US EPA Y2K Chemical Emergencies Alert
In Feb 1999 the US EPA issued an alert saying that y2k could
increase the likelihood of accidental releases at chemical plants. Their
formatted document is available from:
http://www.epa.gov/ceppo/pubs/y2kalert.pdf
A number of people wrote me that they couldn't access the article. To view
the original article, you must have Adobe Acrobat Reader installed on your
computer. This free software is available at
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If you cannot access the original article or wish to forward an email version,
I've supplied the text below.
Tom
PREVENT YEAR 2000 CHEMICAL EMERGENCIES
The Environmental Protection Agency (EPA) is issuing this Alert
as part of its ongoing effort to protect human health and the environment
by preventing chemical accidents. Alerts are issued when EPA becomes aware
of a significant hazard. It is important that facilities, State Emergency
Response Commissions (SERCs), Local Emergency Planning Committees (LEPCs),
emergency responders and others review this information and take appropriate
steps to minimize risk. The Alert is targeted at the chemical process industry
to increase awareness of the potential for chemical safety problems due
to upcoming date changes.
United States Office of Solid Waste EPA 550-F-99-003 Environmental Protection
and Emergency Response February 1999 Agency (5104) www.epa.gov/ceppo
THE YEAR 2000 (Y2K) PROBLEM
It is 11:59 p.m. on December 31, 1999. The Year 2000 problem (also known
as the "millennium bug") could disrupt your chemical process and
storage operations. Is your facility prepared? Here are some examples of
what could happen.
* A safety system, designed to detect emissions of deadly hydrogen sulfide
gas, shut down during a Y2K test on an oil rig in the North Sea.
* At a smelter in New Zealand, all the process controls stopped working
at mid-night on December 31, 1996, because programmers had failed to take
into account that 1996 was a leap year. The loss of process control damaged
equipment valued approximately at $600,000.
* A utility company in Hawaii ran tests on its system to see if it would
be affected by the Y2K bug. The entire system shut down.
At any size company, the Y2K issue could threaten worker and community safety
and health. It could cause complete shutdowns of machinery or safety-related
systems or could generate erroneous information (e.g., wrong temperature)
which could lead an operator to take unsafe or improper steps. For chemical
process industries, the Y2K problem could increase the potential for process
shutdowns and accidental chemical releases.
This alert raises awareness about the Y2K problem and offers a strategy
to address the problem. However, given that the Year 2000 is approaching
soon, facilities should dedicate increasingly more efforts on developing
contingency plans to prepare for unanticipated events like those above.
Contingency planning is especially important for facilities that have not
started or have made little progress in assessing and remediating the Y2K
problem.
In addition to administrative and management systems, (payroll, financial
records, inventory), the Y2K problem could affect three parts of your facility
- your software, your control/process equipment, and critical services provided
to you by others such as utilities and feedstock suppliers.
YOUR SOFTWARE
The Y2K dilemma is the result of a standard practice used in software programming.
To save memory space and keep costs down, computer programs and microchips
were traditionally designed to recognize only the last two digits of a year.
This means that when the year 2000 rolls around, computers may not be able
to distinguish whether 00 means 1900 or 2000.
This could cause computer programs to crash and systems to shut down. For
example, if you rely on computer systems to notify you to schedule maintenance
or retire equipment, the system may not properly notify you because the
computer cannot recognize dates after December 31, 1999. See the "Dates
to Watch" box for a few other dates that might cause problems.
YOUR CONTROL/PROCESS EQUIPMENT
Even if your operations do not directly use computers, some of your control
machinery, process equipment, automation equipment (e.g., valves, pumps),
and emergency protection equipment (e.g., fire and gas detectors), may be
embedded with computer chips that are date-sensitive. If these chips misunderstand
the date change, the equipment could fail or malfunction, causing process
upsets that lead to accidents. For example, an automatic valve with an embedded
chip could fail in such a way that the valve turns off the feedstock supply.
Because Y2K problems can affect so many devices, cascading failures are
possible.
YOUR SERVICE PROVIDERS
The Y2K problem can affect manufacturing, electric utilities and energy
suppliers, water utilities, telecommunications, transportation, and other
sectors that are critical to your facility operations. Disruption of these
services can become your problem. For example, a water supply utility could
shut down, causing loss of critical cooling water to chemical reactor systems.
