The Emergency Response Guidebook (ERG) 1 can be found on nearly every fire apparatus in the United States and Canada and is generally the only reference book found on most fire service vehicles except for some specialized units. Its purpose is to ensure that fire department personnel approach hazardous materials safely and effectively. When hazardous materials are concerned, it is—or should be—their best assurance that everyone goes home.
The ERG has been through numerous editions for decades; new editions are published every four years. Recent editions include 2012; 2016; and, most recently, 2020. With such a long history, you might conclude that the document distills the best available safety information for first responders, honed through decades of tragic experiences. Unfortunately, you would be wrong. The ERG does not comprise an adequate effort to ensure all first responders receive sufficiently good information so that everyone go home. I will look at some of the ERG’s systemic problems and then focus on one major disaster in which 10 firefighters and one civilian assisting the first responders died in a hazmat explosion and didn’t go home. Four other civilians died, and more than 200 persons were injured in that incident.
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Systemic Problems
The four primary systemic problems found in the ERG are the one-size-fits-all approach, the cry-wolf syndrome, poor editing/technical inaccuracy, and failure to revise in response to disasters.
One-size-fits-all approach. Chemicals dangers are not general; they are specific to a particular chemical. Certainly, some chemicals are “similar” in their action and their hazard. But there are around 84,000 tabulated chemicals, of which about 38,000 are in the stream of commerce. In the 2016 ERG, all chemicals are classed into 63 “Guides” (64 are listed, but one is blank). Is that a reasonable number? The chemical profession disagrees. A preeminent guide to dangerous chemicals is the two-volume Bretherick’s Handbook of Reactive Chemical Hazards.2 The first volume comprises a very long alphabetical list of chemicals; for each item, it identifies reactants that may lead to some safety problem. The second volume is an instructional volume on various topics. Among the topics covered are close to 400 categories of hazardous chemicals, quite different from the 63 groups into which the ERG insists on dividing everything.
Furthermore, when tens of thousands of chemicals are discussed, the ERG suggests that a scheme of grouping all of them is the only practical solution. Not true; many are very obscure and not used in significant quantities. But,more important, only a very small number of chemicals have caused repeated, multifatality incidents. The ERG should consider these by themselves, not grouped with others.
(1) Photo courtesy of the Pipeline and Hazardous Materials Safety Administration, U.S. Department of Transportation.
Cry-wolf syndrome. Although there are many diverse injuries that can occur in connection with hazardous materials, the worst is when a first responder is caught in an explosion. Thus, one would hope that at least the ERG would treat explosion disasters with the utmost critical attention. Instead, the issue is trivialized. Approximately 42, or two-thirds, of the 63 Guides list explosion as one of the hazards. This trivializes a very serious issue that should not be treated lightly.
Part of the problem is that “explosion” does not have a uniform definition on which most safety specialists would agree.3 Explosions encompass a very wide range of territory. Throwing an aerosol can of hair spray into a bonfire may cause an explosion. But unless you are so foolish as to do such a senseless act and stay there watching it up close, you will not suffer bodily harm. The explosions that should concern first responders are those with a potential to cause serious injury—not just every explosion, regardless of how mild—a distinction the ERG does not recognize.
But the ERG policy is not just reasonable overconservativeness. Warnings must be carefully crafted to clearly alert involved personnel of serious hazards. Although minor hazards can be tabulated in some fine-print text, distinguishing between the grave and trivial is important. Declaring that some two-thirds of accident categories involve explosion hazards creates a cry-wolf situation, not a useful warning.
Poor editing/technical inaccuracy. This also tends to overlook serious hazards. Over the past 15 to 20 years, lithium ion batteries have become known as a serious explosion concern. First commercially sold in the 1980s, these batteries’ use increases yearly, and so there is now a more than 30-year history of their usage and hazards. Because of their fragility and high energy density, lithium ion batteries represent notable fire and explosion hazards. Already in 2003, in my Ignition Handbook, I discussed a case in which a defibrillator in a fire station exploded severely enough that it “blew the Assistant Chief out the office door.” In many cases, hazards of the greatest concern involve airplanes. Asiana Airlines Flight 991 crashed into the ocean and left little identifiable wreckage. But investigators concluded that the most likely cause was a lithium ion battery fire.4 In view of this potential for disaster, it is truly hard to comprehend that one of the few ERG Guides which does not mention the danger of explosion is Guide 147 on lithium ion batteries. The result is truly a double whammy:Trivial hazards are elevated, while grave hazards are neglected.
