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A 352 VOLUME 112 | NUMBER 6 | May 2004 • Environmental Health Perspectives

Environews Focus

Focus | Lessons Learned?

LessonsLearned?Chemical Plant Safety Since Bhopal

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Environmental Health Perspectives • VOLUME 112 | NUMBER 6 | May 2004 A 353

It was 3 December 1984, a quiet night in Bhopal, India, until acascade of catastrophic circumstances, system failures, and out-right negligence at the Union Carbide pesticide plant led to the

accidental release of approximately 40 metric tons of acutely toxicmethyl isocyanate (MIC). The dense cloud of deadly vapor spreadover the sleeping community. Estimates of immediate and long-termcasualties vary; the U.S. Chemical Safety and Hazard InvestigationBoard (CSB), an independent federal agency, cites more than 3,000people dying within a few days and at least 100,000 injured. Theevent is widely acknowledged to be the worst industrial accident inhistory, leaving as many as 50,000 people partially or totally disabledas of 1994, according to the International Medical Commission onBhopal. The incident also left a morass of civil and criminal litigationin its wake, as survivors continue their effort to recover what theyconsider to be appropriate compensation for their long-term painand suffering.

As the twentieth anniversary of the Bhopal incident arrives later thisyear, there inevitably will be a renewed focus on its impact on safetywithin the chemical industry worldwide. “Bhopal was a wake-up callfor the industry,” says chemical engineer Sam Mannan, director of theMary Kay O’Connor Process Safety Center at Texas A&M University,echoing the opinion of many experts in the field. Although it seemsclear that Bhopal has had a positive legacy in improved chemical plantsafety, particularly in the United States, to this day there is no single,reliable, quantifiable method to answer a very simple, reasonable, andvitally important question: How safe are chemical plants today, andare they really any safer today than they were 20 years ago?

“I wish somebody had a good solid finger on the pulse of chemicalsafety, but we really don’t have that in [the United States] right now,”says CSB toxicologist Gerald Poje. Mannan concurs: “It’s really impos-sible to answer the question ‘Are we doing better or worse?’ without

having data, without having statistics.” Of thatlack of data, he says, “I won’t hesitate to use theword ‘scandalous,’ because it is.”

The Advent of Process Safety

Despite the lack of a definitive, rigorousassessment of chemical safety in the UnitedStates, tremendous strides have been madeover the past 20 years in culture, practices,and attitudes in the chemical-handlingcommunity, as well as in the regulatoryenvironment that governs the industry. IfBhopal was a wake-up call, the call forongoing improvement in chemical safetyhas been answered in numerous ways bythe industry and many other stakeholders.Disparate groups withdiverse agendas areincreasingly finding waysto work together in aspirit of cooperation toreduce or prevent acci-dents, and to enhancethe protection of person-nel and the public alike.

Perhaps the mostimportant developmentin those efforts has beenthe widespread adop-tion of a concept calledprocess safety. Processsafety is a comprehen-sive, systematic approachencompassing the proac-tive identification, evalu-ation, and mitigation orprevention of chemicalreleases that could occuras a result of failures inprocess, procedures, orequipment. Althoughthe idea had been inexistence before Bhopal,it was the tragedy inIndia that brought aboutits complete acceptance as industry stan-dard practice, formalized in 1985 with thecreation of the Center for Chemical ProcessSafety (CCPS) by the American Instituteof Chemical Engineers.

The CCPS was founded by a group ofchemical companies that recognized theneed to establish a professional organizationdevoted to studying, supporting, andadvancing process safety. The CCPS hasevolved into a widely respected source ofknowledge and expertise in the area. CCPSdirector Scott Berger says the center’s statusas a professional organization lets workingon solutions remain the order of the day.“People can just check whatever politics theyhave at the door,” he says, “and talk likeengineers and managers about how to solvereal problems.”

