In case any of my dear colleagues in the blogosphere are in the market for a lead brasserie or heavy metal codpiece, there is one supplier of goods meant to protect those delicate regions from radiation. By way of style, I’d put the design in the 19th century Amish or Mormon settler category. But, that is beside the point. This habillement de mode de plumbum [thanks BabelFish!] is meant to protect the more tender regions from ionization.
Sunday evening on 60 Minutes on CBS there was a segment on dust explosions. For the most part, it was an expose on the failings of OSHA. It is hard to avoid the conclusion that OSHA is lead by a bunch of dullards who are under the enchantment of an administration reluctant to impose new regulations on industry.
The thrust of the program was that OSHA is completely unable to recognize incipient dust hazards on their site inspections, partly due to a lack of training and partly due to a slack-jawed lack of direction. It wasn’t pretty.
As a dramatic backdrop, numerous instances of major plant explosions were trotted out for all to see. The message is that plants keep blowing up from dust explosions, but OSHA isn’t holding companies to higher standards- because there aren’t any. The Secretary cited OSHA’s housekeeping requirement as broad enough to cover the dust explosion scenario. It was less than convincing.
I couldn’t help but notice that the subtext was that there can only be safety if more regulations were written. I didn’t see any company officials grilled in the same manner that the Secretary was grilled.
In fairness to OSHA, someone needed to clarify just what that agency is free to do in regard to rule making and what must be done by the Congress. I know there are smart people in OSHA, but being federal employees, there is little incentive to champion new regulations. Between institutional inertia, lobbyists, and an antagonistic executive branch, who wants to charge ahead of the parade on new rules?
In my career in the fabulous world of industrial chemistry, I have had to drop my pants exactly twice in the cause of business. The first and best time was in Japan. We had just been to the science city of Tsukuba near Tokyo. After driving all day in Tokyo traffic and shuffling around at business meetings in comically small sandals, we finally ended up at what I thought was a restaurant. Glad to get out of the car, I followed my running host through the rain and into a stone building out in the countryside. But instead of walking into a dining area, we walked straight in to a locker room!
I was about to protest that I didn’t have a swim suit when it dawned on me that birthday suits were the standard dress wherever we were going. Hmmm. Lordy, I wonder if this is co-ed? Gaijin anatomy would be the featured attraction this evening.
We padded out, barefoot and naked, into a covered outdoor area and straight into the heated pool. It was delightful. We soaked for 45 minutes and talked about business and life in Japan. All too soon, we got out, showered, dressed, and entered the dining area.
We took our positions on the cushions on the floor by the table and were treated to an incredible meal of exotic food and drink. It was highly civilized, relaxing, and memorable experience.
The next experience is the one time I had to go home without my pants. Some years ago I was making about a kg of some material in a 12 L flask. The reaction proceded normally and all was well until I tried to disassemble the apparatus in preparation for a filtration. The flask slipped from the clamp due to the considerable weight of the halide and dropped a few inches onto the benchtop. The flask broke, discharging the contents onto the hood benchtop. I can’t say what was in the mixture, but I can say that the solvent and residual halogen were absolutely the least of my worries.
It didn’t take long for me to realize that this was beyond my ability to safely handle without a Hazmo suit and supplied air. Somehow, in the course of this, I got a smudge of reaction mixture on my pants. The safety manager looked at me and ordered me to remove the contaminated pants, which I did.
So there I was, standing in my boxer shorts- the ones with the orange and green watermelon print- while the safety manager was standing there shaking his head laughing. He threw a tyvek bunny suit at me and walked out.
We discontinued the reaction after that event. The hazards were just too edgy, even for me.
Th’ Gaussling holds a peculiar view of the theory of the universe. In addition to quantum physics and the big bang, I maintain that the universe will continue to exist until every ridiculous circumstance that can exist eventually does exist.
