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.
2010-06-I-WV-2
Take sustained measures to minimize the exposure of hazards to workers handling highly toxic gases from cylinders and associated regulators, gages, hoses, and appliances. Ensure that OSHA managers, compliance officers, equivalent state OSHA plan personnel, and regulated parties conform, under the Process Safety Management Standard (29 CFR 1910.119) Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) provisions, to industry practices at least as effective as the following: NFPA 55 - Compressed Gases and Cryogenic Fluids Code (2010) CGA P-1 Safe Handling of Compressed Gases in Containers (2008) CGA E-9 Standard for Flexible, PTFE-lined Pigtails for Compressed Gas Service (2010) ASME B31.3 Process Piping (2008) Status: Open - Acceptable Response or Alternate Response
Take sustained measures to minimize the exposure of hazards to workers handling highly toxic gases from cylinders and associated regulators, gages, hoses, and appliances. Ensure that OSHA managers, compliance officers, equivalent state OSHA plan personnel, and regulated parties conform, under the Process Safety Management Standard (29 CFR 1910.119) Recognized and Generally Accepted Good Engineering Practices (RAGAGEP) provisions, to industry practices at least as effective as the following:
2018-01-I-OK-1
Implement one of the three following options regarding regulatory changes: (a) OPTION 1: Apply the Process Safety Management (PSM) standard (29 CFR 1910.119) to the drilling of oil and gas wells; or (b) OPTION 2: Apply the Process Safety Management (PSM) standard (29 CFR 1910.119) to the drilling of oil and gas wells as in OPTION 1, and make the necessary modifications to customize it to oil and gas drilling operations; or (c) OPTION 3: Develop a new standard with a safety management system framework similar to PSM that applies only to the drilling of onshore oil and gas wells that includes but is not limited to the following: Detailed written operating procedures with specified steps and equipment alignment for all operations; Written procedures for the management of changes (except replacements in kind) in procedures, the well plan, and equipment; A risk assessment of hazards associated with the drilling plan; A requirement to follow Recognized and Generally Accepted Good Engineering Practices (RAGAGEP); Development of a Well Construction Interface Document between the operator and the drilling contractor prior to the commencement of drilling activities which at a minimum includes a bridging document and well plan specifying barriers and how to manage them; The performance and documentation of flow checks using acceptable methods at defined points during the operation for a specified duration; and A requirement for employee participation, similar to the Employee Participation requirement in the OSHA PSM standard. Status: Open - Awaiting Response or Evaluation/Approval of Response
Implement one of the three following options regarding regulatory changes:
(a) OPTION 1: Apply the Process Safety Management (PSM) standard (29 CFR 1910.119) to the drilling of oil and gas wells; or
(b) OPTION 2: Apply the Process Safety Management (PSM) standard (29 CFR 1910.119) to the drilling of oil and gas wells as in OPTION 1, and make the necessary modifications to customize it to oil and gas drilling operations; or
(c) OPTION 3: Develop a new standard with a safety management system framework similar to PSM that applies only to the drilling of onshore oil and gas wells that includes but is not limited to the following:
Detailed written operating procedures with specified steps and equipment alignment for all operations;
Written procedures for the management of changes (except replacements in kind) in procedures, the well plan, and equipment;
A risk assessment of hazards associated with the drilling plan;
A requirement to follow Recognized and Generally Accepted Good Engineering Practices (RAGAGEP);
Development of a Well Construction Interface Document between the operator and the drilling contractor prior to the commencement of drilling activities which at a minimum includes a bridging document and well plan specifying barriers and how to manage them;
The performance and documentation of flow checks using acceptable methods at defined points during the operation for a specified duration; and
A requirement for employee participation, similar to the Employee Participation requirement in the OSHA PSM standard.
2020-07-I-NC-1
Issue a safety information product (such as a letter of interpretation) addressing the analysis and control of hazards that are not pre-existing but which result from work activities inside permit-required confined spaces. Status: Open - Awaiting Response or Evaluation/Approval of Response
Issue a safety information product (such as a letter of interpretation) addressing the analysis and control of hazards that are not pre-existing but which result from work activities inside permit-required confined spaces.