The CCPS has published more than 100books and other information products sinceits inception. One of its most noteworthypublications was issued in 1989. Guidelinesfor Technical Management of Chemical ProcessSafety provided the industry with detailedguidance on how to incorporate the processsafety concept into its operations. The book

later served as a basis forfederal regulatory oversightof process safety.

At the Mary KayO’Connor Process Safety

Center, stakeholders in chemical process safetyare served through a variety of programs ineducation, research, and industry service. In1999, the center convened experts from indus-try, academia, government, and environmen-tal groups to undertake an ambitious effortcalled the National Chemical Safety Program.The program’s mission was to establish arational, objective baseline by which tomeasure the ongoing status of nationalchemical industry safety. It culminated inthe production of four reports, including the2001 Assessment of Chemical Safety in theUnited States.

The 2001 Assessment established aframework for prospective quantitativeassessment. It included suggested method-ologies for analyzing several existing feder-al databases to yield useful comprehensive

information on incidents, fatalities,injuries, and other parameters. It also pro-posed indicators and metrics for measuringchemical safety and presented the results ofan O’Connor center survey on public trustand community interaction.

The report provided some statistics aswell, but they are unavoidably limited in their

utility. For example, during the eight-yearperiod examined, fatalities and injuries due toall chemicals (as opposed to specific agents orclasses) decreased. But the National ChemicalSafety Program was unable to normalize itsfindings by correlating them to industrytrends during the period. “We knew on anabsolute basis [that fatalities] had gone down,”says Mannan, “but had the total volume ofwhat had been manufactured or processedgone down too, so the normalized numberswould have gone up? We don’t know. Had thetotal number of people working in the indus-try gone down as well? We don’t know.”

Despite its inherent limitations, the reportdid establish a baseline for future comparisons,and the intent was that the status of nationalchemical safety be assessed annually againstthat baseline. But the National ChemicalSafety Program was unable to secure contin-ued federal funding, and no one else has comeforward to provide the necessary support.Mannan still hopes the project will be revivedat some point, and is adamant about its

A toxic cloud’s silver lining? The 1984 accident at the Union Carbide plantin Bhopal released a toxic cloud that killed and injured thousands. The releasewas the impetus for an examination of chemical plant safety worldwide andan emphasis on safety measures that continues today.


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importance. “We are spending millions andbillions of dollars on these programs on theindustry side and the government side, andyet there’s no way of knowing what the [over-all status of national chemical safety] is,” hesays. “Somebody has to start doing meaning-ful data collection and analysis every year,” headds. “Only then will we know where we’regoing and how fast we’re going there.”

The Government’s RoleRegulatory oversight of process safety wascodified in 1990, when Congress passed theClean Air Act Amendments (CAAA) follow-ing Bhopal and several other serious domesticand international chemical plant incidents.The legislation has three major provisionsimpacting chemical safety and gave addedauthority to the Occupational Safety andHealth Administration (OSHA) and the U.S.Environmental Protection Agency (EPA) toregulate the chemical industry.

OSHA was directed to create, promulgate,and enforce the so-called PSM standard—Process Safety Management of Highly Haz-ardous Chemicals (29 CFR 1910.119). ThePSM standard emphasizes the management ofhazards through a comprehensive programthat integrates technologies, procedures, andmanagement practices. The standard has 16elements, 14 of which are mandatory. MikeMarshall, process safety management coordi-nator in OSHA’s Directorate of EnforcementPrograms, says the various management sys-tem elements are “fundamental to running asafe chemical operation.”

One key element mandated is the processhazard analysis (PHA), which OSHA’s PSMcompliance guidelines define as “an organ-ized and systematic effort to identify andanalyze the significance of potential hazardsassociated with the processing or handling ofhighly hazardous chemicals.” The PHA leadsto the development of operating, mainte-nance, and training procedures, along withemergency response and incident investiga-tion elements. Compliance audits are alsoincluded in the standard, ensuring that non-compliers will face legal consequences suchas citations or fines.

