HURRICANE FLOODING — ORGANIC PEROXIDE SPONTANEOUS COMBUSTION
Arkema Inc. Chemical Plant Fire
Arkema Inc.
📍 Crosby, TX
Incident: August 29, 2017  •  CSB Report: May 24, 2018
0
Fatalities
Organic Peroxides (Thermally Unstable — Refrigeration Required)
Chemical Involved
5
CSB Recommendations
📋 Incident Summary

On August 29, 2017, Hurricane Harvey made landfall and the unprecedented flooding that followed disabled all refrigeration systems at the Arkema Inc. chemical plant in Crosby, Texas. The plant manufactures organic peroxides -- thermally unstable chemicals that spontaneously combust when they exceed their control temperatures. Without refrigeration, the peroxides began to heat; on August 31 the first trailer caught fire. Officials intentionally ignited the remaining trailers on September 3, 2017.

The 1.5-mile evacuation zone displaced thousands of residents. Twenty-one first responders were treated after exposure to chemical smoke. The CSB found that Arkema's facility flood hazard assessment did not evaluate the risk of floodwaters disabling critical safeguards such as backup power and refrigeration, and that no adequate independent layer of protection existed to maintain refrigeration capability during a major flood event.

The May 2018 final report issued 5 recommendations to Arkema's Crosby facility, Arkema Inc. corporate, the Center for Chemical Process Safety (CCPS), and Harris County, Texas. All 5 recommendations were closed.

🔎 Key Findings
Finding 01
Hurricane Harvey Flooding Disabled All Refrigeration Systems
Floodwaters from Hurricane Harvey inundated the facility to depths that disabled both primary and backup refrigeration systems for temperature-sensitive organic peroxides, removing the only safeguard against spontaneous combustion.
Finding 02
Flood Risk Assessment Did Not Evaluate Critical Safeguard Failure
Arkema's flood hazard assessment did not evaluate whether flood levels could disable critical safeguards including backup power and refrigeration -- the assessment underestimated the facility's vulnerability to a major flood event.
Finding 03
Organic Peroxides Spontaneously Combusted Without Refrigeration
Organic peroxides stored at the facility self-heat to decomposition temperature without refrigeration. As temperatures rose, peroxides in refrigerated trailers spontaneously ignited, releasing toxic smoke into the surrounding community.
Finding 04
No Independent Layers of Protection for Flooding
The facility's safeguards against flooding -- including backup generators -- were not designed as independent layers of protection adequate to withstand the flood depths that occurred during Harvey; they failed simultaneously with primary systems.
Finding 05
21 First Responders Treated After Chemical Smoke Exposure
Law enforcement personnel enforcing the evacuation perimeter were exposed to toxic smoke. Responders lacked adequate protocols, air monitoring, and PPE guidance for working near chemical fires in an evacuation zone.
🔍 Root Causes
1
Inadequate Flood Risk Assessment for Critical Safeguards
Arkema did not conduct a flood risk assessment evaluating the potential for extreme weather to disable critical safeguards. Facility flooding risk was not incorporated as process safety information or systematically analyzed in the PHA.
2
Backup Systems Lacked Independent Layer of Protection Design
The facility's backup power and refrigeration systems were not designed or evaluated using independent layer of protection requirements -- common mode failures from flooding were not analyzed, and backup systems failed at the same time as primary systems.
3
Emergency Responders Not Prepared for Chemical Smoke Exposure at Perimeter
Harris County emergency responders lacked updated protocols for enforcing evacuation perimeters during chemical fires, including guidance on PPE, air monitoring, and safe relocation thresholds.
☑ CSB Recommendations
→ Arkema Crosby Facility
Reduce flood risk to as low as reasonably practicable and ensure all safeguards for flooding meet independent layer of protection requirements, including backup power and refrigeration systems.
→ Arkema Inc. (Corporate)
Develop corporate policy requiring all Arkema facilities manufacturing organic peroxides or handling threshold HHC quantities to periodically analyze flood and extreme weather risk, tied to the PHA revalidation cycle.
→ Arkema Inc. (Corporate)
Establish corporate requirements ensuring critical safeguards -- including backup power -- function as intended during extreme weather events, with verified independence from common mode failure caused by flooding or hurricanes.
→ Center for Chemical Process Safety (CCPS)
Develop comprehensive guidance helping companies assess U.S. facility risk from all types of extreme weather events, covering common mode safeguard failures, flood map integration as PSI, and multi-discipline risk assessment.
→ Harris County, TX
Update emergency operations training using Arkema incident lessons to ensure personnel enforcing evacuation perimeters are protected; update protocols for air monitoring, PPE, and safe operations in hazmat evacuation zones.
💡 Lessons Learned
Organic peroxides require uninterrupted refrigeration to remain stable. A hurricane or flood that disables refrigeration -- primary and backup simultaneously -- will inevitably cause spontaneous combustion. Facilities handling thermally unstable chemicals must treat extreme weather as a credible cause of critical safeguard failure.
Process hazard analyses must evaluate natural disaster scenarios as initiating events for loss of critical utilities and containment. Hurricane Harvey was a foreseeable event for a Gulf Coast facility -- its potential impact on refrigeration capacity should have been explicitly analyzed in the PHA.
Independent layers of protection must be truly independent. Backup generators installed at the same elevation as primary systems are not independent when flooding is the hazard -- they fail at the same time as the systems they are supposed to back up.
Emergency responders enforcing chemical facility evacuation perimeters face chemical exposure hazards. Protocols must include air monitoring, PPE guidance, and clear thresholds for relocation of personnel who must remain near or in the evacuation zone.
Extreme weather events are increasingly recognized as process safety hazards. Flood maps and extreme weather probability data must be incorporated as process safety information, and PHAs must specifically evaluate these scenarios as initiating events.
PHA: Process Hazard AnalysisMI: Mechanical IntegrityEAP: Emergency Planning & ResponsePSI: Process Safety Information
🔨 Safety Meeting Toolbox Talk
►If our facility experienced a major flood, which critical safety systems would fail first? Do our backup systems provide truly independent protection, or would flooding knock them all out simultaneously?
►Is extreme weather -- hurricanes, flooding, ice storms -- included in our process hazard analysis as a credible initiating event for loss of critical utilities or containment?
►Do we have chemicals on site that require uninterrupted temperature control? What would happen to those materials if we lost all refrigeration for 48 hours?
►Are our flood risk assessments based on current flood maps and worst-case weather data, or on historical averages that may underestimate current risk?
►If a chemical release occurred during a severe weather emergency, how would we communicate with first responders about the specific hazards they might encounter at our site?
Immediate Action Items
✓Review your facility's flood risk assessment and verify it evaluates the potential for flood levels to disable critical safeguards -- including backup power, cooling, and refrigeration systems.
✓Audit backup safety systems and confirm they are designed as truly independent layers of protection, not subject to the same common mode failures as the primary systems they back up.
✓Identify any thermally unstable or temperature-sensitive chemicals at your facility and verify emergency plans address loss of refrigeration or temperature control as a specific scenario.
✓Review your process hazard analyses to confirm that natural disaster scenarios are evaluated as initiating events for loss of critical utilities or loss of containment at covered processes.
✓Coordinate with local emergency response agencies to ensure they have current information on chemical hazards at your facility and are trained on PPE requirements for personnel operating near your site during a chemical release.
🔗 PSM Failures Behind This Incident

