Public Comments Submitted by the CSB
Click here to view U.S. Chemical Safety and Hazard Investigation Board’s (CSB) comments in response to the California Environmental Protection Agency’s (CalEPA) notice of proposed rulemaking titled, Proposed Amendments to the California Accidental Release Prevention (CalARP) Regulations - Title 19, Division 5, Chapter 2, California Code of Regulations Sections 5050.3, 5110.1 5110.13, 5110.16, 5130.6, NOTICE OF MODIFICATION TO TEXT OF PROPOSED RULEMAKING, (15-day Changes) published in the California Regulatory Notice Register on December 9, 2025.
Click here to view comments submitted by the U.S. Chemical Safety and Hazard Investigation Board (CSB) on September 24, 2025, in response to OSHA’s memorandum dated January 20, 2023 to address the questions from the document titled Modernizing OSHA’s Voluntary Protection Program that fall under the purview of the CSB and our vision of a nation free from chemical disasters.
Click here to view comments submitted by the U.S. Chemical Safety and Hazard Investigation Board (CSB) on July 17, 2024 in response to OSHA’s proposed rule titled Emergency Response, published in the Federal Register on February 5, 2024 (89 CFR 7774).
Click here to view follow up on a letter regarding the Federal Energy Regulatory Commission’s (FERC) June 2023 final rule on Transmission System Planning Performance Requirements for Extreme Weather, in which the U.S. Chemical Safety and Hazard Investigation Board (CSB) urged FERC to address additional extreme weather events, such as high winds and hurricanes, in a future rulemaking as soon as possible.
Click here to view comments in response to the EPA’s Notice entitled, Public Engagement Webinars; Pre-Prioritization and Consideration of Existing Chemical Substances for Future Prioritization Under the Toxic Substances Control Act (TSCA) (Docket Number EPA-HQ-OPPT-2023-0606). As a result of multiple investigations involving highly toxic hydrofluoric acid and hydrogen fluoride (HF), the CSB urges the EPA to initiate prioritization under TSCA to evaluate whether HF is a High-Priority Substance for risk evaluation.
Click here to view the U.S. Chemical Safety and Hazard Investigation Board’s (CSB) comments in response to the Environmental Protection Agency’s (EPA) proposed rule titled, Revisions to Standards for the Open Burning/Open Detonation of Waste Explosives, published in the Federal Register on March 20, 2024.
Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) July 19, 2023, letter to Washington State Department of Labor and Industries
Click here to view The U.S. Chemical Safety and Hazard Investigation Board's (CSB) July 13, 2023, letter to The Federal Energy Regulatory Commission (FERC).
Click here to view The U.S. Chemical Safety and Hazard Investigation Board's (CSB's ) February 3, 2023, letter to support the Environmental Protection Agency’s (EPA) National Enforcement and Compliance Initiative (NECI): Reducing Risks of Accidental Releases at Industrial and Chemical Facilities.
Click here to view The U.S. Chemical Safety and Hazard Investigation Board’s (CSB) comments (December 29, 2022) on the National Fire Protection Association’s (NFPA) proposed consolidated Combustible Dust standard (NFPA 660: Standards for Combustible Dust).
Click here to view the U.S. Chemical Safety and Hazard Investigation Board’s (CSB) comments on the Occupational Safety and Health Administration’s (OSHA) September 20, 2022, Federal Register Notice (87 Fed. Reg. 57520) to address the agency’s Process Safety Management standard modernization rulemaking project (PSM STD Modernization). The comments address some new issues, as well as supplement our previous submission (CSB letter to OSHA Docket: OSHA-2013-0020 dated March 31, 2014) and applicable recommendations made by the CSB to OSHA and other recipients. November 9, 2022
Click here to view U.S. Chemical Safety and Hazard Investigation Board’s (CSB) comments on the Environmental Protection Agency’s (EPA’s) proposed rule, “Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention” (RMP rule) October 26, 2022.
Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the Environmental Protection Agency (EPA) Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act, Section 112(r)(7). July 30, 2021.
Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the State of Washington Department of Labor and Industries (L&I) Division of Occupational Safety and Health (DOSH) proposed rulemaking to amend Chapter 296-67 WAC, Safety Standards for Process Safety Management of Highly Hazardous Chemicals.
Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the Environmental Protection Agency (EPA) Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act, Section 112(r)(7). July 20, 2018.
Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the State of Washington Department of Labor and Industries Division of Occupational Safety and Health proposed rulemaking in amend Chapter 296-67 WAC, Safety Standards for Process Safety Management of Highly Hazardous Chemicals. May 11, 2018.
Click here to view Public Comments by CSB Board Member Rick Engler before the California Department of Industrial Relations Occupational Safety and Health Standards Board on the Proposed Safety Order for Adoption: Process Safety Management for Petroleum Refineries -- Oakland, California, May 18, 2017.
Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the State of California Occupational Safety and Health Standards Board Notice of Proposed Rulemaking to adopt New Section §5189.1 Process Safety Management for Refineries. Sept. 2, 2016.
Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the Environmental Protection Agency (EPA) Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act, Section 112(r)(7). May 10, 2016.
Click here to view the U.S. Chemical Safety and Hazard Investigation Board’s (CSB) response State of California Department of Industrial Relations (DIR) Division of Occupational Safety and Health Proposed GISO §5189.1, Process Safety Management (PSM) for Petroleum Refineries. Oct. 7, 2015.