Today, the PSM standard is perhaps themain regulatory bastion against abuse or neg-ligence within the chemical industry thatcould lead to incidents, and has become a rou-tine part of doing business. “What we’ve seensince [implementation of] the PSM standardis that these industries have really evolved,”says Marshall. “It’s not just a concept on paper,and something that they should be doing, butthey as an industry have fully embraced theconcept now. They don’t see it as a regulationper se, but as good business practice.”

Glenn Erwin, a health and safety coordi-nator with the Paper, Allied-Industrial,

Chemical, and Energy Workers (PACE)International Union, agrees: “I think thePSM standard was one of the best thingsthat [the government] did. I think if appliedproperly, if applied within the spirit of howthe law was written, that it’s good for us anda good way to manage our business.”

The CAAA also directed the EPA to cre-ate its risk management program (RMP) rule(40 CFR 68), which requires companiesusing certain flammable and toxic substancesto develop an RMP that must be revised andresubmitted to the agency every five years.Whereas the PSM standard governs processsafety, the RMP rule is aimed more at protect-ing personnel and surrounding communitiesfrom the hazards associated with an accidentalrelease. It emphasizes hazard assessment andprevention measures, and requires the establish-ment of an emergency response program thatincludes procedures to inform the public andoutside responders in the event of an accident.

The third major provision of the CAAAaffecting chemical safety was the establish-ment of the CSB, which began its activitiesin 1998. Modeled on the National Trans-portation Safety Board, the CSB has the pri-mary responsibility for investigating majorchemical accidents at fixed facilities (asopposed to accidents involving transporta-tion). Upon completion of an investigation,the board issues a full report, includingexaminations of root causes and lessonslearned from the incident. While it does nothave the power to issue citations or fines, itdoes make detailed safety recommendationsto plants, industry organizations, laborgroups, and regulatory agencies.

As an independent federal agency, theCSB also goes beyond the scope of individual

investigations from time to time, issuingreports designed to focus wider attention onwhat it believes to be systemic problems inneed of attention. For example, its 2002 reportImproving Reactive Hazard Managementexplored concerns about chemical reactivityincidents. The paper contained controversialrecommendations that reverberate throughthe bureaucratic landscape to this day.

A Firestorm over ChemicalReactivity Hazards“Runaway” exothermic reactions—when achemical reaction produces heat more rapidlythan it can be removed from the system—areoften the cause of chemical plant catastrophes.Such was the case on 8 April 1998 at MortonInternational’s chemical plant in Paterson,New Jersey, when a production run ofAutomate Yellow 96, a dye used to tint petro-leum fuel products, spiraled out of control.The runaway reaction led to an explosion thatinjured nine workers and a fireball that rainedtoxic chemicals onto the nearby community.

Although the CSB had been in existencefor only a few months, the group had alreadydetected what they considered to be a verytroubling pattern in chemical plant incidents:runaway reactions in processes using combina-tions of chemicals that by themselves are notrated as highly reactive. The Morton incident,among others, triggered the CSB to conduct amajor two-year investigation into the role ofreactivity hazards in chemical plant incidents,which resulted in the September 2002 releaseof Improving Reactive Hazard Management.

CSB staff examined 167 serious chemicalreactivity incidents that occurred in theUnited States between 1980 and 2001, acci-dents that had caused 108 deaths, numerous

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Reaction and action. A 1998 runaway chemical reaction at the Morton International plant inPaterson, New Jersey, helped call greater attention to this particular industry hazard.

injuries, and hundreds of millions of dollars inproperty damage. The study found that morethan half of the incidents involved chemicalsnot covered by the OSHA PSM standard orthe EPA RMP rule, both of which containlists of chemicals specifically addressed in theregulations. Nor do the regulations addressthe issue of combinations of chemicals in spe-cific processes. According to the CSB, theseare major gaps in the regulatory framework,gaps the board has vigorously sought to fill.Among the 18 recommendations includedin the report, the board formally recom-mended that OSHA and the EPA expand

their regulations to include more compre-hensive coverage of reactivity hazards result-ing from process-specific conditions andcombinations of chemicals.