Accordingly, Th’ Gaussling is personally responsible for ratcheting the universe a few notches closer to its eventual doom. That is my frank admission. Here are a few examples:
Exhibit 1. Forklift-Boat Collision. As a young lad I spent a great deal of time at our family business. My father and grandfather had a metal fabricating company that specialized in the manufacture of farm implements. As a result, the precocious young Gaussling learned to use power tools at a very early age. By age 12 I could perform arc, gas and spot welding; operate a variety of brake presses and heavy duty shears; layout; a small amount of blacksmithing; and operate a fork lift.
One day inside the plant the 13-year old Gaussling was joy riding on the propane powered forklift. The rear wheel steering with its short wheel base assured that the machine could turn on a dime, but it could be prone to over-steer in the wrong hands.
This day, turning around a corner just a bit too fast in youthful zeal I over-steered the turn and promptly over-corrected my recovery.
Unfortunately, the Pauli Exclusion Principle puts strict limits on how particles can occupy a given space and, as a result, the boat that was sitting on its trailer in the space I intended to occupy underwent an elastic Newtonian collision with the forklift. The boat appeared as though it would tip over from this collision, but for some reason it rocked violently and returned to ground state. All was well, except for a meter long gash in the trim of the boat.
Exhibit 2. Airplane-Dog Near-Collision. The clouds were scattered and the winds were light and variable. Th’ Gaussling was shooting touch-and-goes solo at the local airstrip flying a left-hand pattern on runway 29. Abeam the numbers on the downwind leg about 800 ft AGL I pull on the carburetor heat, chop the power to 1600 rpm, drop 10 degrees of flaps, and trim the airplane for 60 kts. This is the transition from flying machine to sinking machine.
“Longmont Traffic, Cessna 714 Yankee Bravo turning base for two niner.”
As I rolled onto base, I drop another 10 degrees of flaps, cut the throttle to about 1200 rpm, and dial in a bit more nose down trim. Things happen fast in the landing phase of flight and as soon as you get onto base you have to prepare to roll out onto final approach.
My favorite part of flying is landing. It is like ballroom dancing. The airplane becomes a part of the pilot and the two must deftly and with fluid-like motion arrange to kiss the wheels onto the ground.
Coming over the fence I chop the power to idle, and rely on my peripheral vision to give clues as to altitude. Coming over the runway threshold, I bring the nose up to level flight attitude (flare) and allow the machine to sink as airspeed bleeds away maintaining directional control with the rudder.
Just as I flare I catch a glimse of something ahead that boggles my mind. I can’t believe it! A dog- a black Labrador, to be precise- has wandered onto the runway dead ahead! Somebody’s darling doggie is about to get sliced by the propeller.
Here were my choices- 1) Plow through the dog, 2) attempt to steer around the dog, and 3) attempt to hop over the dog. By the time these choices are in my head, the airplane has touched down and we’re in the landing roll.
Since I had slowed down to “full flaps” stall speed, I was reluctant to hop the plane into the air in ground effect for fear of the subsequent drop to the ground. The dog was too close for acceleration with added power, so option 3) was no good.
Option 1) was highly undesirable for obvious humane reasons. But option 2) could easily result in oversteer off the runway at high speed in a 3-wheel machine full of 110 octane gas. This was no good either.
Instead, I opted for a combination of 1) and 2). I applied heavy braking while turning off center only slightly. I was not about to get injured trying to avoid this airdale that had wandered my way. If I hit the dog I would just have to deal with it. At the last moment, a black streak to port told me what happened.
I missed the dog.
Exhibit 3. Mercury Shower. Whether in production or on the benchtop, filtration is a problematic operation. Against ambient pressure, vacuum pressure is limited to a pressure differential maximum of 1 atm. For a minimally equipped fume hood, pressure above can be supplied by carefully holding your finger on the nitrogen bubbler and carefully applying pressure to the Schlenk filter. This way, the filtration time can sometimes be minimized.
