Process safety management reform a top priority

The US Chemical Safety Board has identified the modernisation of process safety management regulations as its second ‘Most Wanted Safety Improvement’.

Implementing federal and California state recommendations, advises the CSB, will result in significant improvements to petroleum refinery safety across the United States.

CSB chairperson, Dr Rafael Moure-Eraso, said: “I see this as an important opportunity to advance national process safety management reform by advocating for this issue as part of the board’s Most Wanted Chemical Safety Improvements Program.”

Process safety, notes the agency, has improved over the past two decades. Even so, many CBS recommendations put forward during that time to the Occupational Safety and Health Administration and the Environmental Protection Agency “have not been fully implemented”.

Dr Moure-Eraso expressed “hope” that the addition of process safety management to the CSB’s Most Wanted Safety Improvement list would stimulate regulatory actions to “help prevent future catastrophic accidents”.

“The CSB has a statutory, Congressionally mandated task to address the sufficiency of OSHA and EPA regulations. That is a key obligation of the CSB, and I intend to continue pursuing this mandate vigorously.”

Process safety management recommendations

To improve process safety management, the CSB recommends that OSHA:

  • Expands its rules coverage to include the oil and gas exploration and production sector
  • Expands its rules coverage to include reactive chemical hazards
    Introduces additional management system elements which include the use of leading and lagging indicators to drive process safety performance and provide stop work authority to employees
  • Updates 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
  • Develops more explicit requirements for facility/process siting and human factors. These should factor in fatigue

To improve risk management, the CSB recommends that EPA:

  • Expands its rules coverage to include reactive chemicals, high and/or low explosives and ammonium nitrate as regulated substances. It should also change enforcement policies for retail facilities
  • Enhances development and reporting of worst case and alternative release scenarios
  • Introduces new prevention programme requirements. These should include automated detection and monitoring, contractor selection and oversight, public disclosure of information, and, in the case of petroleum refineries, attributes of goal-setting regulatory approaches

CSB board member, Mark Griffon, explained how agency investigations into large-scale incidents had informed the detail of recommendations.

“Modernising process safety management is an issue rooted in critical safety recommendations made over the last two decades to prevent recurrence of catastrophic industrial accidents,” said Mr Griffon. “Recent activities have provided the board with a unique opportunity to advocate for these much needed reforms.”

View the full list of process safety management recommendations

More about the Chemical Safety Board

The US Chemical Safety Board is an independent federal agency tasked with the prime objective of investigating industrial chemical accidents.

Whilst the Board does not issue citations or fines, it is responsible for making safety recommendations to plants, industry organisations, labour groups and regulatory agencies such as OSHA and EPA.

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