Chemical safety as social science

Chemical manufacturing safety is challenging to oversee consistently over time. A given manufacturing facility has many kinds of hazards, some common and some specific to plant activity. Specialized operations will produce hazards that manifest in ways ranging from obvious to obscure to counterintuitive. For those tasked with keeping operations free from injuries and mishaps, the hard part may be to keep everyone vigilant constantly.

I often compare safe practices to the handling of a rattle snake. Every time you pick up that snake, you have to be just as careful as the last time. Over time you may learn to predict or anticipate threatening snake behaviors, but you do not get to bank safety credits for past cautious behavior. Furthermore, it is necessary for you to change some of your basic behaviors around the rattler. For instance, you may want to alter your posture when standing near the snake so, if you lose your balance, you fall away from the snake, not onto it. Or, you may decide to bring the snake out only when there is not a crowd around you for fear of spooking the animal. A wrangler can cite many techniques to adopt when handling this venomous creature.

My views of safety policy and practices have evolved over time. In the academic and industrial lab facilities I have worked, safety policy varied from “don’t get hurt” to academic departmental policies with the unofficial “for god sakes don’t let a student get hurt” to highly professional facilities using “we reserve the right to dismiss you” if your accident involved a violation of policy. In these chemistry jobs I have functioned as a dairy processing lab chemist, student assistant, grad student, postdoc, assistant professor, chemical sales manager, senior scientist and process safety chemist. There has been some variety.

What allowed my successful navigation through these experiences with body parts intact? Skill from good training and a large shot of luck. And having been cautious by nature when it comes to hazardous energy and chemical hygiene doesn’t hurt.

In my estimation there is a large social/psychological component to safety anywhere. Safe operations in a chemical plant requires an alignment of behaviors that lead away from mishaps due to all manner of influences, predictable or otherwise. To oversee safety at a facility, one must use facts and the power of persuasion to convince people to behave in ways that might seem needless or unnatural. There is a large social component to safety. That said, the threat of dismissal doesn’t hurt.

In a US chemical plant, operational staff commonly undergo safety training on hiring and refresher training thereafter on a periodic basis. If an adverse event happens relevant staff may undergo a refresher training session as policy dictates. The range of safety topics will depend on the kind of activity happening at the facility.  Safety training has the goal of bringing and keeping staff up to par on recognition and prevention of some kind of undesired event that plays out as a near miss or an incident.

A core subject in chemical manufacturing facility is the matter of hazardous energy. Hazardous energy is manifested in numerous ways: High pressure, high temperature, electrostatic, rapid or runaway heat of reaction, compressed springs and energy of motion. Hazardous energy can emerge from the familiar and the unfamiliar.

Dangers emerging from “ordinary” hazards, i.e., the hazards everyone is accustomed to, can perhaps be most vexing. How does one convince people not to become complacent with familiar hazards, particularly those of low frequency high consequence?

Frequent training and thorough root cause analysis of actual incidents is probably the best approach to suppressing complacency. One need look no further than the military for an example. Military personnel undergo frequent training with an emphasis on situational awareness. A particular strength is the existence of protocols for many exigencies and the mandatory adherence to that protocol. The obvious problem of the military approach to training is that it is not aimed at producing material goods for a competitive market. Businesses cannot afford to lavish much downtime to training. Civilian safety training in business is conducted but at nothing like the frequency or scale that the military uses to maintain readiness.

A useful tool available to industrial safety is layer of protection analysis (LOP). There are companies that offer custom LOP services/instruction and outside assistance is often a good thing. Other resources exist as well. There are two kinds of layers- administrative and engineering. Administrative layers of protection include the process instruction document, various SOPs and work instructions, training as well as eyes-on active management. Engineering layers of protection refers to the equipment which protects against the effects of an excursion.  Each layer will have empty spaces where they are not protective. The idea is to lay down layers where the empty spaces do not overlap. Most would agree that engineering LOP are preferred over administrative LOP.

The terms “dangerous” and “hazardous” are often used interchangeably. I would argue that the word danger be reserved for the situation when all of the layers of protection around a hazard have been removed. This is an important distinction because our lives are filled with hazards that don’t fill us with dread fear. We tolerate this only because we contain hazards with layers of protection which prevent the consequences of the hazard. In order to keep working in an industrial setting, we all must come to terms with the contained hazards on site. Workers predisposed to chemophobia must become comfortable with the LOP in place, yet remain vigilant for uncontained hazards. The alternative for them is to work elsewhere.

Incidents should be followed closely by a Root Cause Analysis, RCA. There should be an SOP that specifies this action. With any luck, an expert conversation in the subject matter at hand will spark the insight of someone leading to the identification of failure modes related to the incident. The RCA will identify which dominoes fell in the event and will highlight the weak points and hopefully find the initiating event. Finding the incident initiating event is always a goal.

