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.
2023-02-I-LA-4
Per the requirements in EPA Rule Procedures for Prioritization of Chemicals for Risk Evaluation Under the Toxic Substances Control Act, initiate prioritization to evaluate whether hydrogen fluoride, including its anhydrous and aqueous acid forms, is a High-Priority Substance for risk evaluation. If it is determined to be a High-Priority Substance, conduct a risk evaluation of hydrogen fluoride to determine whether it presents an unreasonable risk of injury to health or the environment. If it is determined to present an unreasonable risk of injury to health or the environment, apply requirements to hydrogen fluoride to the extent necessary to eliminate or significantly mitigate the risk, for example by using a methodology such as the hierarchy of controls. (Supersedes 2019-04-I-PA-R3 from the Philadelphia Energy Solutions Report) Status: Open - Awaiting Response or Evaluation/Approval of Response
Per the requirements in EPA Rule Procedures for Prioritization of Chemicals for Risk Evaluation Under the Toxic Substances Control Act, initiate prioritization to evaluate whether hydrogen fluoride, including its anhydrous and aqueous acid forms, is a High-Priority Substance for risk evaluation. If it is determined to be a High-Priority Substance, conduct a risk evaluation of hydrogen fluoride to determine whether it presents an unreasonable risk of injury to health or the environment. If it is determined to present an unreasonable risk of injury to health or the environment, apply requirements to hydrogen fluoride to the extent necessary to eliminate or significantly mitigate the risk, for example by using a methodology such as the hierarchy of controls.
(Supersedes 2019-04-I-PA-R3 from the Philadelphia Energy Solutions Report)
2023-02-I-LA-1
Perform a comprehensive third-party audit of the Geismar facility’s process safety and allied management systems as soon as practicable. The audit shall: A. Be performed or led by an individual, firm, or team meeting the requirements outlined in paragraphs (b), (c), and (d) of Appendix E of this report. B. Evaluate compliance with applicable federal standards (40 C.F.R. § 68 and 29 C.F.R. § 1910.119). In particular, the audit shall include the required elements that contributed to these incidents, including but not limited to: 1. management of change; 2. mechanical integrity; 3. quality assurance; 4. pre-startup safety reviews; 5. operating procedures; and 6. contractor management. C. Evaluate other internal management systems that contributed to these incidents. In particular, the audit shall include but not be limited to: 1. management of organizational and personnel change; 2. management of safety-related capital projects; 3. organizational resilience; and 4. safe work practices including, but not limited to: a. work permitting; b. preparation of equipment for maintenance; c. control of hazardous energy; d. line break safety; and e. personal protective equipment. D. Use the Center for Chemical Process Safety’s Guidelines for Auditing Process Safety Management Systems as guidance to verify both the suitability of these systems and their effective, consistent implementation and performance. E. Result in the development of a comprehensive report meeting the requirements outlined in paragraphs (e) and (f) of Appendix E of this report. If any findings are rejected, the rationale for and documentation supporting the merit of the rejection shall be included. The report in its entirety shall be made available to the Honeywell workforce at the Geismar, Louisiana; Baton Rouge, Louisiana; and Metropolis, Illinois, sites. Status: Open - Awaiting Response or Evaluation/Approval of Response
Perform a comprehensive third-party audit of the Geismar facility’s process safety and allied management systems as soon as practicable. The audit shall:
A. Be performed or led by an individual, firm, or team meeting the requirements outlined in paragraphs (b), (c), and (d) of Appendix E of this report.
B. Evaluate compliance with applicable federal standards (40 C.F.R. § 68 and 29 C.F.R. § 1910.119). In particular, the audit shall include the required elements that contributed to these incidents, including but not limited to:
1. management of change; 2. mechanical integrity; 3. quality assurance; 4. pre-startup safety reviews; 5. operating procedures; and 6. contractor management.
C. Evaluate other internal management systems that contributed to these incidents. In particular, the audit shall include but not be limited to:
1. management of organizational and personnel change; 2. management of safety-related capital projects; 3. organizational resilience; and 4. safe work practices including, but not limited to:
a. work permitting; b. preparation of equipment for maintenance; c. control of hazardous energy; d. line break safety; and e. personal protective equipment.
D. Use the Center for Chemical Process Safety’s Guidelines for Auditing Process Safety Management Systems as guidance to verify both the suitability of these systems and their effective, consistent implementation and performance.
E. Result in the development of a comprehensive report meeting the requirements outlined in paragraphs (e) and (f) of Appendix E of this report. If any findings are rejected, the rationale for and documentation supporting the merit of the rejection shall be included. The report in its entirety shall be made available to the Honeywell workforce at the Geismar, Louisiana; Baton Rouge, Louisiana; and Metropolis, Illinois, sites.
2023-02-I-LA-2
Require periodic reporting updates from the Geismar site regarding the closure of the audit findings. The periodic updates shall continue until all audit findings are fully closed. Status: Open - Awaiting Response or Evaluation/Approval of Response
Require periodic reporting updates from the Geismar site regarding the closure of the audit findings. The periodic updates shall continue until all audit findings are fully closed.
2023-02-I-LA-3
Perform a Safer Technologies and Alternatives Analysis (STAA) for the Honeywell Geismar HFC-245fa unit. The STAA shall meet the requirements outlined in paragraphs (a) and (b) of Appendix F of this report. Status: Open - Awaiting Response or Evaluation/Approval of Response
Perform a Safer Technologies and Alternatives Analysis (STAA) for the Honeywell Geismar HFC-245fa unit. The STAA shall meet the requirements outlined in paragraphs (a) and (b) of Appendix F of this report.