--- title: Chemical Safety Board Recommends Better Process Safety Management description: Within the U.S., most chemical safety requirements are imposed by the Occupational Safety and Health Administration OSHA) and the Environmental Prote image: https://blog.stpub.com/hs-fs/file-3411075986-jpg/images/hazard_sign.jpg --- [![Specialty Technical Publishers](https://blog.stpub.com/hubfs/STP-logo-white-orange.png)](http://www.stpub.com/) - [My Account](http://stponline.stpub.com) - 1-800-251-0381 # Audit, Compliance and Risk Blog ## [Chemical Safety Board Recommends Better Process Safety Management](https://blog.stpub.com/bid/203455/Chemical-Safety-Board-Recommends-Better-Process-Safety-Management) Posted by [Jon Elliott](https://blog.stpub.com/author/jon-elliott) on Mon, Dec 15, 2014 - [Tweet](https://twitter.com/share) ![http://www.stpub.com/federal-toxics-program-commentary-online](https://blog.stpub.com/hs-fs/file-3411075986-jpg/images/hazard_sign.jpg?width=138&height=185&name=hazard_sign.jpg)Within the U.S., most chemical safety requirements are imposed by the Occupational Safety and Health Administration OSHA) and the Environmental Protection Agency (EPA). For example, OSHA (or delegated state agencies) administers a **Process Safety Management (PSM) Standard**, while EPA (or delegated state agencies) administers the **Accidental Release Prevention (ARP) regulation**. In addition to these sets of regulators, however, Congress has created a national agency to conduct independent investigations of major chemical accidents, and to issue accident-specific findings and specific or general recommendations for improved chemical handling and regulation. This agency’s formal name is the **Chemical Safety and Hazard Investigation Board**—which usually refers to itself as the Chemical Safety Board or CSB. Since the 1990s, CSB has offered repeated recommendations for changes to PSM and ARP, seeking clearer regulatory requirements that facility operators enhance their hazard evaluation and management efforts. Neither OSHA nor EPA have adopted many of these recommendations, although both agencies are now reviewing their regulations in response to an Executive Order (I’ve blogged about EPA’s efforts [here](https://blog.stpub.com/bid/201020/EPA-Seeks-Comments-On-Accidental-Release-Prevention-Requirements), and about OSHA’s efforts [here](https://blog.stpub.com/bid/192421/OSHA-Is-It-Time-To-Update-The-Process-Safety-Management-Standard)). CSB has now weighed in again, compiling recommendations for PSM and ARP “modernization.” ### **What Enhancements to PSM Does CSB Recommend?** CSB recommends that OSHA adopt the following revisions to the PSM Standard: - Expand attention to **reactive hazards**, including: - Management of change (MOC) review for organizational changes that may impact process safety. - Comprehensive process hazard analysis written by the facility that includes: - Assurance that the regulator (OSHA or state) is technically competent with adequate resources, conducts ongoing monitoring of regulated facilities and industries (including leading and lagging indicators of safety risks) to support continuous improvement in PSM activities, and conducts appropriate audits and inspections.  - Establish a “model where the regulator, the company, and workers and their representatives play an equal and essential role in the direction of preventing major accidents.”  - Require reporting of information to the public to the “greatest extent feasible.” ### **What Enhancements to ARP Does CSB Recommend?** CSB recommends that EPA adopt the following revisions to the ARP regulation: - Add explicit coverage of catastrophic reactive hazards (i.e., in addition to toxic and flammable hazards). - Require inherently safer systems analysis and a hierarchy of controls when facilities establish safeguards for identified process hazards. ### **What Coordination Between Occupational Safety and Environmental Protection Regulators Does CSB Recommend?** CSB has recommended that EPA and OSHA, and their state counterparts, coordinate PSM and ARP regulatory activities to maximize the benefits of both. Readers should note that President Obama’s Executive Order and subsequent federal activities include these efforts. I’ve blogged about the Executive Order [here](https://blog.stpub.com/bid/185680/Obama-Issues-Executive-Order-On-Chemical-Facility-Safety), and about a report by an interagency task force coordinating these responses [here](https://blog.stpub.com/bid/199003/Chemical-Facility-Safety-Progress-Report-on-the-President-s-Executive-Order). ### **Self-Assessment Checklist** - Do any of my organization’s facilities manage chemicals subject to PSM or ARP? - If so, does any facility comply with: - Has the organization developed organizational-level and/or facility-level programs for chemical risk assessment and handling consistent with requirements of PSM and/or ARP requirements? - Is the organization participating in review and reform activities being undertaken by the implementing agency (or at least tracking them)? **Where Can I Go For More Information?