The CSB issues safety recommendations to prevent the recurrence or reduce the likelihood or consequences of similar incidents or hazards in the future. Recommendations are issued to a variety of parties, including government entities, safety organizations, trade unions, trade associations, corporations, emergency response organizations, educational institutions, and public interest groups. Recommendations are published in CSB reports and are closed only by vote of the Board. The CSB tracks all recommendations and communicates regularly with recommendations recipients to ensure that the recommended corrective actions are implemented. For more information, see Frequently Asked Questions about CSB recommendations.
2020-05-I-LA-1
Evaluate the hazards to the Bio-Lab Lake Charles facility from hurricanes and accompanying wind, rainwater, floodwater, or storm surge forces. Implement processes and safeguards for protection against those hazards, such as through: a. Constructing new and maintaining existing buildings and structures to withstand hurricane winds and flooding, with a particular focus on those containing hazardous materials; b. Implementing safeguards and processes to ensure hazardous chemicals are not compromised and released during extreme weather events; and c. Following the guidance presented in the Center for Chemical Process Safety Monograph Assessment of and Planning for Natural Hazards. Status: Open - Awaiting Response or Evaluation/Approval of Response
Evaluate the hazards to the Bio-Lab Lake Charles facility from hurricanes and accompanying wind, rainwater, floodwater, or storm surge forces. Implement processes and safeguards for protection against those hazards, such as through:
a. Constructing new and maintaining existing buildings and structures to withstand hurricane winds and flooding, with a particular focus on those containing hazardous materials;
b. Implementing safeguards and processes to ensure hazardous chemicals are not compromised and released during extreme weather events; and
c. Following the guidance presented in the Center for Chemical Process Safety Monograph Assessment of and Planning for Natural Hazards.
2020-05-I-LA-2
Develop and implement an improved Process Hazard Analysis (PHA) action item management system. At a minimum the PHA action item management system should: a. Ensure that each PHA action item or recommendation is assigned to an appropriate person with a deadline for initial evaluation; b. Document and maintain the rationale if the action item or recommendation is modified or rejected; and c. Track the status of all PHA action items or recommendations until they are resolved. Additionally, periodic audits must be conducted on the PHA action item management system to ensure its effectiveness. Status: Open - Awaiting Response or Evaluation/Approval of Response
Develop and implement an improved Process Hazard Analysis (PHA) action item management system. At a minimum the PHA action item management system should:
a. Ensure that each PHA action item or recommendation is assigned to an appropriate person with a deadline for initial evaluation;
b. Document and maintain the rationale if the action item or recommendation is modified or rejected; and
c. Track the status of all PHA action items or recommendations until they are resolved.
Additionally, periodic audits must be conducted on the PHA action item management system to ensure its effectiveness.
2020-05-I-LA-3
Perform process hazard analyses (PHAs) on all buildings and units processing or storing trichloroisocyanuric acid. Ensure that the PHAs are revalidated at least every five years. Also include the building design basis as process safety information for the PHA team to reference during their analysis. Status: Open - Awaiting Response or Evaluation/Approval of Response
Perform process hazard analyses (PHAs) on all buildings and units processing or storing trichloroisocyanuric acid. Ensure that the PHAs are revalidated at least every five years. Also include the building design basis as process safety information for the PHA team to reference during their analysis.
2020-05-I-LA-4
Revise the Bio-Lab Lake Charles emergency response plan to require the following: a. The site’s fire protection system is properly maintained and routinely function-tested in accordance with published industry guidance and NFPA requirements. Require in the emergency response plan that any equipment identified as nonfunctional must be repaired in a timely manner in accordance with NFPA requirements; b. Emergency and fire protection equipment (in particular fire water pumps) must be checked regularly to ensure it is in good working order one month before the start of the U.S. hurricane season, as recommended by the Center for Chemical Process Safety Monograph Assessment of and Planning for Natural Hazards; and c. Site personnel must be trained on the use of all emergency generators and other emergency equipment at least one month before the start of the U.S. hurricane season. Status: Open - Awaiting Response or Evaluation/Approval of Response
Revise the Bio-Lab Lake Charles emergency response plan to require the following:
a. The site’s fire protection system is properly maintained and routinely function-tested in accordance with published industry guidance and NFPA requirements. Require in the emergency response plan that any equipment identified as nonfunctional must be repaired in a timely manner in accordance with NFPA requirements;
b. Emergency and fire protection equipment (in particular fire water pumps) must be checked regularly to ensure it is in good working order one month before the start of the U.S. hurricane season, as recommended by the Center for Chemical Process Safety Monograph Assessment of and Planning for Natural Hazards; and
c. Site personnel must be trained on the use of all emergency generators and other emergency equipment at least one month before the start of the U.S. hurricane season.
