Q: Could you provide some thoughts on Hazardous Production Materials (HPM)?
A: “Our technological powers increase, but the side effects and potential hazards also escalate.” ~Alvin Toffler
The residents of Bhopal, India will never forget early December, 1984 when a cloud of methyl isocyanate (MIC) gas seeped from the Union Carbide chemical plant. The government pegs the immediate death toll at 3,787, with more than 500,000 injured, disrupting health, the community, and the economy for decades. It’s estimated 8,000 died within two weeks, while another 8,000 deaths followed later from related diseases. The Indian government estimates almost 4,000 of those injured struggle with permanent disabilities.
What was behind this mass disaster? The list of contributing causes reads like a course book in Facilities Negligence 101: non-functioning safety systems and vent gas scrubbers, an out-of-order steam boiler that cleaned pipes, MIC stored tanks filled well above regulated levels, and corroding non-stainless steel pipelines producing rust that, in the end, only accelerated the toxic reaction. Bottom line: a side pipe missing its slip-blind plate allowed water to enter a tank overfilled with 42-tons of MIC, creating a chain reaction. Inside an hour, 30 metric tons of MIC escaped into the atmosphere.
For a controlled environments facilities engineer, hazardous production materials are not the things that dreams are made of—but proper regulatory compliance and handling during the production process are cornerstones of the job. HPM management—and the plant maintenance that supports HPM—require constant attention.
The International Code Council (ICC) defines hazardous production materials as, “A solid, liquid or gas that has a degree of hazard rating in health, flammability or reactivity of Class 3 or 4 as ranked by NFPA 704 listed in Chapter 44 and which is utilized directly in research, laboratory or production processes that have, as their end product, materials that are not hazardous.”
The responsibilities of the facilities engineer regarding HPM extend from materials ordering and storage through internal distribution, manufacture, disposal, and reporting. HPMs are among the most highly regulated substances in the world, with Federal, state, and local regulations producing a puzzle of ever-changing and sometimes conflicting requirements.
Depending on your organizational structure, the facilities group may be responsible for the complete range of HPM management, or the responsibilities may be segregated between procurement, purchasing, legal, health & safety, manufacturing, and facilities. While segregating responsibilities can ensure that highly focused specialists are in control of the HPMs throughout the chain of use, it’s critical that seamless and constant attention be given to coordination between the individuals along the chain of responsibility.
Some key considerations
The role and proper handling of HPMs are among the most complex challenges any facilities engineer will face—and failure to properly execute can result in injury, death, your organization’s loss of reputation, tremendous financial loss and, if a publicly traded company, a black mark on the organization’s reputation that is impossible to recover from.
There is no clear cut “recipe for success” when dealing with HPMs, but here are a few rules for the road gleaned from my experiences handling these substances both as a facilities engineer in manufacturing and as a consulting engineer at SMRT Architects and Engineers:
1. Regulations rule
The world of HPM is governed by rules that are complicated, convoluted, and constantly changing. And if your facilities exist in different cities, states, or countries, you should expect different regulatory requirements for each facility.
Regulations cover every aspect of HPM usage, from limitations placed on quantities that can be ordered by your purchasing group to disposal. Regulations will vary for different chemicals, and also floor-by-floor for the same chemical depending on whether its storage and/or use will take place on the ground floor or three stories up. Regulations will vary depending upon the manufacturing process.
It may feel like there are more regulations for HPMs than stars in the universe, but there are compelling reasons for this: Hazardous Production Materials kill. Pay attention.
2. What you know is true today, won’t be true tomorrow
As new production processes are developed, new production lines are ramped up, new HPMs are added to the research or manufacturing underway at your facility, and new regulations are adopted, what you know today won’t be true tomorrow. Never assume you know – always double check. “Only asses assume” – don’t become a donkey.
3. Don’t be shy, get help
The constantly shifting sands of HPM management – fueled by the dual challenges of evolving production processes and changing regulatory requirements – make the challenge of keeping current almost a full time job. Don’t be shy; develop a strong relationship with a consulting engineer you trust and use that person consistently.
This is one area where keeping your consulting engineer on speed-dial is a smart move. And make sure your speed-dial directory includes your engineer’s cell number. HPM driven problems can erupt at any hour.
There’s a business strategy to outsourcing this initiative as well: it’s called shifting the liability. By shifting, and clearly delineating the responsibilities to your consultant, a significant amount of professional liability will reside behind the professional engineer’s seal.
4. “It’s not Operations’ job”
Don’t assume that the professionals in manufacturing operations understand the regulations. Their job is to get the product manufactured, and you may often find yourself caught between the rock (manufacturing) and the hard place (regulatory requirements). You will have days when Operations needs X quantity of an HPM yesterday, and that quantity exceeds allowable limits. An order from Operations is not infallible. Deadlines purported by Operations or pressure from end customers are not reasons to by-pass the rules.
5. Maintenance is Job #1
Think Bhopal. A side pipe missing its slip-blind plate? Corroded, non-stainless steel pipes? An out-of-order steam boiler? These are the everyday things that nightmares are made of.
6. Education must be current, comprehensive, and constant
HPMs carry too much risk to skimp on education at all levels of the organization – from management to the newest manufacturing team member. Develop a program, in concert with departments as appropriate to your organization, and diligently drive its execution. Depending on your organization, departments that should be actively involved in developing your education program may include operations, finance, health & safety, security, communications, and legal. You may need to call in outside experts and thought leaders to fill the gaps – don’t hesitate.
7. Document, document, document
The documentation of HPM handling and usage is highly regulated and must be executed in a timely manner. Your work plans must place a high priority on this effort.
8. Top-down advocacy is critical
The president/CEO and the board of directors must be advocates of proper HPM handling, and ongoing facility maintenance. If they aren’t, I’d suggest a career change.
Sound HPM management is, in one respect, everyone’s business. But the facilities engineer needs to step up and ensure all aspects of this challenge are addressed.
Richard Bilodeau, PE, is director of engineering at SMRT Architects and Engineers (www.smrtinc.com). His 30 year career includes plant engineering positions in clean manufacturing. Richard has engineered, designed, operated, and supervised the construction of numerous controlled environments and labs for advanced technology, life sciences, industrial, healthcare, academic, and corporate clients. Dick can be reached at:email@example.com or TheFacilitiesGuy@smrtinc.com
This article appeared in the September 2014 issue of Controlled Environments.