Reader Comment – API & ASME CSB Responses

Yesterday William Sommer, MBA, PE left a comment on LinkedIn on my note about my blog post on the CSB’s video on the Yenkin-Majestic Resin Plant Vapor Cloud Explosion and Fire. He asked:

“I was struck by one of the recommendations for the API and ASME to provide design, construction, alteration guidance for low pressure vessels in flammable or highly hazardous chemical service: Does anyone know status and where to find?”

I have no insight into the status of the development of the design criteria within the American Petroleum Institute (API) and the American Society of Mechanical Engineers (ASME). I can, however, provide a little more information on the CSB’s take on the status of these recommendations; the data comes from the CSB’s Recommendations Statistics page and the September 23^rd, 2025, downloadable spread sheet on that page. Both recommendations were issued on November 30^th, 2023. The table below summarizes the pertinent data about the two recommendations.

 

 

The text of the API recommendation:

“Develop specific design, construction, and alteration guidance for low-pressure process vessels in flammable and other highly hazardous chemicals service not exceeding an internal pressure of 15 psig in API 510 Pressure Vessel Inspection Code, API RP 572 Inspection Practices for Pressure Vessels, and/or other appropriate products. At a minimum, include guidance for:  (i) determining and documenting the low-pressure vessel’s design pressure (such as through a data sheet and a nameplate affixed to the vessel); (ii) determining when or if all or parts of the ASME Boiler and Pressure Vessel Code should be applied; (iii) acceptable alternative engineering methods, if applicable; and, (iv) alteration requirements, such as design assessments, inspections, and pressure testing.”

The text of the supporting ASME recommendation:

“Assist API in developing design, construction, and alteration guidance for low-pressure vessels in flammable and other highly hazardous chemicals service not exceeding an internal pressure of 15 psig. If any new design and construction guidance is specifically developed for pressure vessels in flammable and other highly hazardous chemicals service not exceeding an internal pressure of 15 psig, reference the design and construction guidance in the Section VIII, Division 1 of the ASME Boiler and Pressure Vessel Code (BPVC).”

Even with a reasonable degree of consensus on the need for standards changes, it takes some time to develop, write and reach consensus on these sorts of things. It does seem to me that two years is not an unreasonable amount of time to be working on such a standard.

If anyone has any information on if/how progress is being made within API or ASME, please let me know.

CSB Publishes Remote Isolation Safety Study

Yesterday, the Chemical Safety Board announced the publication of a new safety study on Remote Isolation of Process Equipment”. The RIPE study looks at the historical record of industrial chemical accidents, including a number of CSB accident investigation reports, to determine how useful remote isolation valves would have been in preventing or reducing damages, deaths and injuries. The Study resulted in the publication of three recommendations that were released on Wednesday:

• American Petroleum Institute (API) - 2024-01-H-1,

• Environmental Protection Agency (EPA) - 2024-01-H-2, and

• Occupational Safety and Health Administration (OSHA) - 2024-01-H-3

NOTE: No direct links are currently available to those recommendations, but they can be found listed on the CSB’s Recent Recommendation Status Updates page.

The three recommendations are:

API - “Develop a new publication or revise an existing publication or publications that should be applicable to various facility types such as refineries, chemical and petrochemical facilities, terminals, etc. with major process equipment and atmospheric storage tanks, that details conditions that necessitate the installation of remote isolation devices [use “shall” instead of “should” language] that may be automatically activated or remotely activated from a safe location, particularly during an emergency. When establishing these conditions refer to the guidance published by CCPS entitled Guidelines for Fire Protection in Chemical, Petrochemical, and Hydrocarbon Processing Facilities, Sections 8.1.10 and 8.1.11. At a minimum, the conditions should address major process equipment and atmospheric storage tanks, material volumes/weight as well as flammability, corrosivity, and toxicity”

 

EPA - “Update the Risk Management Program (RMP) rule by expanding the requirements of 40 CFR Part 68 to include an evaluation of the need for remote isolation devices for major process equipment that can be remotely activated from a safe location or automatically activated during a release. The evaluation should be included in hazard assessments, hazard reviews, and process hazard analyses.”

 

OSHA - “Update the Process Safety Management (PSM) standard by expanding the Process Hazard Analysis (PHA) requirements under 29 CFR 1910.119(e)(3) to include an evaluation of the need for remote isolation devices for major process equipment that can be remotely activated from a safe location or automatically activated during a release.”

PHMSA Pipeline Accident Report ICR 30-day Notice

Today the Pipeline and Hazardous Material Safety Administration (PHMSA) published a 30-day information collection request (ICR) notice in the Federal Register (78 FR 55775-55776). The notice includes a response to the one comment PHMSA received from the American Petroleum Institute to the 60-day notice for proposed changes to the PHMSA hazardous liquid pipeline accident reporting program.

API Comment – PHMSA Response

API listed four objections to the proposed changes in to the reporting program. They suggested the following changes:

• That “facility” be replaced with “system” in the instructions for Volume Spilled and Volume Recovered;

• That a new option is needed when a NRC Report was not submitted and proposes that “NRC notification not required at time of release” be added as an option; and

• That changes to both the instructions and form to make clear that the information will be available to the public.

PHMSA adopted the first recommendation and did not take any actions on the other three.

The fourth API comment was an objection “to the instructions regarding the use of the phrase ‘when the operator became aware of the accident’ to describe the earliest date and time an operator identifies a pipeline failure”. PHMSA was not persuaded to make any changes to that wording.

Public Participation

PHMSA is soliciting public comments on this ICR and related changes to the accident reporting program. Responses should be made directly to the Office of Management and Budget’s (OMB) Office of Information and Regulatory Affairs (OIRA). Comments may be submitted via email (OIRA_Submission@omb.eop.gov). Comments need to be submitted by October 11^th, 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 24^th, 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 (fatiguecomments@csb.gov). They should be received by April 5, 2013.

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