It is important to evaluate the existing LOP after the RCA and every effort should be made use the event to strengthen systems. The notion of LOP should be present early in the process of writing instructions for the manufacture of materials. Each batch or process instruction document should be critically evaluated and signed off by a variety of experienced people. This would include R&D chemists, chemists and engineers involved in process scaleup, Environmental, Health and Safety, production supervisors and plant managers. All can be reminded to evaluate the production document with LOPA in mind.

Inevitably, incidents and near misses stemming from unanticipated failure modes will occur. To provide added protection against the unexpected, imaginations need to be stimulated by conducting a PHA- Process Hazard Analysis. This must be done before a process is begun. It is a formal brainstorming session conducted by a committee of subject matter experts evaluating every step in a chemical process at the production scale for possible failure scenarios. These will be chemical, mechanical or safety systems related. In the PHA you ask the question: What happens if this component or action fails in the process? It is a detailed what-if map of the failure or event with potential consequences. Each potential consequence must be evaluated for risk and harm. Software is available to help people guide themselves through the process.

Finally, it should be noted that once the incident investigation is complete, learnings from the event should be applied going forward and archived where the results can be readily found.

Orphan Wells

Recent news tells of the federal government’s intent to spend $1.15 billion to cap orphan gas and oil wells in 26 states. For its part, the American Petroleum Institute issued a statement “We welcome the administration’s efforts to address orphaned wells,” said the API spokesperson. I should hope so.

My question is, what kind of person/organization would walk away from a gas/oil well that isn’t capped? It seems like there should already be structure in place to prevent or remedy this. Leaving behind open wells that could be venting hazardous natural gas should be defined as willful negligence and subject to criminal penalties for the company officers. This behavior is an affront to those of us in the chemical industry who strive to comply with good operating practices and environmental compliance 24/7/365.

Learnings from a career in chemistry.

I will be retiring from industrial chemistry in early 2023. Retirement has snuck up on me, to be honest. I suppose like most 64 year-olds I have trouble recognizing myself in the mirror. The joys and battle scars from my youthful early career are still fresh in my memory even as I turn the corner into the doddering years. I still recall most of the sights and smells and people in the years leading up to the present. I was lucky to meet many good people and unlucky enough to encounter a few problematic jerks. One of my earliest lessons was that not every scientist is one of your brethren. Science contains a bell curve of people- skewed to the good side for the most part, but there are always toxic characters around seemingly bent on making life difficult.

My entry into chemistry was a bit of an accident. I entered college as a physics major and Air Force ROTC minor at the age of 22. Naively I thought that my freshly issued pilots license and an intended physics degree would grease the skids into a flying career in USAF. Boy was I wrong. If anything there was palpable contempt for the pilots certificate. The curious attitude was if you didn’t learn to fly in the USAF then you weren’t shit. Turns out that I was also nearsighted so I was automatically disqualified from a pilot slot. My view in turn became that if you can’t fly jets why be in the USAF?

I took freshman chemistry in the summer for the physics major, then in the fall of my freshman year I started organic chemistry just out of curiosity. I was always puzzled about how drugs work and organic chemistry seemed to be the key. It turned out that organic chemistry was uniquely suitable for my type of ape brain. Soon I switched to a chemistry major and out of ROTC and never looked back at the smoldering crater of my flying career. That said, airplanes are still a passion of mine.

From this end of my career I can look back and see some mistakes I made in the past. First, while I chose a good PhD advisor, I may have aimed too low for the postdoc. It limited my opportunities for a better academic career. Always aim high.

I had a succession of four (count ’em) 1-year sabbatical replacement jobs before I got a tenure track slot at a small midwestern college (with an NMR). One year into my tenure track academic position I drove my career straight into a tree by having an escalating argument with the tenured chemistry department chair. After a long and successful career before my arrival, he tragically became a drunk and a failure in the classroom, he came to treat department faculty with disrespect and was an autocrat. All of this was well known in the department. My mistake in handling the personality conflict was to push a little too hard for near term change in department norms rather than playing the long game by waiting for his retirement. Unfortunately there was no support from the Dean despite the chair’s history of bad behavior. Seeing no help from admin, at Christmas break of the second year I took the first industry job offer I got and left the college. There was no hope for a new contract. I consider this episode to be my fault entirely for not being savvy enough to play the politics right. It was a mistake I would not make again. Oh yes, he died a year after I left.

Lesson No. 1. Learn to engage in politics calmly and ethically. Be patient and smart about it. Abstaining entirely from politics is the politics of victimhood. Like the old saying goes, if you put two people in a room you have politics. If it’s going to happen anyway, you may as well be good at it.