Failure to revise in response to disasters. On April 17, 2013, an ammonium nitrate (AN) fertilizer storage facility blew up, destroying the plant and obliterating a good portion of the town of West, Texas. The local volunteer fire department had arrived only 12 minutes earlier at a fire at the facility and was just starting to apply water when a massive explosion occurred, causing 15 fatalities, 10 of them first responders.5,6,7,8 How did the ERG factor into this disaster? AN is grouped under ERG Guide 140. The fire/explosion hazards described in Guide 140 of the 2012 ERG are as follows:
FIRE OR EXPLOSION
• These substances will accelerate burning when involved in a fire.
• Some may decompose explosively when heated or involved in a fire.
• May explode from heat or contamination.
• Some will react explosively with hydrocarbons (fuels).
• May ignite combustibles (wood, paper, oil, clothing, etc.).
• Containers may explode when heated.
• Runoff may create fire or explosion hazard.
Is this sufficient? Let us remember some history here. The worst industrial accident to occur in the United States occurred on April 16-17, 1947, when two ships blew up in the Texas City, Texas, harbor and killed 581 people.9, 10 The cargo that blew up there was AN, after a fire occurred in the cargo hold of the S.S. Grandcamp. This should make clear that the combination of a serious fire and AN is a recipe for disaster.
So, is the warning adequate concerning the dire effects of fire? “Accelerate burning” surely does not suggest anything dire. But “Some may decompose explosively when … involved in a fire” is exceptionally poor wording. Is AN one of these chemicals? The ERG does not tell you. Here, in a nutshell, is the crucial problem of the one-size-fits-all approach. The firefighter is not a chemistry specialist. If the ERG fails to give a clear warning and only states that “some” chemicals may show this hazard, this guidance is—tragically—worthless.
Let us focus again on this paragraph from a wide-angle view: 581 dead is an outrageously dire fact. If you read the ERG paragraph, do you get any idea that 581 dead bodies may result from an AN + fire incident? If not, then the warning is hopelessly inadequate toward its intended purpose.
The action that the first responder is supposed to take in response to a fire incident with AN is described in the 2012 ERG in another short paragraph. Apart from truck or railcar accidents, the whole of the fire safety advice given is the following:
FIRE
Small Fire
• Use water. Do not use dry chemicals or foams. CO2 or Halon® may provide limited control.
Large Fire
• Flood fire area with water from a distance.
• Do not move cargo or vehicle if cargo has been exposed to heat.
• Move containers from fire area if you can do it without risk.
AN is noncombustible and cannot burn, even though it can explode horrifically. Thus, the text is misleading in and of itself. AN cannot burn, but an external fire impinging on it will create an extreme hazard. Thus, the document should make that clear, but it does not. By the way, in analyzing known AN accidents, it was found that there is a 14% probability of a fatality if a serious fire impinges on AN fertilizer.11 This is not some remote risk; this is an exceptionally severe risk. If someone is exposing themselves to an activity where there is a 14% probability of dying in the process, rethinking is generally advised.
An important question is, did the West, Texas, firefighters act correctly according to the ERG prescriptions? Unfortunately, the answer is yes. The firefighters encountered a fully involved storage building on their arrival—clearly a “large,” not a “small,” fire. They did not enter the building or attempt to move cargo. Instead, they opened an exterior door and started to apply water from the outside. Certainly, they were attempting to “flood fire area,” even though there were some water supply issues. By deliberately choosing not to enter the building, they correctly did this “from a distance.”