But some parties—especially OSHA—don’t agree that expanding regulatory coverageis the appropriate way to improve safety andprevent incidents. In the agency’s formalresponse to the CSB’s recommendations on 13November 2003, John Henshaw, the Depart-ment of Labor assistant secretary for occupa-tional safety and health, wrote that “OSHAhas not yet decided whether to amend thePSM standard,” citing the fact that the agencybelieves “there is no consensus on the part ofexperts on the best approach that should betaken with regard to reactivity hazards.”

While acknowledging that reactivity haz-ards are a serious problem, Henshaw explainedthat rather than expanding the PSM standard,OSHA prefers another approach. The agencyplans to increase outreach activities to enhanceawareness of the hazards associated with

chemical reactivity, and to enforce existingstandards related to chemical reactivitythrough the General Duty clause of the origi-nal 1970 Occupational Safety and Health Act,which gives the agency authority to governserious recognized hazards not covered by spe-cific OSHA regulations.

True to its word, OSHA has alreadybegun two new educational efforts. On 16March 2004 the agency announced its newHazard Communication Initiative, throughwhich it will develop materials to guide chem-ical manufacturers and importers in develop-ing material safety data sheets, conducting

employee safety training, and assessing pub-lished data to determine chemical hazards.And on 30 March 2004, OSHA announced anew alliance with the EPA, the AmericanChemistry Council (ACC), the CCPS, theChlorine Institute, the O’Connor center, theNational Association of Chemical Distrib-utors, and the Synthetic Organic ChemicalManufacturers Association (SOCMA) to edu-cate workers about chemical reactivity hazards.Alliance members will furnish the expertise forconducting reactivity hazard training at con-ferences and meetings as well as throughcourses offered by OSHA’s Training InstituteEducation Centers. Each member will alsodevelop and disseminate print and electroniceducational materials and tools on its website.

But the CSB remains convinced that reg-ulatory updates are critical if reactivity hazardsare truly to be combated. In a 4 February 2004retort to OSHA’s November memorandum,the board wrote that “Board members contin-ue to believe that the evidence compiled by the

CSB’s investigation strongly indicates that arevision of the standard is necessary. . . . Whilethe Board understands that making a decisionto move forward on a new standard or a majorrevision of an existing standard is difficult, wewere disappointed that your letter provided noindication of when a decision may be made,nor did it indicate what criteria OSHA willuse to arrive at that decision.” The board votedunanimously to formally characterize OSHA’sresponse as “Open—Unacceptable Response,”indicating that it will continue to seek actionfrom OSHA on its recommendations.

Another recommendation the CSB madein its report was that the CCPS completework on a book of guidelines for industrypractitioners regarding reactivity hazards.The CCPS did so shortly thereafter, releasingEssential Practices for Managing ReactiveChemistry Hazards in April 2003. In March2004, the CCPS entered into an agreementwith OSHA, the EPA, the ACC, andSOCMA to provide funding for the book tobe distributed on the Internet at http://info.knovel.com/ccps/ free of charge. The ACCalso plans to work with OSHA, the EPA, theCCPS, and SOCMA to push the informa-tion out more broadly within its member-ship and customer chain, and to customizethe material for specific audiences.

In contrast to the broader issue of chemi-cal safety, there is plenty of information onreactivity hazards, but it often is not in theright hands at the right times to prevent acci-dents. “One of the findings in the CSB reportwas that it wasn’t that there was a lack of infor-mation, but that people didn’t know how toaccess it and how to use it,” says DorothyKellogg, leader of the ACC plant operationsteam. “This alliance has been formed to helpaddress those fundamental findings in theCSB report.”

Although there is much praise for theCCPS’s book, the public–private partnershipscreated to widely disseminate it, and otherongoing professional outreach activities, someexperts think more needs to be done to ensureprevention of chemical reactivity incidents.Erwin says that although the CCPS does agood job and publishes excellent material,their recommendations are not mandatory,and there are no consequences to not follow-ing them. He feels strongly that regulatorymuscle is a necessary component. “There needto be the guidelines, then there needs to besome enforcement . . . and that’s where we dis-agree with the American Chemistry Council,”he says. “They think there doesn’t need to beany enforcement. You just put out the guide-lines, and we’re all good scouts, and everybodyfollows the rules. That’s just not the case.”