Believing that my teaching resume was fatally disfigured by this absurd episode, I resolved to move into industry. I joined a startup company that was bringing out new technology for commodity-scale polylactic acid (PLA). I was hired to find new catalysts for the cyclodimerization of lactic acid to lactide (the monomer) and comonomers that would lower the glass transition temperature of PLA. PLA homopolymer has a high glass transition temperature that leads to brittleness under ambient conditions. It was a great job and I took a fancy to polymer chemistry. Unfortunately, 11 months after I joined the company folded and I was on the street. Bringing a new polymer into the market at the commodity scale requires a powerful position in the polymer market which we didn’t have. Worse, we had persistent problems with low molecular weight as the money was running out.

Lesson No. 2. Beware the siren song of startup companies. They often fail.

Losing an academic job and an industrial one in a short interval had me eating a big slice of humble pie. These were dark times. In order to feed the family I took a job as an apprentice electrician working commercial construction sites. I had a good boss and the work was interesting. This phase lasted 6 months.

Not wanting to move across the country again I looked for a local job as a PhD chemist. They were scarce. Passing by pharmaceuticals, I took a risk and got a job in chemical sales at a small local chemical plant. Initially I assumed that my career as a scientist was over. As it turned out, that wasn’t true. Most of the chemistry there was multistep organic synthesis so I fit right in. This job would put my chemistry education to use in ways I hadn’t anticipated. We had diverse customers scattered across the world and marketing and customer sales and service required more than just a conversant level of chemistry knowledge in this small market. Very often being able to speak with equal confidence to both scientists and purchasing managers was a necessary skill in making the sale. And the job required some travel to far flung locations which was very stimulating.

Lesson 3. Don’t assume that your career should look like your dissertation project. Be open to possibilities.

Along the lines of Lesson 3, it is worth mentioning that in the course of a chemistry career the chemist might run into the choice of remaining in the lab or transitioning into the business end. The chemical industry requires some business leaders to have a knowledge of chemistry. This should be obvious. The problem is that relatively few chemists enter the job market with solid business credentials. By contrast, chemical engineers evolve their careers by solving chemical manufacturing problems and designing projects within very tight economic constraints. Whereas chemical scientists have a world view that mainly has two axes- space and time- engineers see the world in terms of 3 axes- space, time, and economics. Engineers are trained to bring capital projects in on time and within budget. This facility with projects and economics provides for the facile promotion of engineers to top management positions. My observation is that lab chemists without training in business generally seem to have less career buoyancy than engineers within chemical organizations. Of course there are exceptions. An MBA for a chemist can have real value in upward mobility and lifetime earnings. I’ve seen it happen numerous times.

Lesson 4. The world of chemical business is very interesting and challenging. Give it some consideration.

One way to migrate from the lab to an executive level for a chemist is to become a chief technology officer. This can be a very consequential position in an organization bearing a heavy load of responsibilities. Executive level chemistry jobs can take you into the thin air of business development and the chance to work with a large assortment of executives and managers from other organizations. It is worth aspiring to.

Lesson 5. Polymer chemistry is very interesting. For all you small molecule people out there, try it. You might like it.

But with all of this said, my view now is that I should have tried harder for a flying job in the airlines.

Applied Science

Like most sciency individuals who graduated from the university/research complex in the US, I planned on a life of doing science. And I did for a few years as a post-doc and assistant prof. But eventually I left academia for the industrial side of the scientific enterprise. There was a period of getting oriented to the commercial arena of chemical technology. But, after seeing the boost in pay, the abundance of lab equipment and the prospects for travel, I quickly adapted.

In industry, scientists are hired to solve problems. And there are usually problems galore. But unlike academia where the entire spectrum of chemical methodologies are available for use, in industry we are often constrained to use in-house technology and standard operating procedures. This in-house technology can consist of proprietary materials and methods, specific substances that are compatible with environmental, health, & safety requirements (OSHA & EPA), or that reaction chemistry which is suitable for scale-up. Suitability can be based on compatibility with materials of construction or the practical operational constraints of existing equipment. Oh, I forgot to mention process safety. Manufacturing at large scale brings safety problems that academics may have little familiarity with.

In-house technology can be broad or narrow in scope. It can be practiced openly in the public domain, reside under just trade secrecy, or under patent protection and a spritz of trade secrecy. Progress in academia is about sharing knowledge and publishing as a measure of productivity, all the while educating students. In industry, the productivity of a scientist is measured as best profit margins on new or old products and technical service to customers. Whereas, an academic is expected to propagate knowledge, we in industry are obligated to keep everything under wraps. Disclosure can be a career ending mistake. This seems like an oil and water compatibility problem.

The differing imperatives, commercial secrecy vs public domain, make the cooperation between industry and academia fraught with difficulties. What is in it for an academic or grad student if they are not able to get a publication out of their labors? A big grant possibly but few publications to show the rank and tenure committee. Will patents get you tenure or a full professorship? I don’t know. Would students be able to use proprietary information in their dissertation? It’s questionable. The matter of proprietary information, inventorship, and assignment of ownership makes cooperation between industry and academia a complex problem for the lawyers.

