Process Safety Ethics | Blog No. 126
- Eli Macha, Founder & Industry Advisor
- 2 hours ago
- 5 min read
The process safety world is abuzz with the potential incident in Orange County. If you haven’t been staying up-to-date, here is a brief overview:
An ongoing hazardous materials incident at a GKN Aerospace facility in Garden Grove, California, began after a 34,000-gallon storage tank containing roughly 6,000–7,000 gallons of methyl methacrylate (MMA) overheated and began venting vapor, raising fears of a catastrophic explosion or toxic chemical release. The incident prompted evacuation orders affecting approximately 40,000–50,000 residents across several Orange County cities while emergency crews worked continuously to cool and stabilize the tank. Officials reported that damaged valves prevented normal mitigation efforts, and Governor Gavin Newsom declared a state of emergency as local, state, and federal agencies responded. Authorities later said a crack in the tank may have relieved internal pressure and reduced the immediate explosion risk, though evacuations and emergency operations remain ongoing.
Our team here at Macha PSM has been praying that this incident would resolve without catastrophe. And praise God, as of yesterday, May 25, 2026, the incident risk has subsided. "We are happy to report that the threat of a BLEVE is now off the table," said OCFA Interim Chief TJ McGovern. "That threat has been eliminated."
While the situation was resolved without an explosion, thousands of people could have been injured or killed. Was GKN Aerospace managing its process safely? This blog is not intended to serve as a thorough incident investigation, but many are questioning the lack of sensors in the process, among other potential shortcomings. Regardless of whether GKN Aerospace was negligent or not, this event causes us to pause and ask some very grave questions. And rather than dive into the weeds, “are they code-compliant or not?,” this article will seek to address the moral component to process safety.
Having consulted with over a hundred facilities, I am well accustomed to navigating grey areas. Simply because a regulation is written does not make it devoid of nuance. What constitutes an incident requiring investigation? What constitutes a change requiring a formal management of change process? Taken to the nth degree, facilities with covered processes would be incapable of actually producing anything, as they would be eternally tied up with process safety tasks. In reality, there is a lot of room for interpretation in process safety, especially since they are performance-based standards. Consider the following questions and take note of their differences:
Are we complying with the law?
Are we complying with the regulations?
Are we complying with the letter of the regulation or the spirit of the regulation?
Are we following RAGAGEP (recognized and generally accepted good engineering practice)?
Are we keeping our employees and visitors safe?
Are we keeping our community safe?
Are we taking responsibility for the hazard at our facility?
I considered making a Venn diagram to show how these questions and implications are not perfectly overlapping, but it proved fairly complicated. (Maybe one day!) But it requires little imagination to see that a company can find ways to be perfectly compliant while failing to protect its employees and community. And while they may not be penalized for being found in such a state, they are no less morally responsible for their decision. In what category does this belong? Rather than referring to some historical model code or obscure technical bulletin, we can turn to the best reference of all.
“When thou buildest a new house, then thou shalt make a battlement for thy roof, that thou bring not blood upon thine house, if any man fall from thence.” Deuteronomy 22:8, Authorized Version
Ancient Israelite homes commonly had flat roofs that were actively used as living and gathering spaces, so the command assumes people will eventually be exposed to the hazard. The responsibility, therefore, falls on the owner to anticipate foreseeable danger before someone gets hurt. The moral issue is not merely the accident itself, but the failure to install reasonable protections once the risk was obvious.
Consider this second example from Scripture:
“If an ox gored a man or a woman, that they die: then the ox shall be surely stoned… but the owner of the ox shall be quit. But if the ox were wont to push with his horn in time past, and it hath been testified to his owner, and he hath not kept him in… his owner also shall be put to death.” Exodus 21:28–30
The passage draws a sharp distinction between an unforeseeable incident and a known hazard that was ignored. If the animal had a documented history of violent behavior and the owner failed to restrain it, responsibility shifted directly onto the person who knowingly allowed the danger to persist. The underlying principle feels remarkably modern: once a hazard is known, ignored warnings and inaction become a moral failing rather than a simple misfortune.
Many mistakenly believe Old Testament commands have nothing to do with today. In 21st-century modern life, I personally have nothing to do with roof battlements or aggressive oxen. Still, these laws are meant for our welfare. Rather than taking the letter of the law, we must understand the spirit of the law. The Westminster Confession of Faith, Chapter 19, Section 4, refers to this principle as taking the “general equity” of those civil laws. So what principle can be taken from these two passages?
If you own property with a known hazard, and there is a known means of preventing harm, you are responsible for taking action. If you do not, you are held morally culpable and responsible.
What does this mean for the process safety industry? If you have a process with extremely hazardous substances, you already know there is a hazard. Even if you do not meet the threshold requirements, you must still understand the gravity of the situation. (The one client I have consulted with that had a process-related fatality came from a process under the federal threshold!)
Here is what is required of you and your company:
Understand the hazards normally associated with your process
Take the required actions to prevent harm
Those first two are easy. The next two require intellectual curiosity, moral fortitude, and sacrifice:
Study your process to learn its unique potential hazards
Take the actions to prevent harm, which are not required by regulation or RAGAGEP
At the end of the day, we should not be laser-focused on what can or cannot be proved in an OSHA, EPA, or DOJ audit. Facility owners should have a higher standard of leadership. How do they continue to produce and contribute to our economy, while protecting their people and the surrounding community?
For a comprehensive training on Anhydrous Ammonia, click here for our PSM Academy Ammonia Awareness training, to learn and earn a certificate of completion. Training is in English and Spanish. Use code SDS20 for a 20% discount on the entire purchase. For more information, email us at academy@machapsm.com.For a comprehensive training on Anhydrous Ammonia, click here for our PSM Academy Ammonia Awareness training, to learn and earn a certificate of completion. Training is in English and Spanish. Use code SDS20 for a 20% discount on the entire purchase. For more information, email us at academy@machapsm.com.
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