Erwin is also critical of OSHA’s stance onthe issue: “We’ve had enough incidents, we’vehad enough people killed, and it’s just not on


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this administration’s agenda. . . . From ourstandpoint, OSHA’s not going to do anything,and it needs to happen.”

Mannan disagrees. Although the O’Con-nor center has published around 50 papers onissues related to chemical reactivity, he insiststhat the science is not yet to a point where leg-islators can write a chemical reactivity regula-tion that would work or be enforceable. Hefeels that education and communication ofexisting knowledge will be more effective. Ofthe CSB’s 167 incidents, he says, the majoritycould have been addressed by very simplescreening techniques, already available in thepublished literature, that could work in mostchemical reactivity situations. “But people arejust not using them,” he says, “and no kind ofregulation is going to solve that unless you puta policeman in every plant.”

Despite the controversy, Poje remainsoptimistic about the situation. “One can’t con-front, as the board has to confront, deadlytragedies involving reactive hazards and believethat we can hold to the status quo,” he says.“And I can’t be negative in my projections ofthe future.” He cites action recently taken bythe New Jersey Department of EnvironmentalProtection as evidence that the tide is turningin favor of increased regulatory scrutiny. In2003, New Jersey added chemical reactivity tothe list of hazards that trigger risk manage-ment planning requirements under the state’sToxic Catastrophe Prevention Act. Poje says hehas pointed out to many of his colleagues,including those at OSHA, that New Jersey’spolicy decision “would be a wonderful way tostudy how one state has already enabled itselfto address reactive hazards in a fashion betterthan their regulation originally portended.”Whether New Jersey’s action will inspirebroader national policy remains to be seen.

Private Sector InitiativesAs the chemical industry and the govern-mental regulations that oversee it havematured, so has the industry’s appreciationof the importance of safety and its impact onboth the bottom line and the sector’s publicimage. “There’s no money to be made inaccidents,” says Kellogg. “We’re always look-ing for ways and tools to improve the safetyof our operations.”

The ACC, whose 140 member companiesrepresent approximately 90% of the nation’sproductive capacity for chemicals, points withpride to its Responsible Care program.Launched in 1988 when the ACC was stillknown as the Chemical Manufacturers Associ-ation, Responsible Care commits companiesto meeting specific environmental, health,safety, and security performance criteria as acondition of membership. In 2002, the ACCupdated the program, replacing its formerCodes of Management Practice with a new

framework called the Responsible Care Man-agement System (RCMS).

The RCMS strengthens the program’scommitment to continuous improvement,and implements tougher performancerequirements along with an independentthird-party verification process. “It requirescompanies to address process safety issuesthroughout the process,” says Debra Phillips,managing director of the program. “There is acontinuous improvement requirement builtin that companies audit and evaluate effec-tiveness, investigate incidents, have a systemin place to evaluate findings, extend thosefindings to other areas within their organiza-tion, and then build on that.”

To assure that these best practices are infact practiced, beginning this year each com-pany is required to submit information to theACC concerning 11 different performancemeasures, including environmental safety andhealth performance, security, product issues,and distribution practices. In an effort toincrease transparency and public accountabili-ty, a subset of the measures submitted by eachcompany will be made available to the publicin the near future.

Under the new RCMS, member compa-nies must also pass an audit conducted by atrained, independent third party. The audit isbased on detailed ISO 14001 technical speci-fications with additional specifications pulledfrom Responsible Care. It is designed to cer-tify that a company has implemented all theelements of the RCMS. Certification is apass/fail process, and passage is a condition ofmembership in the ACC.

