Wednesday, March 13, 2013

CSB to Consider Status of Past Recommendations

The Chemical Safety and Hazard Investigation Board (CSB) announced in today’s Federal Register (78 FR 15931-15932) that it would be holding a public meeting to review the status of some of the chemical safety recommendations that it has made as the result of some of its past investigations. Since the CSB has no regulatory authority, these safety recommendations are the strongest action the Board can take. The meeting will be on April 24th, 2013 in Washington, D.C.

Status Review

The recommendations that the Board will conduct a status review of include:

2005-04-I-TX-7 issued to the American Petroleum Institute (API) and the United Steelworkers International Union (USW) in March 2007. This recommendation urged API and USW to jointly lead the development of an ANSI consensus standard with guidelines for fatigue prevention;

2001-05-I-DE-1 (Process Safety Management coverage of atmospheric storage tanks);

2005-04-I-TX-9 (Process Safety Management requirement for organizational management of change reviews); and

2010-07-I-CT-1 (Regulations addressing fuel gas safety).

Fatigue Response Inadequate

According to the notice the American Petroleum Institute has completed their work on the response to the 2005-04I-TX-7 in the form of the development of a new ANSI-approved Recommended Practice (RP 755; Note that link is to an API presentation about RP 755, to buy the standard see). The CSB staff has reviewed RP 755 and the notice describes their response this way:

“After review, the CSB staff found that RP 755 makes a contribution to chemical safety by explicitly stating that ``workplace fatigue is a risk to safe operations'' and also by suggesting various measures to manage fatigue risks. However, the staff determined that RP 755 does not fully meet the intent of the CSB recommendation in multiple important respects, and therefore has urged the Board to vote designating the status of Recommendation No. 2005-4-I-TX-7 as ‘Open-Unacceptable Action.’”

The full recommendation is available on the CSB web site. The Board will consider that recommendation at this meeting. It will also look at the agency responses for the other mentioned recommendations and take appropriate actions upon them as well.

Public Participation

The CSB is soliciting public comments on the staff recommendation. Comments may be submitted electronically ( They should be received by April 5, 2013.

The CSB meeting on April 24th is open to the public. There is nothing in the notice that indicates that advanced registration is required.

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