One day in grad school, leaning inside the fume hood I was attempting to apply pressure to my filter flask by holding my finger on the exit of my mercury bubbler. At some point, the seal of my skin yielded to the pressure and the high pressure N2 shot mercury up through the bubbler, past my finger, where its trajectory carried it to the top of the hood. As it is prone to do, the mercurial fluid broke into a zillion tiny beads, many of which rained down upon my head. I could feel the delicate tapping impacts on my prematurely grey locks and my shoulders.
After the ritual spewing of foul utterances, not over pain or distress, but over the hazardous mess, I set about cleaning up the mercury spill in my space. I removed my shirt for disposal and shook my head until I was dizzy.
Hours later, I visited the university health office for a visual inspection of my scalp and ears. No point in delivering mercury to my pillow. The nurse was at first reluctant to inspect me, but relented if only to hear the story of why I was there. Later I was pronounced free to go home where I would lather-rinse-repeat all evening.
These are stories of circumstances that have advanced the universe 3 clicks forward in the net cosmic ridiculousness. This very post could be a 4th.
“We live in an age of miracle and wonder” is the refrain from Paul Simon’s album Graceland. All around us and through us are engineered materials devised for their specific physical and chemical properties. Time-released magic bullet drugs that inhibit specific enzymes. Flavorants, colorants, rheology modifiers, and manufactured food substances are engineered and marketed to satisfy our lizard brain’s willingness to shell out cash-for-calories and stimulate our limbic system’s emotive triggers.
It is nearly impossible to avoid contact with manufactured goods that aren’t modified by chemistry. A century and a half of tinkering with substances at the nanometer scale has given us the ability to optimise the composition and performance of products that make our lives easier and safer. Microprocessors and Lycra, Hastelloy and Lipitor. The chemical industry has evolved to produce the raw materials and finished goods needed for the performance we have come to expect.
However, history provides a record of the problems associated with the exuberant but uncritical acceptance of this flood of manufactured goods. From radium poisoning of watch dial painters to chromium VI to asbestos, there is a long list of negligence and environmental insult. The trail blazing of chemical industry leaves behind it a chronicle of tragedy as well as benefits.
The result of the checkered past of industry is a growing (some would say “metastisizing”) intertwined web of state, federal, and international regulatory oversight and requirements. And with it- perhaps as a result of it- has come institutional risk aversion.
In general way, risk aversion is a type of survival trait and is probably hardwired into our brains. It is hard to blame people for being wary or fearful of risks, especially those they do not understand. But on the other hand, risk aversion is also a type of inertia. It is a fulcrum from which metaphysical rather than physical justifications are leveraged.
At what point does concern for safety become excessive and how does one go about commenting on it? In a sense, it is similar to being critical of a religion. Similar to interpreting religion, we interpret that safety is important, but we do not often have a clear path mapped out for us through the maze of details and choices.
It is possible for organizations to be dominated by confident voices that are risk averse. Meeting facilitators will piously intone that “safety first” is our policy. Detailed SOP’s will issue, dragging out the most elementary actions into numerous steps. There is great merit to SOP’s, but enlightened and proactive management of hazardous operations personel is more important.
Organizations can find themselves spiraling into micromanagement of even the smallest details for fear that a regulatory or liability hammer will fall at any moment. Indeed, if one studies the regulations in detail, it is easy to fall into this habit. Risk aversion isn’t just a personality issue, it is statutory.
Statutory risk aversion is the domain of the Nanny State. The name “Nanny State” refers to the sum total of regulated actions and conditions in our lives as well as the set of penalties. Though perhaps well intended, the Nanny State seeks to zero out risk, even for the less risk averse.
The Nanny State makes the startup of new chemical technology companies prohibitively expensive. Nobody advocates the idea that we should be free to pollute and risk the lives of workers and communities. But even for the most skillful and well intended, there are too many regulatory landmines to dodge: air, water, and waste permits; local zoning; OSHA; EPA (TSCA); fire codes; insurance inspections; MSDS’s in multiple languages; ITAR; and DEA. All have reporting requirements, statutes, and paper trails to maintain.