It may be readily noted that the ERG says nothing useful about the required distance. But distance must be considered. The Chemical Safety Board found that shrapnel was propelled in the explosion some 2,000 feet. Thus, firefighters would have had to back off more than 2,000 feet to be out of reach of danger. A high-capacity water stream can project water for about 200 feet. But the firefighters did not have optimal equipment or desirable levels of pressure. Thus, it is doubtful they could have projected water for 100 feet, if that. Presumably, the firefighters had some appreciation for how far they can project a water stream. But they clearly did not know they should stay away 2,000 feet, since the ERG did not tell them! Nor were they instructed that there is a 14% probability of lethalities for this particular firefighting undertaking.
The 2012 ERG was in force for the 2013 disaster. Subsequently, the ERG was revised and published in 2016. The relevant text for AN hazards and firefighting instructions remained unchanged from the 2012 edition. Evidently, it takes a more extreme event than losing 10 firefighters (and five civilians) to make adequate revisions to the ERG.
Needed Safety Measures
It is not a greatly challenging task to develop safety and firefighting instructions for first responders responding to a fire threatening an AN storage facility. A simple warning should suffice, as follows:
FIREFIGHTING AND EXPLOSION WARNING
For quantities of 100 pounds or more of ammonium nitrate: Do not attempt to fight fires threatening ammonium nitrate stored in a building or located on a truck, a railcar, or a ship. Initiate evacuation procedures. Pull back all personnel at least 2,000 feet from the location.
For quantities of less than 100 pounds of ammonium nitrate: Do not approach closer than 50 feet from the product. Apply water at the minimum rate of 125 gallons per minute, and do not stop the flow until the fire is totally extinguished. If all water available is utilized prior to total extinguishment, commence evacuation procedures.
The 100 pounds used here is a very conservative value. Further research could examine if this value can be raised, but no research would have been needed to publish guidance with a 100-pound value and then revise it upward later if justified.
Author’s Note: Thanks to Chief Richard (Smokey) Dyer, Professor David Rockstraw, and Professor Brandon Weeks for their review of this article.
References
1. Emergency Response Guidebook. (2020). https://bit.ly/3hziJPB.
2. Urben, P. G., and Pitt, M. J. Bretherick’s Handbook of Reactive Chemical Hazards: An Indexed Guide to Published Data. (8th ed.). Elsevier, London (2017).
3. Babrauskas, V. Ignition Handbook. Fire Science Publishers/Society of Fire Protection Engineers, Issaquah WA (2003).
4. Safety Recommendations A-16-001 and A-16-002., National Transportation Safety Board, Washington (2016). https://bit.ly/32oZBNG, https://bit.ly/32zOYaY.
5. Firefighter Fatality Investigation (FFF FY 13-06). Texas State Fire Marshal’s Office, Austin TX (2014). https://bit.ly/34D7QbP.
6. West Fertilizer Company Fire and Explosion (15 Fatalities, More Than 260 Injured). Report 2013-02-I-TX, U.S. Chemical Safety and Hazard Investigation Board, Washington (2016). https://bit.ly/2QvWLRy/.
7. Babrauskas, V. “The West, Texas Ammonium Nitrate Explosion: A Failure of Regulation.” J. Fire Sciences, 35, 396-414 (2017). https://bit.ly/3huEdwZ.
8. Babrauskas, V. “Will Firefighters Be Any Safer Under the New Hazardous Materials Code?” Fire Engineering 168:11, 66-70 (Nov. 2015). https://bit.ly/31zmOhi.
9. The Texas City Disaster—Facts and Lessons, The National Board of Fire Underwriters, New York (1948).
10. “From the Fire Engineering Vault: Texas City Explosion.” (4.18.13) fireengineering.com. https://bit.ly/3lsFxTE.
11. Babrauskas, V. “Explosions of Ammonium Nitrate Fertilizer in Storage or Transportation Are Preventable Accidents.” J. Hazardous Materials 304, 134-149 (2016). https://bit.ly/32A1HKM.
VYTO BABRAUSKAS, Ph.D., earned degrees in physics and structural engineering and a Ph.D. in fire safety. As a researcher at the National Institute of Standards and Technology, he developed devices to measure the heat release rate of products and developed a computer program for modeling the development of room fires. He founded a consulting firm in 1993 and provides fire safety science expertise to fire investigation and litigation.
