Wednesday, November 29, 2023

OSHA vs CSB Chemical Incident Investigations

OSHA recently issued citations (here and here) for serious chemical incidents (news reports here and here) at two separate manufacturing facilities. The citations are for regulatory violations that may or may not have directly contributed to the initiation or consequences of the incidents. These regulatory investigations are necessary (and would be more productive if they were conducted before incidents, not after), but they provide little real information about how to prevent incidents.

While both incidents were reported to the Chemical Safety Board (CSB), the Board did not investigate either incident. If it had, their reports would have focused on the processes involved, the proximate cause of the incident, and steps that could have been taken to prevent the incidents. No fines would have been levied, but specific recommendations would have been made to ensure that across the industry (and in associated industries) preventive measures would be available to prevent the reoccurrence of these types of incidents.

Both types of investigations and reports are necessary to help the chemical industry remain a safe work environment and help protect the surrounding communities from the effects of such events. While the CSB provides detailed information about the prevention of such events, OSHA provides the incentives for companies to apply that information to their processes.

Unfortunately, because of the continued backlog of incident reports caused by the inept leadership of previous Boards, the CSB has not initiated a new investigation since September of last year and it had been over a year since the previous last investigation was initiated when CSB personnel arrived at the scene of their latest investigation. While clearance of the remaining five 2021 and earlier investigations should be a priority, the CSB needs to start actively looking at newer incidents and shift their focus back to the present.

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