Dr. Peter Sandman is one of the country’s foremost risk communication and outrage management consultants, and has been in the middle of helping many companies and industries manage communication activities in the wake of disasters. He, like the rest of America, was a spectator to the events at the West Fertilizer facility, and we asked Sandman to share his thoughts, and some advice, from his perspective as an objective observer and professional consultant.
Q. Did you have any personal/professional reaction to the events in West, TX? Anything that came to you “top of mind” when you considered the impact something like this could have on an industry?
When I first heard about the April 17 explosion in West, TX, my reaction was identical to everyone’s reaction: shock and horror at the awful pictures and sympathy for the victims. The Boston Marathon bombings two days earlier and the standoff that followed may have muted my reaction (and the media’s reaction) somewhat – but it was still an awful story.
In the days that followed, I stopped focusing on the horror and turned my attention to three issues:
1. Is this an example of egregiously bad risk management and/or risk regulation, or was this facility fairly typical until the accident?
After pretty much every industrial accident, the media (and later the authorities) unearth evidence of precursors – near-misses, regulatory infractions and other prior bad acts, safety precautions management could have taken but didn’t that might have prevented the accident, etc. The implication is that the company or the regulators or both were irresponsible. But it’s rare for anyone to look with equal scrutiny at comparable facilities where nothing went wrong, to see if they show a similar pattern.
If comparable facilities don’t show a similar pattern, then we have a “bad apple” – a management that misbehaved in ways other managements don’t, and/or a regulator that neglected responsibilities other regulators don’t. To the extent that that’s true, the accident will be of long-term interest chiefly to prosecutors, not to policy analysts. It’s a unique one-off, so it has few if any policy implications.
If comparable facilities do show a similar pattern, on the other hand, then we have a “normal” situation that went badly awry in one place. By definition, it was equally likely to have gone badly awry someplace else instead, and it is still equally likely to go badly awry someplace else at any moment. In that case, we need to figure out how likely that was (and remains) – in particular, whether it was (and remains) likely enough that we want to take or require additional precautions in future. Is the accident simply evidence that “accidents happen” and we should learn to expect an occasional disaster, or is it evidence of a systemic problem or even a systemic scandal that needs to be exposed and fixed? That’s my second question.
But we need to answer the first question first. Nothing sensible can be deduced from any accident until we have some idea in what ways the facility was weird and in what ways it was typical.
• Did the West facility store more ammonium nitrate than most such facilities? Did it store more than was allowed?
• Did it take the conventional precautions (alarms, sprinklers, night guards, fire barriers, etc.)? Did it take the required precautions?
• Where did it stand vis-à-vis comparable facilities with regard to the permits it had, the frequency with which it was inspected, the infractions that were found, the fines it paid, etc.?
• Was it unusual or ordinary in being situated so close to homes and schools, and was that legal?
• Was its one-million-dollar liability insurance less than usual or less than required?
• Is Texas different in any of these regards from most other states?
These are the sorts of questions I was asking myself as I read the media reports.
2. Was what happened in West an unlikely disaster with few if any policy implications, or was it “an accident waiting to happen” that should lead to new industry practices and new regulatory standards?
To the extent that the West explosion wasn’t a unique one-off (my first question), what matters is whether the risk that neighbors of comparable facilities still face is an acceptable risk or one that should be reduced.
The answer to that question depends partly on facts: How big is the risk? What could be done to reduce it? How much additional protection would these measures provide, and at how much additional cost?
But it’s fundamentally a values question: How safe is safe enough?
Regulators ask the values question (and the factual questions) when they decide how strictly to regulate. Industry associations ask it when they decide what industry codes to promulgate. Companies ask it when they decide what additional voluntary precautions to take – or what required or recommended precautions to ignore. Communities ask it when they decide what zoning standards to impose and what emergency planning measures to implement.
Above all, individuals ask it when they decide whether to live near such a facility and – if they do live near one – whether to exert pressure for tougher standards and more protective precautions.
A key implication of the values question – “How safe is safe enough?” – is that it’s almost always possible to get safer, but increased safety may or may not be worth what it costs. In the wake of a disaster, it’s naturally easier for people to assume that all precautions are worth taking than to try to figure out which ones are and which ones aren’t. I read post-disaster media coverage looking (often in vain) for efforts to counter this temptation, to explain risk-cost tradeoffs. Of course, explaining risk-cost tradeoffs isn’t something a management can afford to do after one of its facilities has experienced a serious accident. That would be horribly lacking in empathy for your company’s victims. After something goes wrong, only neutral third parties can raise the issue, and even they have to do so gingerly.
But before anything goes wrong (and again after a suitable time has passed), industries and companies can usefully launch a dialogue about risk-cost tradeoffs and how safe is safe enough. In 2006, I wrote an article for The Synergist, the journal of the American Industrial Hygiene Association, entitled “How Safe Is Safe Enough: Sharing the Dilemma.” In the blurb that introduced the article, I summarized its thesis this way: “Risk managers have no choice but to prioritize precautions and decide which ones they can implement. The claim to be taking ‘every possible precaution’ is always a lie. Risk managers who don’t want to lie can use dilemma sharing to explain why they have chosen not to take some possible precautions.”
It is still unclear whether what happened in West was an accident or a crime. On May 9, a paramedic who had volunteered as an EMS worker in West and responded to the explosion (and talked to the media about it a lot) was arrested for possession of bomb-making materials. As I write this more than two weeks later, officials still aren’t saying whether they suspect him of involvement in the fire and explosion.
Of course, risk is risk, and being vulnerable to a nut with a pipe bomb and a grudge is just as serious as being vulnerable to an act of God. It’s not crazy to believe that managers of risky facilities should be responsible for protecting their neighbors from both, and that if they can’t, they shouldn’t have neighbors. But law and public opinion tend to blame companies a lot less when there’s a terrorist, saboteur or schizophrenic to blame instead. That’s why Union Carbide argued so aggressively that its 1984 Bhopal disaster resulted from sabotage, and why activists and plaintiff attorneys argued so aggressively that it didn’t. At the very least, the policy implications of a criminal act are different from the implications of an industrial accident.
3. What kind of risk communication did management do before the explosion?
As a risk communication professional, I am of course extremely interested in the risk communication record of the West facility’s management – both its corporate owner, Adair Grain Inc., and the local executives of West Fertilizer Co.
I haven’t seen evidence that the company had talked much about the risk of a possible explosion, nor that the facility’s neighbors had worried much about that risk. Are the survivors feeling now that they should have been told more, that they should have had more opportunity to ponder the risk and decide whether they considered it acceptable? I’m pretty sure that’s how I’d feel in their shoes, but judging from the media coverage I’ve seen, few if any local residents have said as much so far. (We may eventually learn more about the company’s prior risk communications if the disaster leads to lawsuits; any such suits will almost certainly allege not just inadequate precautions but also inadequate forewarning of neighbors and regulators.)
Not telling people proactively about the possibility of an explosion someday is bad risk communication, but it’s so prevalent that it’s not widely condemned, even in hindsight after a disaster.
Actually denying that possibility is another matter entirely. Almost immediately after the West explosion, the Dallas Morning News reported that it had seen a document in which the company told the U.S. Environmental Protection Agency and local public safety officials “that it presented no risk of fire or explosion.” The rest of the story is about anhydrous ammonia, not ammonium nitrate, which makes me wonder if maybe the company’s “no risk” claim was limited to the ammonia. But if it turns out the company intentionally misrepresented the risk posed by the facility, that misrepresentation could have huge implications – legal implications as well as outrage implications.