This Q&A focuses on risk communication aspects of a deadly April 17, 2013 explosion at a fertilizer facility in West, Texas. For the basic facts about the explosion, see this Wikipedia article.
Did you have any personal/professional reaction to the events in West, Texas? 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, Texas, 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. (I don’t want to imply that I studied these issues intensely. My attention was casual.) The first two, I believe, are questions that should command attention after every industrial accident.
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.
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.
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 Company.
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.
Although we don’t know yet exactly how it happened, the ag retail industry (the audience for this piece) is slowly getting more scrutiny. If you are a retail fertilizer dealer that sells ammonium nitrate, how do you quell the fear among the public about the product you sell? What do people want to know and how do you convey it?
Before I address this question, let me react to your use of the word “quell.” The desirable level of public concern about a hazardous substance is proportional to the actual hazard. If people are more fearful than the hazard justifies, “quelling” their fear (in my jargon, outrage management) is appropriate. If they’re less fearful than they should be, arousing fear (precaution advocacy) is what’s called for. I don’t know how dangerous ammonium nitrate in a retail fertilizer outlet actually is. Maybe “quell” is the right word. I just don’t think it should come automatically to mind merely because your audience is dealers rather than activists.
Kneejerk quelling of justified concern may be part of the problem here. When industries keep their stakeholders in the dark about relevant risks, or bend over backwards to over-reassure, they may or may not get away with it. Sometimes people smell a rat; sometimes over-reassurance backfires and makes people more concerned instead of less. (This is an example of what I call the seesaw of risk communication.) But even when over-reassurance works in the short term, it’s a long-term liability. After a disaster, or even sometimes after a near-miss, people who were successfully over-reassured belatedly awaken to the risks they have been encouraged to ignore. Instead of reaching a balanced judgment about those risks, they typically jump to the other side of the seesaw. Having been misled makes us extremely likely to overreact.
I won’t take the time to analyze how these dynamics have played out in industry after industry.
Here’s the bottom line: A wise industry doesn’t aim for public concern that’s as low as possible. Unrealistically low public concern is unsustainable, and the overcorrection when it comes is often devastating to the industry.
The wiser course is to aim for a public that:
- understands the risks;
- is used to them;
- knows what precautions are being taken;
- feels empowered to help decide what additional precautions should be taken; and
- feels comfortable with the risk management decisions that have been made.
My comments here are grounded in an assumption I should make explicit: that a retail fertilizer outlet that sells ammonium nitrate poses a non-trivial risk to its neighbors – not huge, presumably, but not negligible either. I don’t know whether that’s true or not. If the risk is genuinely negligible, there is still need for risk communication. The fears of neighbors deserve to be addressed even if they’re completely unjustified. But if the risk is negligible the appropriate goal is to reassure, and my advice to avoid over-reassurance is irrelevant. I’m assuming the risk is non-negligible.
So: Should a retail fertilizer dealer that sells ammonium nitrate talk about the West explosion?
It’s obvious to me that if questions are being raised, addressing them is smarter than dodging them. The people raising the questions are already worried. No answer at all will only exacerbate their worries. So will an over-reassuring “nothing to worry about” answer. A thoughtful answer that takes their worries seriously is a retailer’s best bet. If the risk is genuinely small, a thoughtful answer is likeliest to convince worried neighbors that it really is small. If the risk is not so small, a thoughtful answer is likeliest to keep worried neighbors from escalating their alarm beyond the realm of the reasonable. Once people are concerned, nothing the retailer says can reduce their concern to less than the actual situation justifies (and the retailer shouldn’t want to do that anyway!) – but a thoughtful answer is the best way to keep them from becoming more concerned than the actual situation justifies.
Talking to people who are more concerned than the actual situation justifies is the focus of the kind of risk communication I call outrage management. Its core strategies are profoundly counterintuitive: Acknowledge that people are worried; acknowledge the ways in which their worries are justified; tell graphic stories about their most-feared outcomes; give them credit for any safety improvements you implement; share control with them and offer them some oversight over your precautions; etc. See my Outrage Management Index for more than you want to know about these and related strategies.
And I would caution the retailer: Don’t forget that many of your less worried neighbors are paying close attention to your dialogue with your most worried neighbors. In the world before social media, it mattered less how you addressed the concerns of a few worrywarts. In today’s world, their worries are likeliest to prove contagious if you blow them off. (Of course small towns have always had effective social media: the back fence, the front porch, the local market.)