** - [CSB website](http://www.csb.gov/)   - EPA [ARP webpage](http://www2.epa.gov/rmp/risk-management-plan-rmp-rule-overview)  - OSHA [PSM webpage](https://www.osha.gov/SLTC/processsafetymanagement/)  **Specialty Technical Publishers (STP)** provides a variety of single-law and multi-law services, intended to facilitate clients’ understanding of and compliance with requirements. These include: - *[Federal Toxics Program Commentary](http://www.stpub.com/federal-toxics-program-commentary-online)* - *[Environmental Compliance: A Simplified National Guide](http://www.stpub.com/environmental-compliance-a-simplified-national-guide-online)* - [A range of Air Quality MACT Standards Guides](http://www.stpub.com/search.asp?keyword=mact) - *[Environmental Auditing: Federal Compliance Guide](http://www.stpub.com/environmental-auditing-federal-compliance-guide-online)* - *[The Complete Guide to Hazardous Materials Enforcement and Liability: California](http://www.stpub.com/the-completeguide-to-hazardous-materials-enforcement-and-liability-california-online)*   [![Like What You've Read? Subscribe to Our Blog Now](https://no-cache.hubspot.com/cta/default/129776/432bf34d-5444-4a84-9636-a15f85c32125.png)](https://cta-redirect.hubspot.com/cta/redirect/129776/432bf34d-5444-4a84-9636-a15f85c32125) **About the Author** [![http://www.stpub.com/environmental-compliance-a-simplified-national-guide-online](https://blog.stpub.com/hs-fs/file-17039548-jpg/images/jon_elliott_w_border.jpg)Jon Elliott](http://en.stpub.com/company/authors/jon-f.-elliott) is President of [Touchstone Environmental](http://en.stpub.com/company/authors/touchstone-environmental) and has been a major contributor to STP’s product range for over 25 years. He was involved in developing [16 existing products](http://en.stpub.com/company/authors/jon-f.-elliott), including [Environmental Compliance: A Simplified National Guide](http://www.stpub.com/environmental-compliance-a-simplified-national-guide-online) and [The Complete Guide to Environmental Law](http://www.stpub.com/the-complete-guide-to-environmental-law). Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977). Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee). You may contact Mr. Elliott directly at: [tei@ix.netcom.com](mailto:tei@ix.netcom.com). ###### photo credit: [observista](https://www.flickr.com/photos/everydaylifemodern/1227111551/) via [photopin](http://photopin.com) [cc](http://creativecommons.org/licenses/by-nd/2.0/) Tags: [Corporate Governance](https://blog.stpub.com/topic/corporate-governance), [Business & Legal](https://blog.stpub.com/topic/business-legal), [Health & Safety](https://blog.stpub.com/topic/health-safety), [OSHA](https://blog.stpub.com/topic/osha), [Environmental risks](https://blog.stpub.com/topic/environmental-risks), [Environmental](https://blog.stpub.com/topic/environmental), [EPA](https://blog.stpub.com/topic/epa), [Hazcom](https://blog.stpub.com/topic/hazcom) ### Follow Me ### Subscribe by Email ### Browse by Topic Area - [Accounting & Tax ](https://blog.stpub.com/topic/accounting-tax) - [Business & Legal ](https://blog.stpub.com/topic/business-legal) - [Corporate Governance  ](https://blog.stpub.com/?Tag=Corporate+Governance) - [Environmental ](https://blog.stpub.com/?Tag=Environmental) - [Global ](https://blog.stpub.com/?Tag=Global) - [Health & Safety ](https://blog.stpub.com/topic/health-safety) - [Internet ](https://blog.stpub.com/?Tag=Internet) - [Transportation ](https://blog.stpub.com/?Tag=Transportation) ### Browse by Tag - [Environmental (344)](https://blog.stpub.com/topic/environmental) - [Business & Legal (309)](https://blog.stpub.com/topic/business-legal) - [Environmental risks (300)](https://blog.stpub.com/topic/environmental-risks) - [Health & Safety (296)](https://blog.stpub.com/topic/health-safety) - [EPA (283)](https://blog.stpub.com/topic/epa) - [Terms & Conditions](https://stphub.stpehs.com/wp-content/uploads/2021/01/STP-Terms-of-Use-Dec-20.pdf) - [Privacy Policy](https://stphub.stpehs.com/wp-content/uploads/2020/12/STP-Privacy-Policy.pdf) - [License Agreement](https://stphub.stpehs.com/wp-content/uploads/2021/01/STP-License-Agreement-Dec-20.pdf) - [Sitemap](http://stpub.com/sitemap) - [Support](http://stpub.com/support) © 2021 STP ComplianceEHS - All rights reserved