2020-07-I-NC-2
Require Owner/Operators to ensure the coordination of simultaneous operations involving multiple work groups, including contractors. Include in the requirement for Owner/Operators to ensure the following activities occur: • Identification of potential simultaneous operations • Identification of potential hazardous interactions • Evaluation and implementation of necessary safeguards to allow for safe simultaneous operations • Coordination, including shared communication methods, between the simultaneous operations • Inclusion of emergency response personnel or services in the planning and coordination of the simultaneous operations. As necessary, seek the regulatory authority to promulgate this requirement. Status: Open - Awaiting Response or Evaluation/Approval of Response
Require Owner/Operators to ensure the coordination of simultaneous operations involving multiple work groups, including contractors. Include in the requirement for Owner/Operators to ensure the following activities occur:
• Identification of potential simultaneous operations
• Identification of potential hazardous interactions
• Evaluation and implementation of necessary safeguards to allow for safe simultaneous operations
• Coordination, including shared communication methods, between the simultaneous operations
• Inclusion of emergency response personnel or services in the planning and coordination of the simultaneous operations.
As necessary, seek the regulatory authority to promulgate this requirement.
2020-01-I-TX-8
Issue a safety information product (such as a safety bulletin or safety alert) that addresses the requirements for protecting workers from hazardous air contaminants and from hazardous energy. Status: Open - Awaiting Response or Evaluation/Approval of Response
Issue a safety information product (such as a safety bulletin or safety alert) that addresses the requirements for protecting workers from hazardous air contaminants and from hazardous energy.
2007-6-I-KS-1
Revise the "Guidance for Hazard Determination for compliance with the OSHA Hazard Communication Standard" to advise chemical manufacturers and importers that prepare MSDSs to: -Evaluate flammable liquids to determine their potential to accumulate static electricity and form ignitable vapor-air mixtures in storage tanks. -Test the conductivity of the flammable liquid and include the testing results in the MSDS. Status: Open - Acceptable Response or Alternate Response
Revise the "Guidance for Hazard Determination for compliance with the OSHA Hazard Communication Standard" to advise chemical manufacturers and importers that prepare MSDSs to: -Evaluate flammable liquids to determine their potential to accumulate static electricity and form ignitable vapor-air mixtures in storage tanks. -Test the conductivity of the flammable liquid and include the testing results in the MSDS.
2005-4-I-TX-9
2. Amend the OSHA PSM standard to require that a management of change (MOC) review be conducted for organizational changes that may impact process safety including: a. major organizational changes such as mergers, acquisitions, or reorganizations; b. personnel changes, including changes in staffing levels or staff experience; and c. policy changes such as budget cutting. Status: Open - Unacceptable Response/No Response Received
2. Amend the OSHA PSM standard to require that a management of change (MOC) review be conducted for organizational changes that may impact process safety including: a. major organizational changes such as mergers, acquisitions, or reorganizations; b. personnel changes, including changes in staffing levels or staff experience; and c. policy changes such as budget cutting.
2010-02-I-PR-4
a) Revise the Flammable and Combustible Liquids standard (29 CFR§ 1910.106) to require installing, using, and maintaining a high-integrity automatic overfill prevention system with a means of level detection, logic/control equipment, and independent means of flow control for bulk aboveground storage tanks containing gasoline, jet fuel, other fuel mixtures or blends tocks, and other flammable liquids having an NFPA 704 flammability rating of 3 or higher, to protect against loss of containment. At a minimum, this system shall meet the following requirements: 1. Separated physically and electronically and independent from the tank gauging system. 2. Engineered, operated, and maintained to achieve an appropriate level of safety integrity in accordance with the rrequirements of Part 1 of International Electro-technical Commission (IEC) 61511-SER ed1.0B-2004, Functional Safety - Safety Instrumented Systems for the Process Industry Sector. Such a system would employ a safety integrity level (SIL) documented in accordance with the principles in Part 3 of IEC 61511-SER ed1.0B-2004, accounting for the following factors: i. The existence of nearby populations and sensitive environments; ii. The nature and intensity of facility operations; iv. The extent/ rigor of operator monitoring. 3. Proof tested in accordance with the validated arrangements and procedures with sufficient frequency to ensure the specified safety integrity level is maintained. b) Establish hazard analysis, management of change and mechanical integrity management system elements for bulk above ground storage tanks in the revised 1910.106 standard that are similar to those in the Process Safety Management of Highly Hazardous Chemicals standard (29 CFR § 1910.119) and ensure these facilities are subject to Recognized and Generally Accepted Good Engineering Practices (RAGAGEP). Status: Open - Awaiting Response or Evaluation/Approval of Response