Most plants also have suppliers that produce raw and in-process materials
that are vital to running their processes. Many plants have customers who
accept products through "just-in-time" delivery schedules. Failure
to receive these materials could result in safety hazards at your plant.
SOME DATES TO WATCH
* Sept. 9, 1999: Many computer systems use 9/9/99 as file purge date
* Jan. 1, 2000: Rollover may halt, confuse, or otherwise disrupt many systems
and devices
* Feb. 29, 2000: Many systems may not recognize 2000 as a leap year
* Oct. 10, 2000: First time date field uses maximum length
* Dec. 31, 2000: Some systems may not recognize the 366th day
HAZARD AWARENESS AND REDUCTION
The Y2K concern is real, and the solution may not be easy. However, the
effort now to identify and fix the problem will reduce the risk of more
costly impacts of business disruptions, safety failures, and accidental
chemical releases. While many large companies in the chemical industry already
have started addressing the Y2K problem, many small businesses are just
beginning to realize the impact that the Y2K problem may have on their operations.
STEPS TO ADDRESS THE PROBLEM
There are several steps you can take to identify and address the Y2K problem.
Throughout this step process, you should be sure to document what you have
done. For additional help in performing these steps, you could contact an
appropriate association, trade group, or industry colleague for particular
suggestions and best practices for your industry. If you are unable to implement
these steps in-house, consider using an outside consultant. There is also
a wealth of information on how to follow these steps (See the "Information
Resources" at end of Alert).
1. Identify and check systems for Y2K compliancy. Each company should check
its systems to determine if they are Y2K compliant. Make a list of the date-dependent
components of your systems that are likely to be affected by the "millennium
bug." (See box on "Examples of Equipment to Check"). Focus
on software and equipment with embedded chips, and ask yourself if your
equipment or systems use or depend on date information, for example, does
the system order/retrieve information by date, or perform date-based calculations?
Prioritize the items on your list based on their potential for causing health,
safety, and environmental concerns and how critical they are to business
production. You should review your risk assessments or hazard analyses (e.g.,
HAZOP) to be certain that Y2K vulnerable equipment and devices are inventoried
and addressed. Starting with the most critical equipment, check with your
supplier, installer, or manufacturer to determine if the system component
is Y2K compliant (see section on "Information Resources" for some
vendor web sites).
2. Remedy problem. If critical equipment can be affected by the Y2K problem,
you have several options including repairing, modifying, or replacing the
equipment. Where mission-critical systems cannot be assessed, remediated,
and corrected, you could consider operating the system in a manual override
mode. Staff would need training on new equipment or refresher training on
procedures for manual operation. Additional staff may be needed when automated
processes are switched to manual.
3. Test systems. Your systems and equipment should be tested to make sure
the Y2K malfunction is remedied. Do not forget to test dates other than
January 1, 2000 (see the "Dates to Watch" box). Before you test,
alert local emergency officials and make sure your employees and community
are prepared for any possible failures that may have an adverse effect on
health and safety or the environment. (See EPA's new enforcement policy
on Y2K testing in section "It's Your Duty").
4. Develop and implement contingency plans. Contingency plans are essential
in your strategy to address the Y2K problem. Even if you believe your system
is Y2K compliant, you should develop a Y2K contingency plan to prepare for
unanticipated problems. Your contingency plan should not depend on backup
equipment and systems that could also fail because of the Y2K complication
(e.g., backup generator, automatic shutdown system). Also, you may need
to address staffing and training for meeting Y2K contingency plans and to
handle disruptions to transportation infrastructure and telecommunications.
Facilities should not overlook the possibility that non-Y2K compliant computers
and chips in telecommunications and radio may prevent police, fire, and
mutual aid assistance from arriving promptly or at all. Inform local officials
concerned with emergency situations when testing equipment, and involve
employees in planning for testing and in responding to unexpected system
changes. As part of your contingency planning you could:
* Work with and share solutions and lessons learned with your partners,
suppliers, neighbor facilities, associations, and customers to ensure that
they, too, are addressing the Y2K issue.
* Work with your SERC, LEPC, and other off-site emergency management support
to review emergency response procedures and ensure that the procedures and
resources available cover possible Y2K consequences.
* Make sure employees are trained and prepared to shut down the process
manually, if necessary.
* Consider scheduling downtime and maintenance over the end of 1999 and
beginning of 2000. During shutdowns, systems can be isolated and Y2K tested.