But suppose no one is asking questions. Should a fertilizer retailer raise the safety issue and the West example proactively?
The conventional public relations answer is no. Public interest in the West explosion was very brief. As this Google Trends graph vividly demonstrates, Google searches for “fertilizer” in the U.S. reached a sharp sudden peak on April 18, 2013, the day after the explosion. By a week later the number of “fertilizer” searches was almost (but not quite) back to its pre-explosion background level, where it remains to this day:
In the conventional PR view, it would be foolish to retrigger or prolong people’s interest in fertilizer explosions by raising questions they’re not raising themselves. Even if the retail fertilizer industry is “slowly getting more scrutiny” – the premise of your question – most PR advisors would tell their clients to wait to talk until the scrutiny gives them no choice. The longer the time gap between the West explosion and the regulatory discussion that may be coming, they would advise, the better for the industry.
The risk communication answer is different. Risk communication (especially the outrage management side of risk communication) focuses far more on stakeholders than on publics. If you’re a fertilizer retailer that sells ammonium nitrate, you don’t care what “the public” thinks nearly as much as you care what your neighbors think. And even if they’re not saying so out loud, in the wake of the West explosion at least some of your neighbors are wondering whether your facility is safe to live near. A risk communicator wants to surface those unvoiced concerns and get them addressed.
Bear in mind what I said earlier: The wise goal for the fertilizer retailing industry isn’t a public that is unaware of the risks; that’s a recipe for later over-reaction when people belatedly learn the truth. The wise goal is a public that understands the risks and considers them well-managed. This advice is even truer for stakeholders – a retailer’s neighbors, for example – than it is for the general public.
From that perspective, the West explosion created a teachable moment. For a week or so after April 17, people who live near where lots of fertilizer is stored were avidly interested in fertilizer risks. It was an ideal time for the fertilizer industry and fertilizer retailers to do some teaching. Of course it was an even more ideal time for proponents of greater regulation to make their case. But that doesn’t mean the industry should have gone silent. At a time when public and media interest was briefly high and critics were aggressively vocal, the industry needed to be vocal as well, nationally as well as locally – not defensive, not over-reassuring, but thoughtfully explaining the realities of fertilizer risks.
Has the teachable moment passed? Not really. Not entirely, anyway. Public interest (and especially stakeholder interest) is still higher than the pre-West baseline, and probably will remain that way for some months to come. And public and stakeholder interest is easy to revive – for either side – simply by reminding people of West. Any time a retailer of ammonium nitrate is ready to come out of the closet, he or she can show neighbors a photo like this one to launch the conversation.
The post-West teachable moment should be used not just to explain fertilizer risks and the precautions that are being taken, but also to engage neighbors in a dialogue about what I earlier called the values question: How safe is safe enough?
There are only three post-West choices for a fertilizer retailer that sells ammonium nitrate:
- Duck the teachable moment. Hide. Pass up the opportunity to frame the issues thoughtfully, and wait to see how your critics will choose to frame them sooner or later.
- Misuse the teachable moment. Over-reassure. Tell a one-sided story. Maybe you’ll get away with it for now (or maybe not) – but for sure the moment of truth will be all the more painful when it comes.
- Seize the teachable moment. Explain the risks thoughtfully, and launch a mutually respectful dialogue about what precautions are being taken and what additional precautions, if any, might be worth taking.
The third option is the way to go.
If you don’t sell ammonium nitrate, does the message change? If so, how?
At least so far, investigators sound pretty sure that it was ammonium nitrate at the West facility that exploded. They still don’t know what (or who) started the fire that triggered the explosion, but they think they know what exploded.
Ammonium nitrate is more likely to explode than most fertilizers or fertilizer ingredients. In fact, I have read that it was a military explosive before it was an agricultural chemical. It may or may not be more dangerous in toto than other fertilizers, but the particular way in which it’s dangerous – it goes boom – is scarier than most. Moreover, ammonium nitrate was Timothy McVeigh’s explosive of choice for the 1995 Oklahoma City bombing. It has a fair amount of stigma attached to it – not as much as dioxin, say, but a lot more than most fertilizers. Stigma arouses dread, and dread exacerbates outrage.
If I ran a retail fertilizer operation that doesn’t stock ammonium nitrate, I wouldn’t stay mum after the West explosion. I’d assume that some of my neighbors are already wondering whether my place could blow up the way the West facility did. I’d tell people, proactively, that I don’t stock ammonium nitrate. And then I’d segue into a thoughtful discussion of the risks posed by my operation.
