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Bio Lab Conyers Chemical Release

Overview

On September 14, 2020, a thermal decomposition event occurred at the Bio-Lab facility in Conyers, GA. The company reported the thermal decomposition of a product that contained chlorine. No injuries were reported. Interstate Highway 20 was closed temporarily due to smoke produced from the event.

Incident Snapshot

Field Value
Facility / Company Bio-Lab, Inc.
Location Conyers, GA
Incident Date 09/14/2020
Investigation Status The CSB's Investigation was released April 24, 2023.
Accident Type Thermal decomposition event
Final Report Release Date 04/24/2023

What Happened

  • At approximately 5:50 a.m., Worker #5 reported the decomposition to management and called 9-1-1.
  • Wearing a respirator, Worker #5 used a forklift to move non-decomposing super sacks of material stored in the northeast section of the building to other areas inside the warehouse to isolate them from the decomposing super sacks.
  • The Rockdale County Fire Department arrived on-site at 5:54 a.m. but did not immediately enter the building because the Bio-Lab emergency responders believed they could isolate the decomposing product by relocating storage bags using forklifts.
  • After Bio-Lab personnel moved approximately 10 pallets of the super sacks, they determined conditions were no longer safe to continue the work.
  • The forklifts used to move the materials were sliding on the wet floor, and the continued fume formation was causing visibility in the warehouse to worsen.
  • The Rockdale County Fire Department then led the emergency response operations, assisted by Dekalb County mutual aid.
  • Responders sprayed water to control temperatures of the decomposing TCCA-based formulation to prevent adjacent combustible materials from getting “hot enough to combust,” and they continued moving unaffected material away from decomposing materials.
  • At approximately 11:47 a.m., air monitoring stations were established in the Conyers parking lot and within residential areas and business properties surrounding the facility using the EPA’s Viper wireless remote monitoring system.
  • Chlorine concentrations were measured at a nearby business property approximately one-quarter of a mile from the Bio-Lab Conyers facility at concentrations as high as 12 ppm.
  • The Fire Department established an external decontamination area and moved decomposing materials to this area using forklifts and skid steers to stop the chemical reactions inside the building.
  • The Fire Department temporarily closed a portion of Georgia Interstate 20 (I-20) from approximately 7:00 a.m. to 1:00 p.m. while chemical plumes were emitting from the Bio-Lab Conyers facility.
  • Post-incident, nine firefighters were taken to the hospital for evaluation after inhaling hazardous vapors, and were subsequently released.
  • Bio-Lab Conyers facility employees relocated some of the TCCA-based formulation inventory in Plant 6 into trailers after the first event.
  • The Fire Department had remained on-site performing fire watch activities as a precaution at the request of Bio-Lab Conyers when, on September 18, 2020, a second decomposition occurred in one of the trailers.
  • The probable cause of this second event was the decomposition of a TCCA-based formulation that had gotten wet or heated during the September 14, 2020, event.

Facility and Process Context

  • Bio-Lab, Inc. is a KIK Custom Products subsidiary that manufactures and supplies pool and spa chemicals, including chlorinated isocyanurates.
  • Bio-Lab’s TCCA-based formulation is one of the chemicals manufactured at the facility.
  • Plant 6
  • The Fire Department remained on-site performing fire watch activities as a precaution at the request of Bio-Lab Conyers.

Consequences

  • Fatalities: There were no reported injuries from this event.
  • Injuries: There were no reported injuries from this event. Post-incident, nine firefighters were taken to the hospital for evaluation after inhaling hazardous vapors, and were subsequently released. There were no reported injuries in the second event.
  • Environmental Release: A large plume of hazardous gases, including toxic chlorine, was released into the air and crossed the facility boundary. Chemical plumes were emitting from the Bio-Lab Conyers facility. Chlorine concentrations were measured at a nearby business property approximately one-quarter of a mile from the facility at concentrations as high as 12 ppm.
  • Facility Damage: The TCCA-based formulation decomposition and fire destroyed a production building at the Bio-Lab facility and damaged additional structures. Plant 4 was destroyed, and the Finished Goods Warehouse was severely damaged.
  • Operational Impact: The Fire Department temporarily closed a portion of Georgia Interstate 20 (I-20) from approximately 7:00 a.m. to 1:00 p.m. while chemical plumes were emitting from the facility.

Key Findings

Immediate Causes

  • rainwater contacting stored trichloroisocyanuric acid-based formulation
  • Category 4 Hurricane Laura winds damaged portions of the facility’s building roofs that were not built to current wind design requirements
  • The probable cause of this second event was the decomposition of a TCCA-based formulation that had gotten wet or heated during the September 14, 2020, event.

Contributing Factors

  • Bio-Lab’s inadequate preparation for extreme weather
  • Bio-Lab’s deficient process hazard analysis action item management system
  • insufficient regulatory coverage of chemicals with reactive hazards
  • Bio-Lab’s inadequate and largely nonfunctional fire protection system
  • the absence of automatic extinguishing systems
  • access to the decomposing pallets was hindered by other surrounding poorly stacked pallets of materials
  • The forklifts used to move the materials were sliding on the wet floor
  • the continued fume formation was causing visibility in the warehouse to worsen

Organizational and Systemic Factors

  • Bio-Lab did not learn the importance of preparing for extreme weather after the 2017 Arkema incident.
  • Bio-Lab did not adequately implement industry guidance for preparing for extreme weather.
  • Bio-Lab had no documentation that the 2010 PHA recommendation was ever implemented.
  • Bio-Lab communicated that it does not have a PHA action item management system.
  • Bio-Lab voluntarily established a process safety management program for its facility modeled after some of OSHA’s Process Safety Management elements.
  • Bio-Lab did not ensure that personnel could activate its rental backup generator.
  • Bio-Lab did not adequately maintain its fire protection system to ensure its functionality.

