Saturday, January 4, 2014

EO 13650 §6(a) RFI – Areas Covered

This is the second in a series of posts addressing the recent request for information (RFI) from the EO 13650 Working Group. That RFI addressed requirements in §6(a) of the Improving Chemical Safety and Security Executive Order (EO 13650) for the Working Group to “develop options for improved chemical facility safety and security that identify improvements to existing risk management practices through agency programs, private sector initiatives, Government guidance, outreach, standards, and regulations”. Earlier posts in the series include:

EO Section 6(a) Requirements

In my earlier post I failed to note that the three requirements in §6(a) were actually serial requirements.

• The initial requirement to “develop options for improved chemical facility safety and security” {§6(a)(i)} has been accomplished by the Working Group and is reflected in the RFI.

• This RFI address the second requirement to “engage key stakeholders to discuss the options and other means to improve chemical risk management that may be available” {§6(a)(ii)} that were identified by the Working Group.

• The final requirement to “develop a plan for implementing the practical and effective improvements to chemical risk management” {§6(a)(iii)} will be addressed by the Working Group after receiving the public feedback being solicited in this RFI.

Areas to be Considered

The Working Group has identified 9 areas where it feels that improvement could be made to chemical facility safety and security. Those areas are:

• Improving the safe and secure storage, handling, and sale of ammonium nitrate process safety improvement and modernization;
• Coverage of additional hazardous chemicals or categories of chemicals under process safety and security regulations;
• Chemical reactivity hazards;
• Explosive chemical hazards;
• Oil and gas facilities;
• Coverage of bulk storage of flammable liquids under process safety and security regulations;
• Process and hazardous chemical security; and
• Identifying facilities covered under existing process safety and security regulations.

Anyone that has reviewed the earlier OSHA PSM RFI will recognize that there will be some overlap in the areas to be considered. Since there have been no comments posted to that RFI in the month that it has been active, it certainly makes sense to include many of those items in this RFI.

Type of Input Requested

The Working Group has identified a number of policy options for consideration under each of the above listed areas and asks for some specific input on each of those options. In addition they list five general types of information about each of the topic. They include:

• Examples of where implementation of the same or similar options has been successful;
• Information or data that would characterize the positive impacts the options might have, including additional benefits;
• Potential limitations or unintended consequences of the options described;
• Methods for implementing the options, including methods for potentially increasing benefits or reducing costs; or
• Alternatives to the options that could achieve substantially the same result.

Posting Comments

The RFI calls for comments to be submitted by March 31st, 2014. It provides the docket number (OSHA-2013-0026) for submitting comments through the Federal eRulemaking Portal ( Unfortunately, as of 11:30 am CST today that docket has not yet been established. I suspect that it won’t go live until this RFI is published in the Federal Register sometime next week.

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