On May 21, more than a month after the West explosion, Oregon’s Polk County Itemizer-Observer ran a story explaining why a similar explosion wasn’t likely at nearby fertilizer plants or storage facilities. It begins with this anecdote:
The day after a West, Texas, fertilizer plant erupted in a massive explosion in April, Bill Blair walked into Polk County Fire District No. 1 to calm any nerves about the possibility of a similar explosion in Independence….
Blair is the manager at the Simplot Grower Solutions retail unit in downtown Independence. The facility sells dry and liquid fertilizers and crop protection products, none of which contain ammonium nitrate….
“He (Blair) came in at 8 o’clock that next morning. He had stuff diagrammed out from the West incident, kind of showed us what was going on,” Neal Olson, Polk Fire No. 1 training/operations division chief, said. “They don’t have a lot of the stuff that was down there. Their security measures are high. We’ve done walk-throughs; our crews are pretty familiar with their facility.”
To his credit, Blair didn’t just tell local firefighters that he doesn’t stock ammonium nitrate and therefore can’t have a West-like explosion. The story suggests that he also discussed the risks his operation does pose, the precautions he has taken, and what firefighters would need to know in an emergency.
Blair made good use of the teachable moment.
I have mixed feelings about the Polk County Itemizer-Observer story. It does a good job of explaining why what happened in West probably couldn’t happen in Polk County. But it doesn’t go on to say much about whether there are other fertilizer-related risks that its readers should take seriously.
Aside from that, this is the kind of “Could it happen here?” story that local journalists in farm country should have been producing – and that local fertilizer retailers should have been inspiring and sourcing. And still should.
What is/are the biggest mistake(s) that businesses make when they face public concern/regulatory scrutiny about what they do in the course of business?
I will answer this question purely from a risk communication perspective, although I realize that industries and companies must consider many other perspectives as well when they’re deciding what to do. All I can ask is that they consider risk communication too.
The biggest risk communication mistake industries and companies make when they see regulatory scrutiny on the horizon – after a disaster like the one in West, for example – is to go silent. In the hope that the public’s concern will abate, and the regulatory fervor with it, they pass up the teachable moment – and let their critics frame the issues. I’ve said enough about this already.
The biggest risk communication mistake industries and companies make when regulatory scrutiny is manifest and unavoidable is to construct a one-sided case. As I wrote in my 2002 “Laundry List of 50 Outrage Reducers”:
The dynamics of outrage are not symmetrical. Whenever you are trying to increase people’s outrage, exaggeration is a useful tool. There are limits beyond which the claim lacks credibility (and ethics), but within those limits the more you exaggerate the more outrage you will get. When you’re trying to diminish people’s outrage, on the other hand, exaggeration backfires. It follows that most well-fought controversies are battles between the outrage-increasing extreme and the outrage-reducing middle. If the fight is between their extreme and your extreme – that is, if they con you into a polarized debate – they win. Those of you who yearn for the pleasures of exaggeration, go join an activist group. When playing defense, exaggeration has no place in your playbook. Stake out the middle ground.
Or as I put it in a 2011 Guestbook answer on “How not to play into the hands of extremists”: “Going to war with extremists is nearly as self-defeating as ignoring them…. In a battle of extremes, the alarming extreme, the outrage-provoking extreme, has a natural advantage. So if you’re on the reassuring, establishment side of a controversy, you need to stake out the middle. That means putting a higher priority on demonstrating your responsiveness to the extremists’ valid claims than on rebutting their invalid ones.”
(For still more on staking out the middle, see this video.)
Staking out the middle is never wiser than in the midst of a highly publicized regulatory battle. Industries and companies that come across as intransigent often end up over-regulated. Industries and companies that say which of their critics’ regulatory proposals they think are feasible and sensible, as opposed to the ones they consider extreme and unworkable, are less likely to end up getting saddled with the latter.
Of course staking out the middle is just one of many strategies for ameliorating stakeholder outrage and thus avoiding over-regulation. Among the other standbys: acknowledging prior misbehavior, acknowledging current problems, sharing control, being accountable, giving credit to critics, etc.
If and when regulatory attention turns to fertilizer retailers, I have no doubt activists will be talking about West: how awful it was and what lessons need to be learned so it won’t happen again. The question is whether retailers will be smart enough to talk about West too – and smart enough to have been talking about West all along.
Copyright © 2013 by Peter M. Sandman