Failed Safeguards or Barrier Breakdowns

  • Bio-Lab did not implement the 2010 PHA recommendation to consider evaluating warehouse roof structure for hurricane conditions; verify warehouse is built to withstand high winds.
  • Bio-Lab did not conduct activities described in the CCPS Monograph Assessment of and Planning for Natural Hazards for its facility buildings.
  • Bio-Lab did not have automated fire sprinklers in Plant 4 or the Finished Goods Warehouse.
  • Bio-Lab had neither a fire detection system nor an automatic fire sprinkler system in either Plant 4 or the Finished Goods Warehouse.
  • Bio-Lab’s backup generator was not functional before the hurricane.
  • One of the diesel fire water pumps was nonfunctional before the hurricane made landfall.
  • The employees did not have a manual or operating procedure to reference for the rental generator.
  • The Rockdale County Fire Department did not immediately enter the building because the Bio-Lab emergency responders believed they could isolate the decomposing product by relocating storage bags using forklifts.
  • The Fire Department temporarily closed a portion of Georgia Interstate 20 (I-20) while chemical plumes were emitting from the facility.

Recommendations

  1. 2001-01-H-R1 | Recipient: Occupational Safety and Health Administration (OSHA) | Status: Previously Issued Recommendations Reiterated in This Report | Summary: Amend the Process Safety Management (PSM) Standard, 29 CFR 1910.119, to achieve more comprehensive control of reactive hazards that could have catastrophic consequences.
  2. 2001-01-H-R3 | Recipient: U.S. Environmental Protection Agency (EPA) | Status: Previously Issued Recommendations Reiterated in This Report | Summary: Revise the Accidental Release Prevention Requirements, 40 CFR 68, to explicitly cover catastrophic reactive hazards that have the potential to seriously impact the public, including those resulting from self-reactive chemicals and combinations of chemicals and process-specific conditions.
  3. 2020-05-I-LA-R1 | Recipient: Bio-Lab Lake Charles | Status: New Recommendations | Summary: Evaluate the hazards to the Bio-Lab Lake Charles facility from hurricanes and accompanying wind, rainwater, floodwater, or storm surge forces. Implement processes and safeguards for protection against those hazards.
  4. 2020-05-I-LA-R2 | Recipient: Bio-Lab Lake Charles | Status: New Recommendations | Summary: Develop and implement an improved Process Hazard Analysis (PHA) action item management system.
  5. 2020-05-I-LA-R3 | Recipient: Bio-Lab Lake Charles | Status: New Recommendations | Summary: Perform process hazard analyses (PHAs) on all buildings and units processing or storing trichloroisocyanuric acid. Ensure that the PHAs are revalidated at least every five years. Also include the building design basis as process safety information for the PHA team to reference during their analysis.
  6. 2020-05-I-LA-R4 | Recipient: Bio-Lab Lake Charles | Status: New Recommendations | Summary: Revise the Bio-Lab Lake Charles emergency response plan to require that the site’s fire protection system is properly maintained and routinely function-tested, emergency and fire protection equipment is checked regularly one month before the start of the U.S. hurricane season, and site personnel are trained on the use of all emergency generators and other emergency equipment at least one month before the start of the U.S. hurricane season.
  7. 2020-05-I-LA-R5 | Recipient: Louisiana Governor and Louisiana State Legislature / Secretary of the Louisiana Department of Environmental Quality | Status: New Recommendations | Summary: into effect.
  8. 2020-05-I-LA-R6 | Recipient: U.S. Environmental Protection Agency (EPA) | Status: New Recommendations | Summary: Implement the five open recommendations issued in the 2022 U.S. Government Accountability Office Report titled Chemical Accident Prevention: EPA Should Ensure Regulated Facilities Consider Risks from Climate Change.

Key Engineering Lessons

  • Buildings storing reactive chemicals such as TCCA-based formulation require design and protection against hurricane wind and water intrusion consistent with the hazard.
  • Automatic fire detection and automatic sprinkler protection were absent in Plant 4 and the Finished Goods Warehouse, limiting early control of the event.
  • Emergency power and fire water systems must be functional and operable before severe weather events.
  • PHA recommendations and action items need an effective management system so identified hazards are actually addressed.
  • Emergency response planning should include pre-season checks and training for generators and fire protection equipment.

Source Notes

  • Primary incident details were taken from the final report extract (source_priority 1).
  • The release schedule document (source_priority 4) was not used for incident facts because it contained only publication timing information and no investigative details.
  • The final report extract included references to both the Lake Charles incident and the Conyers follow-on decomposition events; the dataset preserves the Conyers incident metadata provided in the crawler while retaining only directly supported details from the final report extract.
  • Recommendation 2020-05-I-LA-R5 was preserved as provided, including the truncated summary text in the source extract.

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