Review - Joint EPA/OSHA/CISA Safety Advisory – Hazardous Chemical Storage

 Today, CISA’s Office of Chemical Security published a ‘News Item’ on the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center pointing at a new joint EPA-OSHA-CISA safety advisory: “SAFETY ADVISORY: Risks of Improper Storage of Hazardous Chemicals at Chemical Warehouses and Chemical Distribution Facilities”.

The Safety Advisory notes:

“In the past several years, federal agencies have visited numerous chemical warehouses and chemical distribution facilities (i.e., companies that process, formulate, blend, re-package, store, transport, and market chemical products) to determine compliance with applicable regulatory requirements for chemical accident prevention, preparedness, safety, and security. Based on information gathered, agencies found that many facilities do not manage chemicals in a safe or secure manner. Complying with applicable regulations may help avoid catastrophic chemical accidents.”

It then goes on to list eleven concerns about chemical storage. The first 10 are common safety issues that anyone who has worked around chemical storage will readily recognize. The eleventh item of concern is related to the CFATS program:

“Failure to complete a CISA CFATS Top-Screen, as well as not utilizing predictive filing to determine all reportable chemicals of interest.”

The bulk of the five-page Safety Advisory provides a brief overview of the various regulatory programs run by these three agencies that deal with chemical safety and security issues. It lists the commonly used name for each program, the CFR reference (no active links unfortunately) and a brief summary of the program requirements. There are a number of links provided to various program web sites and fact sheets.

This is a valuable document because it puts a summary of the major chemical safety and security programs in this country into one document. It would be more valuable with links to the US Code and CFR references mentioned in the document, but those are readily available from https://www.govinfo.gov/, so that is not a major problem.

For more details about the advisory, see my article at CFSN Detailed Analysis - https://patrickcoyle.substack.com/p/joint-epaoshacisa-safety-advisory - subscription required. NOTE: This article is being sent to all of my subscribers, paid and free, because of the potential importance of the message.