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US Chemical Safety Board Wants Better Process Management

17.12.2014 -

The US Chemical Safety Board has identified process safety management (PSM) as a key area in which it sees scope for improvement in facilities dealing with chemicals.

Appointed by the President and confirmed by the Senate, the independent federal agency is charged with investigating serious chemical accidents. While CSB - itself under fire from several directions - noted that a number of improvements in PSM regulations have been made since the 1990s, it said these have not been substantively revised to address the passage of time or improvements in chemical management.

During its investigations of recent major refinery accidents, CSB said it found process safety and risk management programs wanting. It said there was no requirement to reduce risks to As Low As Reasonably Practicable (ALARP), no mechanism to ensure continuous safety improvement and no requirement to implement inherent safety or the hierarchy of controls. Here, the board would like to see "an increased role for workers and worker representatives in process safety management as well as a more proactive, technically qualified regulator."

As regards PSM, the safety board recommended expanding coverage to oil and gas exploration and production as well as chemical hazards. Farther-reaching recommendations include 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.

CSB also recommended updating the existing US 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 as well as developing more explicit requirements for facility/process siting and human factors, including fatigue.

For risk management processes separately, the board suggested that the US Environmental Protection Agency (EPA) expand coverage to reactive chemicals, high and low explosives and ammonium nitrate as regulated substances in addition to changing enforcement policies for retail facilities. It also proposed enhancing development and reporting of worst-case and alternate-release scenarios.

CSB also identified a need to add new prevention program requirements, including automated detection and monitoring, contractor selection and oversight, public disclosure of information.

CSB itself under scrutiny

On August 1, 2013, US President Barack Obama signed an executive order on improving chemical facility safety and security. In its late-August appraisal of the chemical safety board's work, the US Government Accountability Office (GAO) implied that it does not investigate enough.

In 2007, GAO said CSB received notifications of 920 chemical accidents, including 35 with at least one fatality, but investigated only one such incident. In its defense, CSB told the accountability agency it lacked the resources to investigate more than a small percentage.

Criticizing the board's data collection and reporting, GAO said CSB "relies primarily on the media, largely online and television, to learn about chemical accidents."

While acknowledging the board has inadequate resources, the accounting office said the lack of data reporting regulations and problems of data quality limit the board's ability to target its resources, identify trends and patterns in chemical accidents and thus prevent future accidents.

In view of the board's understaffing, GAO recommended that it make more extensive use of the work of government agencies, companies and contractors, improve its accident-screening data base, reinstate the position of chief operating officer (COO) and generally improve personnel - all points reports it said CSB approved of.

The chemical safety board, racked with dissension among its leaders as well as hobbled by partisan squabbling in Washington, is said to have had issues with GAO's recommendation that it develop a plan to address the investigative gap, request that the US Congress provide more resources and require facilities to report all chemical accidents.

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