The US Chemical Safety Board and Inherently Safer Technology

The United State (US) Chemical Safety Board (CSB) was created by the same legislation that mandated the regulation of high hazard industries by the Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (EPA) under the Process Safety Management (PSM) and the Risk Management Program (RMP) regulations respectively. A great deal of knowledge and experience has accumulated in the two decades since this legislation, however, and this experience can suggest improvements to high hazard chemical regulation. In particular, the PSM and RMP regulations did not incorporate several principles that are today widely accepted to be crucial for effective process safety management, especially those principles related to inherently safer design and technology.

The CSB legislative mandate does not constrain the Agency to the existing regulatory framework, however, but rather calls for the CSB to issue recommendations to improve it. This presentation will review the CSB's experience with “outside the box” recommendations that call for implementation of inherently safer technology and principles from six investigations (DuPont, Bayer CropScience, Kleen Energy, ConAgra Foods, Valero refinery, BP refinery). The presentation concludes with a brief discussion of the challenges the Agency faces in advancing those principles, and the need for increasing collaboration to advance the adoption of inherently safer design and technology.