Modernizing Process Safety Management Regulations Identified As Key Safety Improvement By CSB

Posted on Dec 2, 2014 in Energy/Environmental, Process Safety | Comments Off on Modernizing Process Safety Management Regulations Identified As Key Safety Improvement By CSB

Yesterday, the U.S. Chemical Safety Board (“CSB”) identified modernizing U.S. Process Safety Management Regulations as its second “Most Wanted Safety Improvement.”  (The CSB identified the adoption of a combustible dust standard for general industry as its Most Wanted Safety Improvement in 2013).  According to the CSB, many of the recommendations it has made over the last two decades related to OSHA’s PSM program and EPA’s Risk Management Program (“RMP”) have not been fully implemented, including recommendations to adopt a more rigorous regulatory system that would require covered facilities to continuously reduce major hazard risk.

In particular, the CSB referenced its submissions in response to Requests for Information issued by OSHA and EPA following President Obama’s August 1, 2013, Executive Order 13650, Improving Chemical Facility Safety and Security.  The CSB’s recommendations regarding PSM include that OHSA:

  •  Expand the rule’s coverage to include the oil and gas exploration and production sector;
  • Cover reactive chemical hazards;
  • Add additional management system elements to include the use of leading and lagging indicators to drive process safety performance and provide stop work authority to employees;
  • Update existing Process Hazard Analysis requirements to include the documented use of inherently safer systems, hierarchy of controls, damage mechanism hazard reviews, and sufficient and adequate safeguards; and
  • Develop more explicit requirements for facility/process siting and human factors, including fatigue.

The CSB’s recommendations regarding RMP include, in addition to the PSM enhancements above, that EPA:

  •  Expand the rule’s coverage to include reactive chemicals, high and/or low explosives, and ammonium nitrate as regulated substances and to change enforcement policies for retail facilities;
  • Enhance development and reporting of worst case and alternate release scenarios; and
  • Add new prevention program requirements, including automated detection and monitoring, contractor selection and oversight, public disclosure of information, and, for petroleum refineries, attributes of goal-setting regulatory approaches.

 

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