Thank you for posting information about the “hot work” incident that occurred in Colorado. Dr. Rafael Moure-Eraso, chairperson and CEO of the U.S. Chemical Safety Board (CSB) may have been saddened by this hot work incident of July 8, 2010, but I was sickened. 60 fatalities, according to the CSB safety bulletin, over the past 20 years stemming from hot work incidents is 60 too many. The cause for such fatal incidents can be attributed in large measure to one or more of the following: 1. complacency; 2. underestimating cause and effect; 3. an effort to reduce cost; or 4. poorly written protocols for the hot work permit.

As Dr. Moure said, “There is no secret to preventing these accidents”. Having a hot work permit system in place and training workers, as the company stated it did, is not sufficient if it is not done properly. It is certainly no secret, and an obvious aspect to the logical mind, that the monitoring of flammable vapors before and during hot work is crucial to the safety of those workers performing these high risk activities.

One of the root causes to such insufficient safety protocols is the fact that in many cases the authors of these written procedures are not the individuals performing the work. With no skin in game (personal risk) a degree of complacency in developing a well thought-out comprehensive procedure may exist. At the very least some of the authors of these procedures may be inexperienced individuals that do not fully understand the potential catastrophic result when a vital step, such as monitoring, is missed.

While “hot work” was not the issue the same analogy can be applied to the February 7, 2010, explosion at the Kleen Energy power plant in Middletown, CT that caused six deaths and multiple injuries, and the June 9, 2009, explosion at the ConAgra Foods Slim Jim plant in Garner, North Carolina, that killed four workers and injured 67. These incidents are similar in that complacency possibly played a large role in each of the cases.

I can only imagine that years ago some hotdog crew wanting to save time and money in purging a gas line of air quite simply decided to open the gas supply valve supplying gas to a newly installed system in an effort to vent air and gas to the atmosphere. That procedure was apparently executed without a mishap so it was done again, then again, and then again until over the years it became a fairly routine practice in the industry for purging air and internal cleaning of the pipeline after leak testing.

In my 45 years of having worked as a piping engineer in virtually all but a very few industries, and having reviewed and written countless piping specification and procedures I have never come across a clean and test procedure like the one that was performed at Kleen Energy and ConAgra. If, as an Owner’s representative, I would have read the clean and test procedures that were followed at these two job sites I would have required that they be changed. It is beyond my comprehension that an engineer would sign off on a procedure that would, in the case of the Kleen Energy project, dump 2 million standard cubic feet of volatile gas to the atmosphere in a work populated area from a point 20 feet off the ground. My wife and I tell our grandchildren never to use the word, but in a case like this I feel it is appropriate to say stupid, stupid, stupid.

For goodness sakes people apply some common sense thinking to your procedures, particularly to the safety aspect of any procedure. For those of you writing procedures that affect the safety and welfare of personnel, such as the protocol for a hot work permit, go out and stand next to someone that is working on a tank that contained a flammable liquid and feel the trepidation that the welder feels when they are grinding or welding in that environment. Or, feel the adrenaline that the welder feels at having your face 18 inches from an active pipeline when performing the necessary fit-up and welding in preparation for a hot to perhaps a live steam line. Or, if you are writing a clean and test procedure for a natural gas line, how comfortable would you feel standing in close proximity to a point where thousands of cubic feet of gas are being discharged to the atmosphere; A situation in which a single spark from a dropped tool could ignite the volume of gas. Please, apply a large measure of common sense to what you do and write it as though you were going to perform the work yourself, it could save a life.

Thanks again,

Bill Huitt
W. M. Huitt Co.