Professionalism/OSHA and the Pitkin, LA, Explosion

Introduction

On March 4th, 1998, approximately 10 miles from the quiet Louisiana town of Pitkin, a natural gas explosion would rock the nearby timberlands and the lives of four families. At 6:15PM, a catastrophic vessel failure and fire occurred at the Temple 22-1 Common Point Separation Facility owned by the Sonat Exploration Company, killing four workers instantly. The facility housed two petroleum separation trains, separation equipment, piping, storage vessels, and a gas distribution system. The separation trains were designed to produce crude oil and natural gas from well fluid derived from two nearby wells. The train consisted of several pieces of equipment (e.g. petroleum separators) connected in series and used to perform sequential operations on a product stream. The facility had two such trains, a smaller “Test Train” and a larger “Bulk Train.” The vessel failure occurred in the Bulk Train.The vessel ruptured due to overpressurization, releasing flammable material which then ignited and killed the four Sonat employees.

The United States Chemical Safety and Hazard Investigation Board (CSB) identified two root causes and one contributing cause. Foremost among root causes, Sonat management did not use a formal engineering design review process or require effective hazard analyses in the course of designing and building the facility. The secondary root cause identified was the lack of engineering specifications to ensure that equipment was adequately protected by pressure-relief devices. Additionally, the contributing cause of the disaster was the absence of written operating procedures for the start-up and operation of the facility. In the wake of the disaster, recommendations were made by OSHA and the American Petroleum Institute, but were largely ignored by Sonat and other petrochemical corporations in the ensuing decades.

Background and Incident Summary

The Sonat explosion was not an isolated event, but rather part of a broader pattern of industrial risk concentrated in Louisiana’s petrochemical corridor. Cancer Alley, an 85-mile stretch along the Mississippi River, contains over 150 petrochemical plants and refineries situated near marginalized and low-income communities. Sonat’s disaster reflects systemic problems, with a lack of regulatory enforcement and lack of accountability contributing to repeated safety failures and harmful impacts on families (Cite HRW).

There were significant proximate and underlying issues that resulted in this explosion. The proximate cause of the incident, or the direct cause, was that two critical valves in the bypass line were mistakenly left in the closed position. This prevented purged gases from venting, forcing fluids into the third-stage separator where they became trapped and caused over-pressurization. Beyond the proximate cause, there are several underlying causes. One underlying cause is that Sonat lacked a formal engineering design review process. The third-stage separator failed because it was exposed to pressure far beyond its safe maximum allowable pressure. Multiple different groups, such as the Chemical Safety Board (CSB), the Oak Ridge National Laboratory, and Sonat itself, conducted investigations, and estimated that the pressure inside the vessel that was designed to operate at atmospheric pressure had risen to anywhere between 135 to 400 psig before bursting (NASA, 2008).

The explosion could likely have been avoided with a properly designed and implemented pressure-relief system. Sonat misclassified the ruptured vessel, failing to recognize it as a separator despite meeting the criteria for one, which meant it lacked essential pressure-relief devices, as required by ANSI/API Specification 12J-1992. This misclassification, combined with the absence of formal design reviews and process diagrams, prevented proper hazard identification. Sonat did not maintain written procedures or piping and instrumentation diagrams (P&IDs), making it difficult to fully understand or evaluate operational risks. A thorough engineering design review would typically include at least one documented hazard analysis, assessing the consequences of likely deviations in process conditions. However, such an analysis would have been impossible in this case due to the absence of accurate and complete engineering documentation (U.S. Chemical Safety and Hazard Investigation Board, 1998).

Sonat’s decision to rely on verbal instruction instead of formal written procedures posed a major operational hazard. Instead of having detailed, standardized documentation to guide workers through tasks like well testing, component purging, or separator management, knowledge was passed informally. This informal training method allowed for errors and inconsistencies. Even in day to day life, oral communication can be easily misinterpreted. In high-risk environments like oil and gas production, small errors or misunderstandings can cause fatal consequences. While written procedures provide consistent and structured understanding, the absence of such written procedures created an environment where mistakes were likely to happen. Sonat’s training program relied on on-the-job instruction, monthly safety meetings, and external courses, with on-the-job training being the primary method. However, there was no evaluation to ensure consistency or accuracy in the training, which could lead to unsafe practices being passed down. While safety meetings covered key topics and incidents, the lack of formal, process-specific training left workers unprepared for variations across different facilities, increasing the risk of errors. Sonat also relied heavily on contactors that were also not properly trained (U.S. Chemical Safety and Hazard Investigation Board, 1998).