I live under a rock but perhaps the readers might know of fruitful alliances in the lab between the two chemistry domains- college chemistry faculty and industry. I suppose in circumstances where a company has been started by a professor, productive alliance could happen more easily. 

 

Flying Cars

I’ve been thinking a lot about flying cars lately. The promoters of these cars have said nothing about what would happen if these things became popular. How would one qualify to operate one? Presumably the FAA would get responsibility for regulatory oversight of this new air traffic. What airspace would these flying cars be allow to fly in? Would they have to be automated? Would you dare fly without a backup pilot on board?

While driving on a busy road, look at how people drive. I’m sure you’ll agree that there might be a large fraction of folks who should not be allowed to control a flying vehicle. Just how much air traffic congestion could/should we tolerate overhead? The issues get stickier the more you think about it.

Currently there is extensive training and 3 tests to pass to get a basic airman’s certificate. Of course these vehicles could hit the market with full automation and without a licensed pilot. But that doesn’t mean there won’t be the need for a backup pilot for some period of time. After all, modern airliners are heavily automated but pilots are still required. And, do we really want them to land just anywhere even though that is a selling point? Perhaps there will be selected places where they can land, you know, like an airport.

I doubt that we’ll see flying cars replacing significant ground commuter traffic even into the distant future. I think they’ll get a recreational vehicle status and will be limited -economically- to wealthy status seekers, show-off executives, or the state.

Eventually, the police and FBI will want them them as well. And criminals.

Hydrogen Fluoride in the News

The July 8, 2019, online issue of the NY Times featured an article by Dr. Daniel Horowitz, an organic chemist and former member of the US Chemical Safety Board, on the matter of hydrogen fluoride (HF) use in petroleum refining. HF is an acid catalyst used in taking small hydrocarbon molecules and making somewhat heavier hydrocarbon molecules for use as octane boosters for gasoline. This is a critical technology for efficient use of petroleum in the manufacture of motor fuels.

My take on the article is that Horowitz believes that refineries are using an alkylation technology that is too hazardous for workers and the public. He writes that there have been several recent near-misses that could have lead to the release of HF that might have left the plant site and spread into the surrounding communities.

Risk = consequence of hazardous activity x probability of event (Wikipedia).

While actuaries understand how to calculate risk, one wonders how executives go about deciding what is an acceptable risk for other stakeholders like the public. Hmmm. Just a thought.

Thanks to RW for the link.

Agilent 1260 LCMS

Learning how to use an Agilent 1260 LCMS (with just the diode array detector, not the MS). Oh. My. God. I last used an Agilent 1200 LC 10 years ago. This bloody 1260 is wildly complex, specifically in regard to the MassHunter data collection and workup software. It’s like a Swiss Army knife with 500 tools on it. The thing is designed for a busy analytical lab with high throughput and heavy documentation, like the boys and girls in pharma would use. I’m just using it for research. It’s like giving a taser to a monkey. It’s just a matter of time before something goes dreadfully wrong. Crimony.

Dr Prominent Professor gets a patent

While doing some IP due diligence I ran into a patent that claimed some art of interest to me. The art was very useful, but it was claimed by a Prominent Professor of chemistry at Well Known University (WKU). Digging a bit deeper I found that the patent had expired well into it’s lifetime due to non-payment of maintenance fees. So, let’s look at this a bit deeper.

Prominent Professor files a patent application in 1998 on said art and then shoots off a paper to Well Known Publication. Then in 2003, the USPTO grants a patent to Prominent Professor and is assigned to WKU. Fine.

If the patent had been generating royalties, it seems unlikely that WKU would have allowed the patent to expire. There is no record of transfer of ownership to another assignee either. My guess is that by the time of the final maintenance fee, interest in the patent was slim to none. Seeing no royalty income likely, WKU elects to allow the patent to expire. Not uncommon.

The work produced by Prominent Professor was funded by DoE. In short, Prominent Professor received public funding and then by virtue of filing for a patent, the technology produced by said public funding is denied use by the public unless they pay again for it in a royalty agreement, unless it was under exclusive agreement with another entity. Evidently the art sat fallow for a good dozen years until it expired. Prominent Professor and WKU got a feather in their caps, and industry and the public had to sit on their thumbs during the period of unproductive time.

This is but one example of a sham allowed under public law.

The Packaging Fetish

I received a package from the across the Atlantic last week. It contained a small pressure transducer which, in it itself, isn’t very interesting. But what was odd was the number of layers of packaging it had. It had 6 separate bags and envelopes as well as a piece of foam.

At what point does precaution give way to fetish? They could learn something from Amazon. When in doubt, use those green air pillows and a box.