On August 4th, 2020, a massive explosion destroyed the port and devastated much of the city of Beirut, Lebanon, located on the Mediterranean Sea. While only preliminary reports exist as of press time, indications are that the blast may have been the result of the detonation for causes yet to be determined of up to 2,750 tons of ammonium nitrate, which as a highly explosive component of many agricultural fertilizers is classified as a Class 5 Oxidizer.
According to current news reports, the chemical had allegedly been stored in a seaside warehouse for up to six years following its reported confiscation from a vessel which was detained for administrative reason in the port of Beirut and was subsequently abandoned by its owners. As with many chemical substances, ammonium nitrate can deteriorate, becoming less stable over time, and the warm climate and humid conditions found in a typical Mediterranean port town would only tend to exacerbate that. Initial reporting indicates that the physical damage to the city is extreme, with attendant high casualty rates among its inhabitants. Video of the event and its immediate aftermath is ample testimony to the power that was unleashed. Such tragedies are sadly not unique in the industrial sector, although this one stands out for its vast magnitude. As such, as dangerous goods professionals it behooves us all to remember that our responsibility extends beyond safety of transport to also accounting for correct storage and handling of many of the hazardous commodities we deal with on a routine basis. Fortunately, the regulatory structure provides guidance in this regard.
In the United States, storage of hazardous materials is governed on both the national and local levels by both regulation via OSHA and, if RCRA regulated hazardous waste, the EPA, as well as by code compliance requirements through locally governed fire codes. OSHA governs the activity under 29 CFR 1910 Subpart H. Here’s a link to Labelmaster’s offering of the regulation:
EPA governs the accumulation and disposal of hazardous waste in 40 CFR Parts 260-265:
Fire Codes are governed by local municipalities on the city, county, and township levels, depending on the particular location and circumstance of government. However regardless of the unit of government with authority, one of two code standards are in use; either the International Fire Code (IFC) of the National Fire Protection Association (NFPA) Standard #1.
IFC intro: https://codes.iccsafe.org/content/IFC2018
The OSHA regulations are relatively general in nature and provide a structure for using what one might consider to be common sense ways of limiting potential danger when storing and handling various hazardous commodities. In contrast, the fire codes, regardless of which of the two primary US codes are in use in any given location, provide extremely detailed information placing limits on both the type and amount of storage permissible in various types of buildings based on the their municipal zoning. These codes also stipulate the type and performance requirements of associated fire protection systems, ingress and egress routes, spill control measures, incident response requirements, and a bevy of other associated ancillary requirements that may impact the buildings electrical, HVAC, and other mechanical infrastructure. They also stipulate some related employee training and emergency response organization notification measures. EPA regulations governing hazardous waste fall into something of a middle ground between those two levels of structure, with detailed rules for accumulation and marking, but less intensive focus on specific conditions of storage prior to disposal. It is important to remember that any commodity stored will always be subject to the regulations and codes in place at all levels; if as an example one is storing a flammable hazardous waste, then one will be subject to both the EPA and OSHA requirements attendant to that storage as well as to the provisions of the local fire code applicable. So, DG professionals must have a working knowledge of all relevant governing regulatory and code language.
Regardless of the type of storage and handling necessary, there are some routine guidance measures that will help ensure safety in any case. Here are a few ideas that one should keep in mind when addressing this activity:
- As noted above, be aware of which regulations and codes the site and its activity is subject to and work to implement them
- Ensure any necessary registrations and or permits are in place; unless the storage amount is tiny, it’s very likely there are at least some attendant permit and registration requirements
- Verify that the site is provided with adequate physical security and visitor handling processes
- Provide applicable training to your employees
- Prevent the storage of hazardous commodities in amounts that exceed the site’s permitted maximums
- Periodically review storage to ensure that commodities are not stored in ways that may make them more hazardous than they need to be; for instance, the storage of oxidizers and flammables in proximity to each other or near heat sources, etc.
- Maintain the site’s fire suppression and mechanical infrastructure at least to the level required by the applicable fire code directives
- Remember that a clean, well-organized site is always inherently more safe than a dirty, cluttered one
- Maintain a friendly, cooperative relationship with local emergency response officials; the fire marshal or code enforcement office can be a huge ally if viewed as a helper rather than as an adversary
- Promote the safety culture and praise employees who proactively embrace it
Taken in concert with a healthy regard for and implementation of the regulatory and code requirements that formally govern the site, the above helpful hints can go a long way towards making industrial workplaces safer, help protect the employees that work there, and shield the community that surrounds them from the potentially devastating results witnessed in the Beirut explosion.
That’s all a big task. Transporting dangerous goods compliantly is tough enough; understanding and working to implement these other requirements just adds to it. Fire codes in particular can be a somewhat arcane topic if for no other reason that the widely variant requirements that can be imposed on users on a municipality to municipality basis. Fortunately, help is available! Labelmaster Services, our team of DG consulting experts, is equipped to help with this set of needs as well as assisting with transport issues. If you have facilities that need help with fire code analysis, strong limits, OSHA regulations, or the EPA waste world, then it’s almost certainly something a Labelmaster Services consultant can help with. Keep us in mind as a resource! Here’s a link for more information:
Meanwhile; stay safe, review your workplace’s current storage situation and the permits, processes, and procedures necessary to do it safely, and keep in mind that the difference between a normal workday and an unspeakable tragedy often comes down to giving proper attention to the routine but vital details of site safety—“it’s never happened here” is only true until it does happen. Work to prevent that at your facility. Never be complacent.
Labelmaster is a full-service provider of products, shipping and training software, and professional consulting services to assist the DG and HS&E professional to comply with national and international regulations. See our full line of solutions at www.labelmaster.com