However, before you schedule downtime, recognize that startups and shutdowns
have their own risks which must be balanced against the potential risks
from Y2K problems. Also, if you are a large power user, notify your utility
if you plan to have a shutdown. Utilities could have operating problems
if power demands unexpectedly drop, particularly if many facilities shut
down.
* Have a full staff available for a number of hours just before and after
critical date changes for unanticipated emergencies.
* Consider conducting an exercise using a Y2K scenario to improve emergency
response capabilities. One community, Lubbock, Texas, already has successfully
conducted such an exercise and learned a number of important lessons, including
the need to prevent emergency communications failure. Remember, in terms
of contingency planning, facilities should take advantage of the one positive
piece of information that the Y2K problem offers us: the ability to know
when it will occur.
EXAMPLES OF EQUIPMENT TO CHECK
- Controllers
- Alarms
- Lighting
- Robots
- Air monitoring/leak detection devices
- Hazard communication databases
- Underground storage tank monitors
- Security systems
- Generators
- Lab instruments
- Environmental control systems
- Controllers for refrigeration, valves, pumps, sensors and analyzers
- Programmable control systems
- Safety shutdown systems
- Fire detection systems
- Explosion suppression systems
- Elevators
- Conveyors
- Vehicles
IT'S YOUR DUTY
Under the General Duty Clause of the Clean Air Act (CAA section 112(r)(1)),
owners and operators of facilities with hazardous substances have a general
duty to prevent and mitigate accidental releases, including those caused
by Y2K failures. Also, under EPA's Risk Management Program (RMP) Rules (CAA
section 112(r)(7)), accidental release scenarios related to Y2K problems
(e.g., loss of utilities, interruption of raw material deliveries, failure
of monitoring devices) would be reasonable alternative scenarios to consider.
The public may view any Y2K-related operating problems that occur in January
2000 as a test of the quality and reliability of your RMP. In addition,
EPA has initiated an enforcement policy designed to encourage prompt testing
of computer-related equipment to ensure that environmental compliance is
not impaired by the Y2K computer bug. Under this policy, EPA intends to
waive 100% of the civil penalties and recommend against criminal prosecution
for environmental violations caused by tests designed to identify and eliminate
the Y2K-related malfunctions. This policy is limited and subject to certain
conditions. (See complete policy on EPA's Year 2000 web site listed in "Information
Resources.")
The Occupational Safety and Health Act (OSHA) has a similar General Duty
Clause (section 5(a)(1)) for protection of employees from hazardous situations
involving the use of highly hazardous substances. Also, OSHA's Process Safety
Management (PSM) Standard is intended to prevent or minimize injury to employees
from accidents (including those caused by Y2K problems) involving highly
hazardous chemicals.
INFORMATION RESOURCES
Below are some resources that will help you to get started to address the
Y2K problem at your facility. Future updates of this resource list can be
found at the EPA CEPPO Website below.
Environmental Protection Agency (EPA) Provides information on EPA's efforts
to address the Year 2000 problem. This includes EPA's Y2K enforcement policy,
and under the heading "Environmental Y2K Sectors," the Office
of Water guidance for wastewater systems (including a checklist of basic
systems) and the Office of Solid Waste flyer on waste management and the
Y2K problem. http://www.epa.gov/year2000/
EPA's Office of Solid Waste and Emergency Response Y2K information. http://clu-in.com/y2k.htm
EPA's Chemical Emergency Preparedness and Prevention Office (CEPPO) has
this Y2K alert and updates. http://www.epa.gov/ceppo
Occupational Safety and Health Administration (OSHA) The OSHA web site has
a bulletin on Y2K. http://www.osha.gov/Y2knews.pdf
Chemical Safety and Hazard Investigation Board (CSB) The CSB has sponsored
a conference and report on the Y2K problem and the potential for accidental
chemical releases. Relevant Year 2000 sites can be found on the CSB Web
site by clicking on Chem Links and then searching on "Year 2000."