Poje thinks such actions are an importantfactor in maintaining the integrity of the

overall system of safety. “We need to havesome degree of independent oversight to keepourselves rigorous in our approaches towardmanaging facilities that handle highly haz-ardous materials,” he says. “If you don’t havethat, you’re going to run the risk that a fewpeople will do the wrong thing even thoughthey know the right thing is mandated.” Thefirst round of RCMS certification audits isdue to be completed in September 2005.

The ACC also credits Responsible Carewith what it reports to be a dramatic improve-ment in employee health and safety in mem-ber companies. It cites a 16% improvement inoverall safety among member companyemployees in 2002 over the previous year, and

a 42% improvement since 1993. An ACCnews release of 5 August 2003 also stated thatbased on statistics gathered by the federal gov-ernment, workplaces at member companies in2001 were approximately four times safer thanthe combined average of all U.S. manufactur-ing industries and twice as safe as the chemicalindustry as a whole.

As the major labor union representingU.S. chemical workers, the PACE Inter-national Union in 1996 instituted its ownhealth and safety initiative, known as theTriangle of Prevention (TOP). Designed tobe a cooperative effort among the interna-tional union, local branches of the union,and corporate management, the three sidesof the triangle represent the critical elementsof the program: measuring and trackingincidents, systems of safety training, andunion leadership. According to Erwin, whois project director for TOP, the program is asystems approach to managing health and safe-ty in the workplace.C

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A process of identification.

The TOP program educates all employeesat participating facilities to recognize that allincidents are caused by systems failures in anyof six areas: design and engineering, mainte-nance and inspection, mitigation devices,warning devices, training and procedures, andhuman factors. Workers are trained to employan objective, rule-based, logic tree methodolo-gy to investigate incidents and determine rootcauses, as well as to arrive at specific solutionsto specific problems in order to prevent futureincidents and near-misses. The program alsouses a mechanism known as Lessons Learnedto share information among facilities, so thatsafety and prevention experience reaches oper-ators directly. “If we learn a lesson at one site,then we’ll post it on our website,” says Erwin.“All of our member [facilities] do at least twoLessons Learned a year. The ones that have thelowest rates and the safest plants are the onesthat do the most.”

Another important element of the pro-gram is the TOP Index, which measures afacility’s safety based not only upon rates ofcertain injuries that must be reported toOSHA (these rates are often viewed as a stan-dard index of industrial workplace safety), butalso upon the occurrence of a variety of inci-dents and near-misses, as well as actions takento fix or prevent problems identified to be rootcauses. Thus, it tracks, measures, and givescredit to constructive, positive change in theworkplace.

To Erwin, the index is a more accuratereflection of overall safety than simpleinjury reporting, and he says it is widelyaccepted by the facilities that participate inthe TOP program as a valid yardstick of

overall performance. He adds that althoughincidents have not been eliminated, theamount of human error leading to incidentshas been reduced; today the number-onecause of accidents is mechanical failure.

Poje praises the efforts of groups such asthe CCPS, the ACC, and the PACE Inter-national Union, but still feels that they don’tadd up to a comprehensive system to preventtragedies. “There has to be an awareness andan enthusiasm across the entire chemical-handling community for gaining the knowl-edge that needs to be had to operate safely,” hesays. “Any single professional organization,trade union, or groups of corporations areimportant pointers to the right direction, butthey are not substitutes for the whole of thechemical-handling community getting its acttogether and operating with the kind of safetythat everybody merits.”

What About the Chemicals?An assessment of the state of chemical safetymust, of course, take into account the chemi-cals themselves—the thousands of compoundsto which workers, transporters, and ultimatelythe public are often exposed. How much dowe know about these materials? Which are themost dangerous, and which are cause for lessconcern? What about long-term, chronicexposures? Is anyone’s finger on the pulse ofthis aspect of chemical safety?

Again, the answers are unclear. Althoughmuch is known about the chemicals in usetoday, much more remains to be discovered.And although a good deal of research is beingconducted on the risks associated with expo-sures, there is a surprising and disturbing lack

of even basic publicly available informationabout many of the chemicals most commonlyproduced in U.S. manufacturing facilities.