2020-05-I-LA-6
Implement the five open recommendations issued in the 2022 U.S. Government Accountability Office Report titled Chemical Accident Prevention: EPA Should Ensure Regulated Facilities Consider Risks from Climate Change, which are: a. The U.S. Environmental Protection Agency (EPA) should provide additional compliance assistance to Risk Management Program (RMP) facilities related to risks from natural hazards and climate change; b. The EPA should design an information system to track common deficiencies found during inspections, including any related to natural hazards and climate change, and use this information to target compliance assistance; c. The EPA should issue regulations, guidance, or both, as appropriate, to clarify requirements and provide direction for RMP facilities on how to incorporate risks from natural hazards and climate change into their risk management programs; d. The EPA should develop a method for inspectors to assess the sufficiency of RMP facilities’ incorporation of risks from natural hazards and climate change into risk management programs and provide related guidance and training to inspectors; and e. The EPA should incorporate the vulnerability of RMP facilities to natural hazards and climate change as criteria when selecting facilities for inspection. Status: Open - Awaiting Response or Evaluation/Approval of Response
Implement the five open recommendations issued in the 2022 U.S. Government Accountability Office Report titled Chemical Accident Prevention: EPA Should Ensure Regulated Facilities Consider Risks from Climate Change, which are:
a. The U.S. Environmental Protection Agency (EPA) should provide additional compliance assistance to Risk Management Program (RMP) facilities related to risks from natural hazards and climate change;
b. The EPA should design an information system to track common deficiencies found during inspections, including any related to natural hazards and climate change, and use this information to target compliance assistance;
c. The EPA should issue regulations, guidance, or both, as appropriate, to clarify requirements and provide direction for RMP facilities on how to incorporate risks from natural hazards and climate change into their risk management programs;
d. The EPA should develop a method for inspectors to assess the sufficiency of RMP facilities’ incorporation of risks from natural hazards and climate change into risk management programs and provide related guidance and training to inspectors; and
e. The EPA should incorporate the vulnerability of RMP facilities to natural hazards and climate change as criteria when selecting facilities for inspection.
2020-05-I-LA-5
Under existing statutory or regulatory authority or through the establishment of new authority by executive or legislative action, for all existing chemical manufacturing and storage facilities that: (1) Are located in a hurricane-prone region as defined by the International Building Code, and (2) Manufacture or store or can inadvertently or otherwise produce (e.g., by chemical reaction) regulated substances inside equipment or building(s) built before more current wind design requirements came into effect Require the facility operators to evaluate the hazards to their facilities from hurricanes and accompanying wind, rainwater, floodwater, or storm surge forces. Require the facility operators to implement processes and safeguards for protection against those hazards, such as through: a. Ensuring that buildings and structures (both new and existing) can withstand hurricane winds and flooding, with a particular focus on buildings and structures containing hazardous materials; b. Implementing safeguards and processes to ensure that hazardous chemicals are not compromised and released during extreme weather events; and/or c. Following the guidance presented in the Center for Chemical Process Safety Monograph Assessment of and Planning for Natural Hazards. Status: Open - Awaiting Response or Evaluation/Approval of Response
Under existing statutory or regulatory authority or through the establishment of new authority by executive or legislative action, for all existing chemical manufacturing and storage facilities that:
(1) Are located in a hurricane-prone region as defined by the International Building Code, and
(2) Manufacture or store or can inadvertently or otherwise produce (e.g., by chemical reaction) regulated substances inside equipment or building(s) built before more current wind design requirements came into effect
Require the facility operators to evaluate the hazards to their facilities from hurricanes and accompanying wind, rainwater, floodwater, or storm surge forces. Require the facility operators to implement processes and safeguards for protection against those hazards, such as through:
a. Ensuring that buildings and structures (both new and existing) can withstand hurricane winds and flooding, with a particular focus on buildings and structures containing hazardous materials;
b. Implementing safeguards and processes to ensure that hazardous chemicals are not compromised and released during extreme weather events; and/or