Ethical Considerations

From the initial occurrence of the incident to the drafting of the report, the response to the Pitkin explosion followed the standard local, state, and federal procedures of the day. Indeed, local and state emergency teams arrived quickly and contained the fire, the CSB performed a thorough and competent investigation, and OSHA recommended apt solutions to prevent another such disaster. It is, however, the manner in which these solutions were handled that left much to be desired ethically. Chiefly, the lack of an implementation or enforcement method for the report’s recommendations nullified the work of the investigation and allowed Sonat to proceed with what amounted to a sternly critical letter. The absence of substantial change in American petrochemical industrial practices in the investigation’s wake appears to be a symptom of the increasingly laissez-faire manner in which the federal government has regulated corporations since the rise of neoliberalism under the Reagan Administration and its later affirmation under the Clinton Administration, during which the Pitkin explosion occurred.

During the late 1990s, Charles N. Jeffress served as the Assistant Secretary for OSHA under the Second Clinton Administration. Jeffress’ leadership of the agency was characterized by a 35% decline in safety inspections and a 187% increase in significant or fatal cases from 1993 to 1999 (Labar, 1999). Prior to the Clinton years, the Nixon, Ford, Carter, Reagan and H. W. Bush Administrations cumulatively enforced seventeen major health rules through OSHA, while the Clinton Administration did not institute any (Labar, 1999). The relaxation of federal oversight from OSHA was a fruit of Vice President Al Gore’s guiding principle of “Reinventing Government”, which sought to streamline federal processes and cut bureaucracy, which in the case of OSHA included many of its inspectors. There is nothing inherently unethical about increasing government efficiency, even if it may come at the cost of reduced public jobs. A prime, positive example of this was the Clinton Administration’s adoption of the Internet for intra-government communication and interfacing with the public. However, under Jefress’ tenure of OSHA, it would seem that meeting a workforce reduction quota was a higher priority for him than making the system work better for American workers.

Aftermath

Ultimately, the Pitkin Explosion and the four deaths that accompanied it would be no more than a second page story in local and national papers, leaving no positive advancement of American petrochemical safety in its wake. Sonat itself would descend into similar irrelevance amongst the general public, merging with El Paso Corporation in 1999, following a second explosive incident in October, 1998, that killed seven additional employees. From 2003 to the present, Sonat’s assets and those of successor corporations–largely under the Texas gas giant, Kinder Morgan–would experience over 50 more fatal incidents in the vein of the Pitkin explosion (PHMSA, 2010). As late as 2011, the United States Department of Transportation (USDOT) cited Kinder Morgan for failing to have and follow written startup and shutdown procedures, and failing to have measures that could detect and respond to atypical operating conditions (PHMSA, 2011). This inertia towards the establishment and enforcement of safety standards appears to be a symptom of a federal aversion towards corporate regulation. In the case of Pitkin, though the opportunity to establish and enforce stricter rules was present, OSHA instead chose to give recommendations and minor fines, the latter of which were dropped. More recently, in response to the spilling of 8600 gallons of oil by Kinder Morgan in Perth Amboy, New Jersey, the only punishment implemented by USDOT was a mere $425000 fine without any mechanism to ensure such an incident would not occur again (PHSMA, 2011).

As far as future extensions of this casebook chapter are concerned, it would most appropriate to delve into responses to Pitkin-esque incidents in other countries of the Developed World, the growing role of Wall Street investors in corporate scrimping on safety, the weakening of regulatory power of federal agencies that has gradually taken hold since the Reagan Administration, and how the landmark Supreme Court case of Chevron v. NRDC will impact the future of petrochemical safety in the United States.

Bibliography

Human Rights Watch. (2024, January 25). US: Louisiana’s cancer alley. Human Rights Watch.

U.S. Chemical Safety and Hazard Investigation Board. (1998). Catastrophic vessel overpressurization (Report No. 1998-002-I-LA).

Labar, G. (2003, November 5). Group: OSHA inspections decline under Clinton. EHS Today.

NASA Office of Safety and Mission Assurance. (2008, December 1). Sonat explosion.

Pipeline and Hazardous Materials Safety Administration (PHMSA). (2010, October 21). Pipeline risk report: Pipeline and informed planning alliance (PIPA).

Pipeline and Hazardous Materials Safety Administration (PHMSA). (2011). Notice of probable violation, proposed civil penalty, and proposed compliance order.