EO13650 and IST: A Look Back at Proposed Solutions

There has been an interesting undercurrent in the EO 13650 Working Group about the inevitable discussions about inherently safer technology that have come up in the public listening sessions being held by the Working Group. The environmental and worker’s rights advocates are predictably pushing EPA, OSHA and DHS to adopt some form of IST mandate as a way to reduce the hazards from accidental or deliberate releases of industrial chemicals. Just as obviously, industry groups continue their adamant stance against any such proposal.

The regulators that sit on the dais at these listening sessions, acting as the ears of the agencies, are placed in an unenviable position. Some level of IST commitment is almost certainly going to come out of this process as a proposal for regulations, but the regulatory community is not going to get any additional manpower or funding for implementing such a regulation because this is an Executive Order, not Congressional authorization.

Complicated Topic

All sides of the disagreement do acknowledge that inherently safer technology techniques do offer a way to reduce the hazards associated with dangerous chemicals. The two sides, however, vehemently disagree on how such a program should be implemented or how much of a role the government should have in such an implementation.

Unfortunately, neither side really listens to (or even trusts) the other side. As with most complex problems this is not a black/white issue that can be resolved by simple means. Over the last six+ years writing this blog, I have taken a hard look at the IST issue and have offered suggestions on how to effectively deal with many of the issues involved.

I have a great deal of self-confidence and think rather highly of my ideas, but I know that I am not the source of all knowledge. But I have tried to look at IST from the point of view of a professional in the chemical manufacturing industry who has spent many years making things work. Some of the ideas that I have written about could be used to form the basis of a workable IST regulatory scheme.

IST ISSUES Page

I have just put up a new page on this site that compiles a list of the IST posts that I have written over the last six years. They are not indexed; they are just listed chronologically. I have added a listing of the sub-headings from those posts (or at least the ones with such sub-headings) to give people some insight as to what is being discussed.

There are a couple of specific series of blog posts that I would like to call special attention to because they do an in-depth look at various aspects of a practical IST regulatory system. I will list the last post in these two series here as those posts will provide links to the earlier posts in the series. Those two series were:

What Standard to Apply for IST – Cost Estimates

IST Questions – Active Mitigation

Formatting Issues

I do have to apologize for the readability of some of those earlier posts. In transferring posts from the original site on AOL Communities to Google, much of the formatting disappeared. From time to time I do go back and re-edit the formatting of some of those earlier posts to make them more readable. That is a time consuming (and very boring process) so some of those posts can be more challenging to read than others. I will give priority to fixing these IST posts over some of the others, but it will still take time.