“At the end of the day, the goals are simple: safety and security.” Jodi Rell
At Bluefield Process Safety, our mission is to make the world a safer place. One of the resources we utilize to help us achieve our mission is the recommendations and safety videos released by the U.S. Chemical Safety Board (CSB). The CSB investigates industrial chemical accidents and hazards. These investigations lead to recommendations aimed to prevent recurrence and to protect workers, the public, and the environment. Some of these recommendations are still waiting to be addressed, but others have been implemented in industry, such as relocating temporary trailers to be away from danger zones at plants. The CSB also releases safety videos where they use their investigations as a teaching tool. By staying informed on CSB findings and recommendations, we can suggest implementation of appropriate safety measures to our clients.
How does the CSB fit into the 2018 Budget Proposal?
Recently, the Office of Management and Budget released America First, A Budget Blueprint to Make America Great Again. The proposed budget for 2018 was designed to be highly focused on national security and public safety. The proposed budget significantly increases defense spending. This increase in spending is offset by reductions elsewhere. These reductions include the elimination of funding for several independent agencies, including the U.S. Chemical Safety Board.
What is the U.S. Chemical Board? What do they do?
The CSB became operational in January 1998, under the authorization of the Clean Air Act Amendments of 1990. The CSB is an independent, non-regulatory federal agency. Being independent gives the CSB the ability to perform their investigations unprejudiced by the rulemaking, inspecting, and enforcement authorities of the EPA and OSHA. This independence allows the CSB to identify chemical hazards that have not been addressed by other agencies, as well as to review the effectiveness of existing regulations and regulation enforcement in the chemical industry. Being non-regulatory means that the CSB does not issue fines or citations. Instead, they make recommendations. While these recommendations are not mandatory, they are usually followed. Since the recommendations are made after incident investigations, they are realistic, effective, and designed to help prevent similar incidents. These characteristics are desirable to recipients and make compliance an enticing option. Over 60% of the recommendations from CSB have been successfully implemented by the recipients.
The CSB conducts investigations into industrial chemical accidents. These investigations can be into specific accidents or general chemical accident hazards. Accident investigations aim to determine root causes of the accident. The root cause is anything that could have prevented the incident had it not occurred and can be anything from a deficient safety management system to human error to equipment failure, etc. The first hazard investigation performed by the CSB looked at uncontrolled chemical reaction in industry. A second hazard investigation is being done on combustible dusts. The recommendations that come from these hazard investigations, as well as the accident investigations, can result in the EPA or OSHA implementing regulatory changes.
Do we really need the CSB?
When there is an industrial chemical accident, many agencies respond to the scene and perform investigations. Some may wonder, is one less investigation really that big of deal? Yes, it is. The CSB is currently the only agency that is authorized to and performs investigations in the way they do. Other investigating agencies do not search for the root cause of the incident. The CSB is very thorough in their investigations, generally spending six months to a year, and will even model incidents to aid in root cause determination or event impacts as necessary. In addition, the CSB is an independent agency which means it can review other agencies’ regulations and regulatory enforcements to make a determination as to whether those held some responsibility for the incident. Currently other investigating agencies do not do this.
Another benefit of the CSB investigations is that the findings and recommendations from each investigation are made public. This means that anyone can see these, including industries that are closely related to the incident but did not experience it. Learning from previous incidents is crucial to the evolution of safety. It allows those who have not experienced the incidents themselves to take preemptive steps to avoid a similar occurrence. The published information also allows a wider audience to develop protection measures and solutions to the incidents. The wealth of knowledge created by the CSB provides the different industries with valuable tools to prevent loss of life, property, or additional injuries that would be expected if they had to first experience their own similar incident before the hazard was identified.
Without the CSB investigation there would be no recommendations made solely to prevent incident recurrence based on the root cause. There would be no recommendations to the EPA or OSHA to implement regulatory changes. Without CSB investigations there would be no more recommendations made that are accepted industry wide and that make the employees, community, and environment safer. There would be no more safety videos based on the findings of their investigations to be used as teaching devices.
The CSB acts as a safeguard for the chemical industry and works hard to improve public safety by investigating accidents and hazards and making recommendations. Without the CSB, the chemical industry will not be as safe as it could be. This puts the lives of workers and the public at a greater risk than they would be otherwise.
What does this mean moving forward?
America First, A Budget Blueprint to Make America Great Again is not the Federal budget, it just lays out the priorities of the President and his Administration. The full 2018 budget will be unveiled sequentially. However, before the proposed budget becomes official it will need be passed by Congress. This means that eliminating the CSB budget is not yet official.
One of the two focuses highlighted by the Administration’s 2018 proposed budget is public safety. The CSB provides public safety services by making the chemical industries safer and protecting the public around those industries. We believe that the CSB serves an important safety function, not only in the chemical industries, but for society as a whole. If you see the value in continuing funding for the CSB, please consider reaching out to your local congress/senate representatives and voicing your opinion. We hope to see the CSB continue to make America and the world a safer place.