AGENCIES AS SUGGESTED BY THE NTSB. IN LIGHT OF THE EXTENSIVE ACTIONS DISCUSSED ABOVE, RSPA BELIEVES THAT RECOMMENDATION R-85-70 SHOULD BE RECLASSIFIED AS "OPEN-ACCEPTABLE ACTION" PENDING PUBLICATION OF FRA'S REVISIONS TO PARTS 173 AND 174 OF 49 CFR.

From: NTSB
To: RSPA
Date: 5/11/1987
Response:

From: RSPA
To: NTSB
Date: 3/27/1987
Response: RSPA HAS REVIEWED THE HAZARDOUS MATERIALS REGULATIONS THAT APPLY TO LOADING FACILITIES AT PETROCHEMICAL PLANTS AND HAS DISCUSSED INSPECTION PROCEDURES WITH THE FRA. REQUIREMENTS PERTAINING TO THE LOADING AND UNLOADING OF RAIL TRANSPORT VEHICLES ARE SPECIFIED IN 49 CFR PART 174. WE AGREE THAT FURTHER REFINEMENT OF THE REGULATIONS PERTAINING TO THE OPERATION OF LOADING AND UNLOADING FACILITIES WOULD LEAD TO IMPROVEMENTS IN THEIR SAFE OPERATION. WE HAVE DISCUSSED THIS MATTER WITH THE FRA STAFF MEMBERS WHO ARE DEVELOPING A PROPOSAL TO AMEND 49 CFR, PART 174 WITH THIS GOAL IN MIND. FRA CURRENTLY HAS COMPREHENSIVE INSPECTION PROCEDURES FOR LOADING AND UNLOADING FACILITIES BASED ON THE STANDARDS SPE CIFIED IN THE REGULATIONS, AND EXPERIENCE SHOWS THAT THESE INSPECTION PROCEDURES HAVE BEEN EFFECTIVE DURING RECENT YEARS. TO ENSURE THAT SIMILAR ACCIDENTS AT PETROCHEMICAL FACILITIES WILL NOT HAPPEN IN THE FUTURE, THE FRA HAS BEEN CONDUCTING A SERIES OF INTENSIVE TEAM INSPECTIONS AT PETRO CHEMICAL FACILITIES. THE LAST SUCH ACTION INTENSIVE TEAM INSPECTIONS AT PETROCHEMICAL FACILITEIS. THE LAST SUCH AC TION TOOK PLACE IN HOUSTON, TEXAS IN OCTOBER OF 1986. AN OTHER EN MASSE INSPECTION IS PALNNED AT A DIFFERENT LOCATION FOR EARLY 1987.