That situation came to light in the late1990s, when three studies—Toxic Ignoranceby Environmental Defense, the EPA’s Chem-ical Hazard Data Availability Study, and theChemical Manufacturers Association’s PublicAvailability of SIDS-Related Testing Data forU.S. High Production Volume Chemicals—allshowed that even basic screening-level data onhuman and environmental hazards were notavailable for most of the chemicals producedin large volumes in the United States. These“high production volume” (HPV) chemicals,which are defined as those produced inamounts exceeding 1 million pounds annual-ly, account for more than 90% of the totalvolume of chemicals manufactured and used.Toxic Ignorance noted that “the public cannottell whether a large majority of the highest-usechemicals in the United States pose healthhazards or not—much less how serious therisks might be, or whether those chemicals areactually under control.”

The three groups, having called attentionto this serious gap in knowledge, proceeded tojointly develop an initiative designed to fillthat gap. Launched in 1998, the HPV Chal-lenge Program is intended to develop andmake public basic hazard screening data on theapproximately 2,800 chemicals deemed at thattime to be HPV. It calls for individual manu-facturers to gather existing data and then spon-sor the research necessary to fill the remainingdata gaps for their HPV products.

The program adopted as its required dataelements the Screening Information Data Set(SIDS) of the Organisation for Economic Co-operation and Development. SIDS includestests for acute toxicity, chronic toxicity, devel-opmental/reproductive toxicity, mutagenicity,ecotoxicity, and environmental fate. The SIDSresults, while covering only a subset of all rele-vant health end points, will ultimately be usedas a screen to identify those chemicals in needof further research into their hazards.

The HPV Challenge Program is due to becompleted in 2005, and although there are stillseveral hundred “orphan” chemicals that werenot sponsored, officials are optimistic that thedeadline will be met for most HPV chemicalsand that the orphan chemicals will be addressedat some point. Perhaps the most important ele-ment of the program is the fact that all of theinformation will ultimately be made public inan Internet-accessible database. “The power ofinformation is really the essence of the pro-gram,” says Ward Penberthy, associate directorof the Chemical Control Division in the EPAOffice of Pollution Prevention and Toxics. “Thewhole premise is public availability of the data.”

Senior scientist Richard Denison ofEnvironmental Defense also sees public


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disclosure as the key to the program’s suc-cess. “That is where the rubber ultimatelyhits the road,” he says. “All of the playershave a vested interest or a reason to wantthis information to be made public: notjust the public, but industry players, gov-ernment officials, academics, purchasingofficials in companies, all of the people thatmight have an interest in understandingmore about the chemicals that they use orare exposed to, or the products that containthose chemicals.”

Although the data sets fall well short ofproviding comprehensive information aboutany particular chemical, the power of theproject will be to aid prioritization of furtherwork that needs to be done—which chemi-cals deserve more research, and which can beconsidered lower priority. “I think it willserve as a funnel to allow the targeting ofresources in academia, in government, inindustry, and in environmental organiza-tions, to focus on those chemicals that looklike they warrant the most scrutiny first,”says Denison.

Industry-Supported ResearchDespite the apparent dearth of knowledgeuncovered in the public domain by the origi-nators of the HPV Challenge Program, thereis obviously an enormous amount of researchinto chemicals and the hazards they representbeing conducted in governmental, academic,and industrial laboratories around the world.The chemical industry itself has long recog-nized its obligation to support research intothe potential impacts that chemicals may haveon the health of humans, wildlife, and theenvironment.

For over 25 years the ACC has supportedthe CIIT Centers for Health Research ofResearch Triangle Park, North Carolina, arespected facility in environmental healthresearch. More recently, in 1998 the ACCestablished the Long-Range Research Initiative(LRI), which awards research contracts toindependent third-party institutions through acompetitive request-for-proposals process. Theprogram, which as of 2003 consisted of 67active projects, focuses on three areas of partic-ular interest: methods (improving health andecological effects screening and testing, humanexposure testing methods, determinants ofdose response), susceptible populations(exploring differences in biologic sensitivityand exposure), and chemicals in the environ-ment (human exposure assessment and analy-sis, ecosystem exposure analysis).

