Chemical Safety Board Changes

The Chemical Safety Board (CSB) continues to undergo unsettling changes, as described in the C&EN article Changes on tap at U.S. Chemical Safety Board, and in the PEER report Outgoing Chemical Safety Chair Fires Managing Director.

The following is a comment on the C&EN article made by Ian Sutton.

As a process safety professional I have two responses to this article.

The first is that clients reasonably expect to receive reports from incident investigations and hazard analyses promptly. Delays lead to justified frustration for the client, and the sense of urgency and opportunity is lost. In particular, if there has been a serious event at a process facility, senior management is shaken up and is usually willing to spend the money and do whatever it takes to prevent something similar from happening again.

When I read, “six reports were incomplete, one of which stretched back six years”, my mind jumped to Hamlet’s words to do with delay (in his case, procrastination),

. . . enterprises of great pith and moment . . . their currents turn awry, And lose the name of action.

After six years, any sense of urgency is long gone. The “name of action” has disappeared.

The Chemical Safety Board want their investigations to be thorough. But that goal has to be traded against the importance of timeliness.

In the immediate follow-up to a serious incident, site management will often issue “Immediate Temporary Controls (ITC)”  — generally within 24 hours. They don’t know the root causes of the event but that can identify immediate causes.

Let’s say that a leak was caused by corrosion under insulation; the ITC could be to “Check the integrity of all piping under insulation”. Later on, the incident investigators may identify a root cause, say to do with not properly following engineering standards.

Maybe the CSB could do something similar, i.e., issue recommendations very quickly based not on root causes, but on immediate causes.

The second thought is that process safety management (PSM) is now well-established and mature. After all, the first standards were issued in the early 1990s. This means that managers are used to looking at incidents in terms of the elements of PSM such Management of Change, or Operating Procedures, or Prestartup Safety Reviews. It would be helpful if the CSB could organize its analysis and finding around those well-established elements..