The plant is the domain of the chemical disaster. The inner offices are the domain of the administrative disaster. Executives fear being out of regulatory compliance almost as much as an exploding 1000 gallon Pfaudler reactor (alright, I exaggerated … slightly).
In my view, the USA is becoming ossified in Nanny State paralysis in much the same way the EU has. The combination of technological risk aversion along with the popular sport of outsourcing by our nations corps of MBA wizards only serves to accelerate the de-industrialization of the USA and the EU.
According to the August 27, 2007 issue of C&EN, page 29, the EPA says that the toxicology data on tetrahydrofuran show “suggestive evidence of carcinogenic potential”. The cited document can be found at this link.
It’ll be interesting to see what happens as a result of this study. It is understatement to say that THF is a mighty important solvent. More than a few important processes require this cyclic ether. Perhaps this is how Methyl THF makes its appearance to a wider audience? But in doing so it will only attract the attention of toxicologists.
With REACH and the EPA’s reexamination of many substances in current use, there is likely to be an extended shakeup coming for US chemical processors in the next 5-10 years. What the rest of us have to reconsider is what constitutes acceptable risk. It’s time for that old aphorism- “A ship in harbor is safe. But that is not where ships are meant to be.”
The hardest problems to deal with seem to be the low signal-to-noise ratio phenomena- low level radiation, low level pollution, trace levels of this or that in the working environment. Most likely, acceptable THF exposure levels will come way down and the material will stay in use. That’s my guess.
Safety is something that everyone who handles chemical substances must come to grips with. That’s pretty obvious. It is possible to structure prudent handling practices into policies that control how people come into contact or proximity with chemicals. While I can’t speak for the rest of the world, in the US and EU virtually all of academia and industry have rules that govern the use of personal protective equipment (PPE) and hazardous material storage.
As a group, I have known chemists to span the range of chemical aversion from compulsive chemophobia to stuntman fearlessness. Most chemists are in the middle ground in regard to what toxicological or energetic hazards they’ll unleash at arms length behind the sash.
But there is risk and there is perceived risk and the difference can be quite large. Research laboratories are places where we try to achieve understanding about the unknown. Material hazards may not be readily apparent in advance of an experiment. We all have our sensibilities about what’s hazardous- call it “intuition” or just “experience”- but in reality most workers need to get an occasional recalibration. Our perception of a given risk can be spot on, overly conservative, or overly lax.
Institutions eventually have to put boundaries on the definition of acceptable risk. In innovative industry, companies want employees to try new things. Being overly conservative with risk can lead to time consuming procedural gymnastics that accomplish only delay. Being overly lax with risk can lead to the loss of life and facilities. The necessary administrative skill is to encourage safe innovation.
Researchers have physical hazards to contend with. Managers must dodge administrative hazards that can blow a project out of the water. Reseachers operate within the bounds of physical law. Managers have the fundamental forces of economics, politics, and CYA (cover your a**) in addition to physics.
In candid moments, R&D chemists may admit that much of research seems to entail the discovery of new failure modes. The broad search of reaction space can lead the researcher into patches of higher risk activity. It is quite possible to blunder into energetic hazards or unwittingly generate highly toxic moieties that you were heretofore unaware of. The abstracts from a SciFinder search don’t always offer notification of such hazards, especially if you are making new chemical compounds.
I know more than a few reasonable chemists who work for companies that have attempted to extract all risk of R&D scale incidents. All experiments have to be planned and approved by some overseeing body. Any incident involving a fire or spill is subject to an investigation and disciplinary action is meted out based on the in-house definition of negligence. Large publically-owned commodity producers seem to be the most onerous in this regard. (This is my opinion and the reader is free to take exception).
As is not untypical of large irritable mammals, Th’ Gaussling doesn’t automatically welcome visits by the safety goonsquad. One of my many festering conceits is that I write procedures, I don’t follow them. Unfortunately, this is a card that you can play once or twice at most. The best strategy for long term employment is to stay off the safety radar screen. If you have to take the dragon out for a walk, have your route planned and for gawds sake, keep it on the leash.
Lamentations on Chemistry 