MM&A: Mislabeled Hazardous Cargo!

"Crude oil really isn't supposed to explode. But according to an article in Bloomberg on the investigation of the MM&A train accident that might not be true of the oil coming from North Dakota's booming Bakken region.

And three major oil companies have won the right to turn down suspect shipments. Enbridge Inc., Tesoro Corp.,  and True companies all won the approval of the Federal Energy Regulatory Commission to refuse oil that had high levels of hydrogen sulfide, a highly flammable gas that can be a byproduct of oil production, after they started seeing oil with concentrations tens and even hundreds of times higher than what regulators have deemed safe for exposure."  [Source: Mother Jones]

Well. today (Wednesday 9-11) the Canadian Transportation Safety Board (TSB) said the oil contained in the rail cars involved in the Lac-Mégantic disaster in July was mislabeled and was more flammable than previously thought. “The lower flash point of the crude oil explains in part why the crude oil ignited so quickly,” said Donald Ross, the lead TSB investigator on the Lac-Mégantic disaster.

Petroleum crude oil is considered a dangerous good and is categorized into one of three groups ranging from Class 1, which is the most flammable and volatile, to Class 3, which is the least. The TSB determined over the course of its investigation that the crude being transported in the Lac-Megantic disaster was mislabeled as a Class 3, or Packing Group III product, when in fact it was a Class 2, or Packing Group II product.

A placard provides  a variety of information through several different methods.

The first information indicator is the color of the placard. Red indicates flammable, green indicates nonflammable, yellow indicates oxidizer, blue indicates dangerous when wet, white indicates inhalation hazard and poison, black and white indicates corrosive (acid and caustic), red and white indicates flammable solid or spontaneously combustible, depending on the color pattern on the placard, white and yellow indicates radiation or radioactive, orange indicates explosives, white with black stripes indicates miscellaneous hazardous materials, and there is another red and white placard that says “dangerous” on it.

The second information indicator is the number in the bottom corner of the diamond. This number refers to the hazard classes as used internationally and by the United States DOT. There are 9 classes for hazardous materials:
• Class 1 explosives
• Class 2 gases (flammable, nonflammable, inhalation hazard/poison, or oxygen)
• Class 3 liquids that burn (flammable and combustible liquids, based on their flashpoint)
• Class 4 flammable solids, spontaneously combustible, or dangerous when wet materials
• Class 5 oxidizers and organic peroxides
• Class 6 poison/toxic solids and liquids, infectious materials
• Class 7 radioactive (three sub classes)
• Class 8 corrosives (acids and bases)
• Class 9 miscellaneous

The third information indicator is the symbol in the upper corner of the diamond. A variety of symbols are used to indicate combustion, radiation, oxidizers, compressed gas, destruction of materials and skin by corrosives, an explosion, or skull and cross bones to indicate poisons.

The fourth information indicator is the four digit United Nations (UN) number used for the hazardous material contained in the container. There are hundreds of four digit numbers used, from 1001 (acetylene) to 9279 (hydrogen, absorbed in metal hydride). The number in some cases is specific to a chemical and in other cases reflects a variety of hazardous materials. (For example, 1017 is only used for chlorine, 1005 has five chemical listings, 1993 is used for eight chemical listings and 2810 is used for 36 chemical listings.)

In the case of the MM&A oil train, the placard on the tanker reads UN ID Number is 1267. Crude Oil.  Most "first responders" carry the Emergency Response Guide Book in their vehicles, which is the  "last word" on hazardous materials, their characteristics, and how to deal with them when involved in a spill or fire.

To demonstrate how this Guidebook works, open the Guide Book link (.pdf) above to Guide Number 128, to see the hazards associated with Crude Oil, and remedial response.

At the same time, because there were different wells involved in supplying the crude involved, the crude was labeled in several different ways on their initial material safety data sheets [MSDS]. Investigators reviewed 10 different msds's, and some reported the goods as Class 1, Class 2, and Class 3, and other with no classification whatsoever!

But records show the crude oil was labeled Class 2 when it was transferred from the wellheads to the transloading facility, where they were loaded into the railcars. “We had records on our investigation file that it was transported as Packing Group II, and then the train information, based on the shipper’s information, was shipped by rail as Packing Group III.”

The derailment also draws into question the safety of transporting similar goods in the controversial 111A rail cars involved in the disaster. The TSB has been pushing since 2004 for a more resilient type of rail care to be used than the current 111A tank cars commonly used in Canada (and US) to transport goods.

A similar effort is afoot in the U.S. because the 111A cars have thinner walls and lack the head shields or housings that help prevent damage in the event of a derailment and are commonly available on newer rail cars.

The TSB accident data suggests more than 60% of spills from 111A cars come from damaged top fittings, and more than 25% from structure failure, mainly through punctures in the head or shell. As a result, TSB investigators will be looking into what role the type of rail car used had in the accident. (Source:  Montreal Gazette.)

One rail-safety advocate even called the DOT-111 the "Ford Pinto" of rail cars. 69% of tank cars on North American rails are DOT-111 specification.

Finally, the Montreal, Maine & Atlantic track condition has become the focus of attention. I cannot imagine a sane person allowing a hazardous material train to operate on such junk.

Once again reflect on the words spoken by the Chair of the TSB Wendy Tadros:

"At the TSB we hold by the theory that no accident is ever caused by one thing, it's always a series of things.  It always involves the organization and the way that they operate, so we have to look deeply into that. It never comes down to one individual." 

  See Also:
•  The Night a Train Destroyed a Town
•  MM&A:  Unit Oil Train
•  MM&A:  The Investigation Continues
•  MM&A:  Opps! Mr. Burkhardt 

[Editors Note: This article would not have transpired had it not been for a "heads up" by my sister! "Thanks, Les!ey!"]