The LRI actively seeks to support pro-grams that are complementary to or collabo-rative with organizations such as the NIEHSand the EPA. One such project commencedin 2001 with a memorandum of understand-ing between the ACC and the NIEHS. With

contributions of $1 million and $3 millionrespectively, 14 grants have been funded todevelop methods for understanding the poten-tial effects of chemicals on human reproduc-tion and fetal and childhood development.

So Where Are We?Industry, government, academia, and envi-ronmental groups are all doing their parts tofurther scientific knowledge about chemicalsin the production stream and the potentialhazards they represent in both acute andchronic exposures. Perhaps integrative meas-ures such as the HPV Challenge Program willindeed contribute significantly to prioritizingthose disparate efforts, so that risks can beminimized without compromising the unde-niable benefits that chemicals provide to oureconomy and to our society. As Denison putsit, “So much of the debate around chemicalsis based on either haphazard or piecemealinformation. . . . And the result has been thatwe sort of lurch from one problem to another,

or one chemical incident to another, ratherthan systematically tackling the problem in away that allows us to understand where thereal risks are, where we should be focusing themost attention.”

Are chemical plants and the chemicals theyproduce and use safer today than they were 20years ago, when Bhopal sounded its tragicwake-up call? No one can say for sure. Giventhe significant strides made over the past twodecades, there is a strong temptation to answerthat question at least tentatively in the affirma-tive. Attitudes have evolved, culture has pro-gressed, technologies have matured, and amore cooperative, collaborative atmospherehas emerged. There is ample reason for opti-mism. But as long as issues such as managingchemical reactivity remain unresolved, it seemslikely that the day when incidents are reducedto zero is still far away.

Ernie Hood


Toward Safer Chemical PlantsResponsible Care Management System (RCMS)WHO: American Chemistry CouncilWHAT: Member companies must submit information to the American Chemistry Council regarding 11 different per-formance measures, including environmental safety and health performance, security, product issues, and distributionpractices, and pass an independent audit to certify that they have implemented all the elements of the RCMS. WHERE: http://www.americanchemistry.com/

Long-Range Research Initiative (LRI)WHO: American Chemistry Council WHAT: LRI awards research contracts to independent research institutions in three areas: methods (improving healthand ecological effects screening and testing, human exposure testing methods, determinants of dose response), sus-ceptible populations (exploring differences in biologic sensitivity and exposure), and chemicals in the environment(human exposure assessment and analysis, ecosystem exposure analysis).WHERE: http://www.uslri.org/

Triangle of Prevention (TOP)WHO: Paper, Allied-Industrial, Chemical, and Energy Workers International UnionWHAT: TOP trains workers at union facilities to use an objective, rule-based, logic tree methodology to investigate inci-dents and determine root causes, as well as to arrive at specific solutions to specific problems, in order to prevent futureincidents and near-misses.WHERE: http://pacehealthandsafety.org/TOP/Main.htm

HPV Challenge ProgramWHO: U.S. Environmental Protection Agency, American Chemistry Council, Environmental DefenseWHAT: The HPV Challenge Program aims to gather and make public basic human and environmental screening haz-ard data including acute toxicity, chronic toxicity, developmental/reproductive toxicity, mutagenicity, ecotoxicity, andenvironmental fate on the approximately 2,800 chemicals deemed to be high production volume (HPV).WHERE: http://www.epa.gov/chemrtk/volchall.htm

Hazard Communication InitiativeWHO: Occupational Safety and Health AdministrationWHAT: The recently announced Hazard Communication Initiative will aid compliance with the agency’s HazardCommunication Standard through education on preparing material safety data sheets, developing employee safetyprograms, and translating published guidance into useful hazard communication materials.WHERE: http://www.osha.gov/SLTC/hazardcommunications/index.html

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