Over the past two decades, there have been 167 serious reactive chemical incidents, killing an average of five people every year. These are two of the reasons why the U.S. Chemical Safety and Hazard Investigation Board (CSB) calls reactive hazards a "significant chemical safety problem."
The board announced its findings at a public meeting held in Houston earlier this week.
The CSB recommendations won initial praise from industry and labor groups. The release of the two-year special investigation represents a major accomplishment for an agency that has often been criticized for mismanagement by members of Congress and the Office of Inspector General.
The safety board said that when it comes to covering reactive chemical hazards, there are "significant gaps" both in OSHA's Process Safety Management (PSM) standard (29 CFR 1910.119) and in EPA's Chemical Accident Prevention Requirements (RMP). As a result, CSB recommended that both agencies improve their efforts to control and monitor reactive hazards.
One reason it took CSB two years to complete its special investigation of reactive chemical hazards is that there is currently no comprehensive source for information on such incidents; rectifying the data collection problem figured prominently in the board's recommendations.
Currently OSHA's PSM rule lists some "self-reactive" chemicals, but according to CSB, the list approach is incomplete because it does not cover reactive hazards that result from process-specific conditions or from a combination of chemicals.
The safety board recommended that:
- OSHA amend its PSM to include reactive chemical hazards resulting from process-specific and combinations of chemicals;
- OSHA and EPA establish a central registry of reactive chemical incident reports and investigate such occurrences;
- EPA revise its RMP (40 CFR 68) to include catastrophic reactive hazards.
- The National Institute of Standards and Technology develop a publicly available database for reactive hazard test information.
- The Center for Chemical Process Safety publish comprehensive guidance on model reactive hazard management systems.
- The American Chemistry Council (ACC), the National Association of Chemical Distributors and the Synthetic Organic Chemical Manufacturers Association expand their safety codes to emphasize the need for managing reactive hazards.
"ACC agrees with the board's conclusion that more can be done to identify and appropriately manage reactive chemical hazards," commented Chris VandenHeuvel, an ACC spokesperson. He applauded CSB's decision to opt for "performance-based" OSHA and EPA regulations, rather than a specific list of reactive chemicals.
"In early 2003," said VandenHeuvel, "ACC expects to release new guidelines, based largely on successful programs currently used by ACC members, that will better identify and manage potential reactive hazards."
The CSB recommendations also won the approval of the Paper, Allied-Industrial, Chemical and Energy Workers (PACE), but the union called on OSHA and industry to follow up on the proposals.
"Workers need OSHA Assistant Secretary of Labor John Henshaw to reverse his decision made last year to drop the PSM standard from OSHA's regulatory agenda," said Dave Ortlieb, PACE's health and safety director. "Their lives depend on it."