To,
Dr. P. Krishnaiah, I.A.S. (Retd.)
Chairman, APPCB
Sub: Misinformation and lack of transparency in toxic release incidents and accidents in general – Incident at Tagoor laboratories in particular
Dear Dr Krishanaiah Garu,
Fatal accidents are happening regularly in Telugu states, and AP is leading in fatalities. We have been following the accidents since the uncontrolled release of styrene in May 2020. We find that lives are lost due to criminal negligence of safety and unconcern for the right to life of poor workers. Systems put in place for overseeing safety at workplaces are corroded from within and made dysfunctional. Most of the deaths could have been avoided without any great cost to management. A safety culture is all that is needed.
Andhra Pradesh Pollution Control Board (APPCB) officials keep saying safety is not their responsibility, not knowing that process safety and environmental protection are intertwined and inseparable. In all OECD countries, environmental agencies deal with safety through mandatory risk management programs that require the implementation of risk management plans to prevent accidents and mitigate their consequences. We wonder why APPCB is acting as a first respondent in several accident cases taken by NGT while rejecting any mandate for safety in industries.
APPCB officials have been members of all investigation committees on accidents and even drafted several investigation reports. All these reports are never made available in the public domain. Some of the reports accessed through the NGT website show fundamental errors, because of the lack of engagement with safety. Anyone can make errors, but the opaque and closed system at APPCB does not help in eliminating these errors.
We are quite disturbed by the way APPCB, as the first respondent, dealt with the case of the fire and explosion accident at Sahiti Pharma, Achutapuram. The company causing 6 deaths got away without even a penalty. APPCB was so eager to revoke the SPO well before the NGT case was settled. It sought repeated adjournments for 9 months after the announcement of the final hearing claiming to submit reports to prevent future accidents. The submissions had nothing relevant and worthy to prevent a similar accident. The committee appointed by the district collector to inquire into the accident included an APPCB official. The report was not completed in 16 months. It is not known if it is completed even now. How can our workplaces be safe with such a lack of concerns for safety in the regulatory bodies?
This week several employees of Tagoor Laboratories, JNPC, Parawada were exposed to a toxic gas release in the early hours of 27 November 2024 but were not shifted to any hospital for about 6 hours. This exposure caused the death of two workers and the hospitalization of 32 to date. It is reported that all the 190 more persons on duty that day were also checked for health effects later. One worker’s condition is critical. There are 30 persons undergoing treatment at hospitals now.
The information given in the press refers to the release of hydrogen chloride while mixing Hydrochloric acid with chloroform. Why were they doing that? It may be noted that Hydrochloric acid and chloroform are immiscible and do not react. Our inquiries reveal that tri-phosgene, a solid powder, was being dissolved in chloroform in preparation for the synthesis of the first stage raw material for lamivudine production. We use scientific reasoning to rule out the release of Hydrogen Chloride causing the incident and identify phosgene as the most probable cause. We welcome any correction to this with evidence.
Likely, the chloroform used was not free of water (It can contain 0.8% of water at room temperature) or contained impurities like alcohols, amides, Amines, ferric oxide, and alkaline chemicals capable of decomposing tri-phosgene.
These contaminants could be responsible for the decomposition of tri-phosgene to phosgene. This is yet another example of open feeding of solids through a manhole (At Synergene fire and explosion were due to that) instead of closed feeding to avoid any exposures and releases. In the eventuality of any toxic gases released during feeding, these should be directed to a scrubber or suitable removal system. These are part of an inherently safe design missing from our industries. Authorities investigating the accident should look into the presence of contaminants that caused the decomposition of tri-phosgene.
Normally, tri-phosgene dissolution involves heating the kettle with hot water. If the hot water temperature is too high, tri-phosgene is decomposed to produce highly toxic gases such as phosgene.
The presence of impurities (such as organic amines) can lead to the decomposition of tri-phosgene. All these possibilities should be checked and the actual cause identified.
Permissible Exposure Limit (PEL) for phosgene is 0.1 ppm for OSHA. “The odor threshold for phosgene is 5 times higher than the OSHA PEL. Thus, odor provides insufficient warning of hazardous concentrations.” Exposure happens without knowing. Only after symptoms of exposure manifest can one realize the harm.
The Immediate Danger to Life and Health (IDLH) value for Phosgene is 2 ppm. Exposure to phosgene at 5 ppm for 30 minutes could be fatal.
Hydrogen chloride: Acute exposures of hydrogen chloride beyond the IDLH value of 50 ppm could be fatal. However, the effects of HCl are immediate and localized. The effects of exposure are not delayed.
Phosgene: As per the information provided by “Agency for Toxic Substances and Disease Registry” (ATSDR) USA “Phosgene is a severe pulmonary irritant. However, serious pulmonary effects may be delayed up to 48 hours.”
“Phosgene has relatively little odor or irritating effects at moderately toxic air concentrations; serious health effects may occur without warning or symptoms. Because serious complications may be delayed up to 48 hours after exposure, all patients who have suspected phosgene exposure should be transported to a medical facility for evaluation.”
“There are no tests to positively determine whether you have been exposed to phosgene. If you suspect that you may have been exposed to phosgene, a chest X-ray may be the quickest way to determine if your lungs have been damaged.”
Admitting 18 workers more in the hospital on 28.11.2024, nearly two days after the exposure points to the fact of low phosgene exposure. The company has been hiding the truth and misinforming the public. Regulatory officials as usual abandon the people and promote the story fed by the offending company. These officials have not questioned the false information being spread through the media. What protections can people expect from such a system?
How are the APPCB and other departments involved different from Union Carbide? Phosgene is a raw material in the production of methyl isocyanate that caused the Bhopal tragedy. Union carbide hid the truth about MIC release and its effects, our officials have hidden the truth about phosgene release from the public. Any higher quantitative release of phosgene would have caused a major tragedy with such secrecy and lying. Please at least now tell the truth. Your silence becomes betrayal in the words of Martin Luther King.
Sincerely,
Dr K Babu Rao
Dr K Venkat Reddy
Dr Ahamed Khan
Dr M Bapuji
Dr C V S Murty
Copy to: MS, APPCB
Collector, Anakapalli District