This incident traced to breakdowns across 4 PSM elements (PHA · MI · EAP · PSI). Each represents a documented gap that process safety documentation and consulting can close before a similar event occurs at your facility.

Process Hazard Analysis (PHA)
A structured PHA or HAZOP study exists to identify exactly these scenarios before they occur. When PHA is absent, superficial, or overdue for revalidation, hazards operate unseen until they kill someone.
Supporting documents in our library →
Mechanical Integrity (MI)
Equipment must be designed, inspected, and maintained to operate safely in its intended service. Mechanical integrity failures — degraded equipment, missed inspections, deferred repairs — contributed to loss of containment here.
Supporting documents in our library →
Emergency Planning & Response
When process safety barriers fail, emergency response capability determines whether the outcome is controlled or catastrophic. Gaps in emergency preparedness amplified the consequences here.
Supporting documents in our library →
Process Safety Information (PSI)
Accurate, complete Process Safety Information is the foundation every other PSM element depends on. When PSI is missing or wrong — chemistry data, equipment specs, P&IDs — the entire hazard analysis is built on a flawed base.
Supporting documents in our library →
Process Safety Management Consulting & Document Library
📂
PSM Document Library
32 ready-to-deploy PSM documents covering all 14 OSHA elements — procedures, checklists, and audit templates built for facilities operating under 29 CFR 1910.119.
Browse the Library →
📊
Free PSM Health Score
Find out where your PSM program stands across all 14 OSHA elements. Our free health score surfaces your biggest gaps in under 10 minutes — no account required.
Check Your Score →
📞
Consulting Services
PHA facilitation, PSM program builds, compliance audits, and OSHA inspection support. Transparent flat-fee pricing — no retainer required to get started.
View Pricing →
📋 Explore the full incident library: All 132 CSB Case Studies →