From Bhopal to Bio-Lab: Are we really learning?

The above is an AI-generated image of a generic chemical manufacturing plant.

40 years. Two industrial disasters. And the uncomfortable truth about risk, controls, and corporate memory.

Industrial disasters are rarely the result of a single catastrophic moment. More often, they are the culmination of ignored warnings, eroded controls, cost-cutting, over-confidence, and a belief that “it won’t happen to us”.

Two events, on opposite sides of the world, separated by four decades, highlight this pattern alarmingly well:

The Union Carbide Gas Disaster in Bhopal, India (1984)
The Bio-Lab Chemical Fire in Conyers, Georgia (2024)

Different contexts. Different industries. Different eras of regulation and technology. And yet, when viewed through a risk and control lens, these two events feel eerily familiar.

This raises a powerful question: If the world truly learned everything it should have from Bhopal… would Bio-Lab have still happened?

Here’s my view, from a risk and control perspective.

The Union Carbide Disaster: A Catastrophe Born from Known Risks

On 3 December 1984, a runaway reaction at Union Carbide’s pesticide plant released around 40 tonnes of methyl isocyanate (MIC) gas into the night air over Bhopal. The consequences were immediate, devastating, and long-tail:

Thousands died within days
Hundreds of thousands suffered injuries and lifelong illness
Generational environmental contamination continues today

But what’s most confronting from a risk perspective is this: none of the critical failures were unknown.

Key risks were documented, visible, and repeatedly raised – including by Union Carbide’s own health & safety auditors:

MIC tanks overfilled far beyond safe limits
Refrigeration systems switched off to cut costs
Safety systems disabled or unmaintained
Undertrained and underqualified employees and skeleton staffing
Previous internal audits flagging major hazards, left unaddressed

Bhopal wasn’t an accident. It was the predictable outcome of chronic inattention to risk.

The world responded with new regulations, process safety frameworks, and a global awakening about hazardous industries.

Or so we thought.

The Bio-Lab Fire: Different Century, Same Story

On 29 September 2024, fire erupted in a Bio-Lab facility storing pool chemicals in Conyers, Georgia. Water interacted with a chlorine-based, water-reactive product – something that should never happen by design.

The reaction triggered an intense fire, sending toxic plumes across the community, closing major roads, disrupting schools for weeks, and raising long-term health concerns.

Again, the pattern feels familiar:

Water-reactive chemicals stored in a warehouse with active sprinklers (the fact that employees were rostered on for “fire watch” in the warehouse beggars belief)
A nearly identical Bio-Lab fire just four years earlier (Westlake, Louisiana, 2020)
Community concerns raised long before 2024
OSHA later citing improper hazardous-material storage

Like Bhopal, Bio-Lab wasn’t a surprise. The risks were documented. The warnings existed. And the organisational learning from earlier incidents didn’t travel far enough.

Where the Failures Overlap

Across both disasters, we see four recurrent categories of control breakdown:

1. Known Risks Were Tolerated

Bhopal: Overfilled MIC tanks and safety systems that had been turned off
Bio-Lab: Water-reactive chemicals stored in a sprinkler-protected warehouse

These weren’t unknown threats. They were known risks that became normalised.

2. Inherently Safer Design Was Overlooked

Bhopal taught us a critical principle: “What you don’t have can’t leak.”

Yet at Bio-Lab, incompatible chemicals and sprinkler systems co-existed – a design flaw that created the exact conditions for failure.

3. Weak Process Safety Management (PSM)

Bhopal should have been the global turning point for PSM. But Bio-Lab shows the Achilles heel of many organisations:

They learn locally, not organisationally.

One facility has an incident → that site improves → other sites continue with business as usual.

4. Emergency Preparedness Gaps

Bhopal lacked an actionable emergency plan. Bio-Lab handled the emergency more effectively, with evacuations, air monitoring and road closures, and this undoubtedly prevented deaths.

But communication about long-term exposure risks was inconsistent, and community trust was shaken (to put it mildly) in both events.

The Big Question: Would Full Bhopal Learnings Have Prevented Bio-Lab?

If every lesson from Bhopal had been truly embedded across global industry, supply chains, and regulators, how would that have changed the the Bio-Lab scenario?

1. Storage design would have been fundamentally different.

No water-reactive chemicals in a sprinkler-protected building
Physical segregation of incompatible substances
Alternative suppression systems (e.g., dry chemical, foam)

2. Bio-Lab’s previous fire at Westlake in 2020 would have triggered company-wide reform.

A mature process safety culture would treat one incident as a global learning event – not a site-specific problem.

3. Regulators would demand a stronger safety case.

Many hazardous industry regulators force organisations to prove they’ve reduced risk “as low as reasonably practicable” or ”so far as reasonably practicable”. This would have been near-impossible for Bio-Lab to prove, when storing water-reactive chemicals in a room with active sprinklers.

4. Residual risk would still exist – but the specific ignition scenario almost certainly wouldn’t.

Hazardous-material processing will never be risk-free. But structural weaknesses like “sprinklers + water-reactive chemicals” simply shouldn’t survive a Bhopal-level safety mindset.

It is my belief that Bhopal’s lessons could very plausibly have prevented the Bio-Lab fire. But only if they had been applied consistently, globally, and without exception.

The Hard Truth for Risk & Audit Professionals

These events teach us that:

Risk awareness isn’t enough; it must convert to control design.
Controls aren’t enough; they must be maintained.
Maintenance isn’t enough; warning signs must drive action.
Action isn’t enough; learning must be shared beyond the immediate site.

And perhaps most importantly:

The absence of incidents is not the presence of safety.

Both disasters occurred in environments where chronic risks had become normalised.

Where Do We Go From Here?

For organisations handling hazardous materials, “learning” isn’t a workshop, a memo, or a local corrective action plan. It must be:

1. Systemic

One site’s failure is a lesson for all sites.

2. Preventive

Use inherently safer design principles upfront, not after a fire.

3. Brave

Challenge normalised risks. Escalate uncomfortable truths. Ask whether controls are truly effective, or simply present.

4. Human

Communities live beside these facilities. Every hazard is someone’s home, school, or workplace.

Final Thought: Are We Really Learning?

Industrial disasters don’t repeat because we lack knowledge.

They repeat because knowledge isn’t acted upon consistently.

From Bhopal to Bio-Lab, the story is the same: We know more than we apply. We see more than we respond to. And we underestimate what’s at stake until it’s too late.

Claire Berry (CA, CFE, CPRM, AMIIA) is the Founder and Director of Green Pen Consulting, providing tailored risk management and internal audit support to risk and audit teams.

With nearly 20 years’ experience across audit, risk and governance roles, prior to establishing Green Pen Consulting Claire was Group General Manager – Risk & Internal Audit for an ASX100 entity in the chemical manufacturing industry.

Claire also authors the monthly Green Pen Digest newsletter, keeping readers up to date on the latest news and events across the accounting and auditing industries.