http://www.chemsafety.gov
U.S. Small Business Administration (SBA) This web site offers information
specific to helping small businesses address the Y2K problem. It provides
a list of questions to help identify date-sensitive equipment. SBA also
has an extensive list of links to major corporations that post their Y2K
status online. http://www.sba.gov/y2k/
Hotline: 1-800-U-ASK-SBA (1-800-827-5722)
General Accounting Office Guide: "Year 2000 Computing Crisis: Business
Continuity and Contingency Planning" has general principles for use
by businesses as well as government agencies. http://www.gao.gov/special.pubs/bcpguide.pdf
National Institute of Occupational Safety & Health (NIOSH) NIOSH has
Y2K case studies, a web forum, vendor list, and an equipment manufacturer
directory. http://www.cdc.gov/niosh/y2k/y2k-hmpg.html
Prevent Year 2000 Chemical Emergencies 4 February 1999Health & Safety
Executive (UK) The British Health and Safety Executive web site offers several
reports on the Y2K problem. Of particular interest to the chemical industry
is "Health and Safety and the Year 2000 Problem - Guidance on Year
2000 Issues As They Affect Safety-Related Control Systems" and "Contingency
Planning for a Safe Year 2000." http://www.open.gov.uk/hse/dst/2000indx.htm
National Fire Data Center A basic system check that can help you determine
if your organization's computer system is Y2K compliant is available on
this website. http://www.usfa.fema.gov/y2k/y2kcom.htm
Electronic Systems Center of the Air Force Materiel Command (site maintained
by Mitre Corporation) The site provides information on Y2K certification,
compliance, solutions, testing and evaluations, contingency plans, cost
estimation, tools and services. http://www.mitre.org/technology/y2k
National Institute of Standards and Technology The site has links to free
software tests, self-help tools and product compliance status databases
for use in Y2K assessment, testing, contingency planning and remediation.
Information is provided for smaller manufacturers through the Manufacturing
Extension Partnership, a nationwide network of centers providing technical
and business assistance to smaller manufacturers. Small manufacturing firms
can call 1- 800-MEP-4MFG. http://www.nist.gov/y2k
President's Council on Year 2000 Conversion-Product Compliance Information
The site has a list of computer manufacturers' Y2K sites. http://www.y2k.gov/java/product_compliance.html
Mary Kay O'Connor Process Safety Center The site has links to compliance
status of some manufacturers' control systems. Click on Y2K information.
http://process-safety.tamu.edu/y2k/y2k.htm
Chemical Manufacturers Association (CMA) Survey CMA has developed a standard
survey form for the use of its members. This survey package is designed
to help companies assess Y2K efforts of critical suppliers and customers
and minimize the risk of service interruption. The survey (posted on 12/14/98)
can be found in the "What's New" section of the CMA website. http://www.cmahq.com
Case Study of One Chemical Manufacturer's Approach to Y2K Problem http://www.dell.com/smallbiz/y2k/studies.htm#merisol
American Petroleum Institute The site provides industry activities, company
status reports, Y2K database, and technical links. http://www.api.org/ecity/y2k/index.html
Year 2000 The site has a list of Year2000 vendors and consultants. http://www.year2000.com
National Bulletin Board for Year 2000 Provides tools for analysis, conversion,
and testing for Y2K problems. http://it2000.com/solutions/index.html
Y2K Freeware and Shareware http://www.aphis.usda.gov/y2k/wares.html
Year 2000 Embedded Systems Vendors, Associations, and Manufacturers http://ourworld.compuserve.com/homepages/roleigh_martin/y
2k_com.htm
Some PC Test Results for Y2K Problems http://www.hqisec.army.mil/y2kweb/y2kresults.html
http://www.nim.com.au/year2000/ye02001.htm
FOR MORE INFORMATION... CONTACT THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW
HOTLINE 800 424-9346 OR (703) 412-9810 TDD (800) 553-7672 MONDAY-FRIDAY,
9 AM TO 6 PM, EASTERN TIME
TO OBTAIN COPIES OF THIS PUBLICATION, CONTACT NATIONAL SERVICE CENTER FOR
ENVIRONMENTAL PUBLICATIONS (NSCEP) PHONE: 800-490-9198 FAX: 513-489-8695
http://www.epa.gov/ncepihom
VISIT THE CEPPO HOME PAGE ON THE WORLD WIDE WEB AT: http://www.epa.gov/ceppo
NOTICE The statements in this document are intended solely as guidance.
This document does not substitute for EPA's or other agency regulations,
nor is it a regulation itself. Site-specific application of the guidance
may vary depending on process activities, and may not apply to a given situation.
EPA may revoke, modify, or suspend this guidance in the future, as appropriate.
Prevent Year 2000 Chemical Emergencies
6 February 1999
United State Environmental Protection Agency (5104)
Washington, DC 20460