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.
2008-05-I-GA-6
Incorporate combustible dust hazard awareness into employee and member companies’ training programs, such as the Safety and Health Management Systems training course. Include combustible dust characteristics, especially ignition energy and minimum explosible concentration; best practices for minimizing dust accumulation, especially on elevated surfaces; and safe housekeeping practices.
2008-05-I-GA-7
Add specific combustible dust inspection requirements and metrics to the Food Contact Packaging Facility audit procedures.
2008-05-I-GA-8
Actively promote improvements in combustible dust hazard awareness and control throughout the wholesale baking industry by publishing bulletins or safety guidance that address combustible dust characteristics including ignition energy, minimum explosible concentration, best practices for minimizing dust accumulation, and safe housekeeping practices.
2008-05-I-GA-1
Apply the following standards to the design and operation of the new Port Wentworth facility:
2008-05-I-GA-2
Conduct a comprehensive review of all existing Imperial Sugar Company sugar manufacturing facilities against the standards listed in recommendation R1 and implement identified corrective actions.
2008-05-I-GA-3
Implement a corporate-wide comprehensive housekeeping program to control combustible dust accumulation that will ensure sugar dust, cornstarch dust, or other combustible dust does not accumulate to hazardous quantities on overhead horizontal surfaces, packing equipment, and floors.
2008-05-I-GA-4
Develop training materials that address combustible dust hazards and train all employees and contractors at all Imperial Sugar Company facilities. Require periodic (e.g., annual) refresher training for all employees and contractors.
2008-05-I-GA-5
Improve the emergency evacuation policies and procedures at the Port Wentworth facility; specifically,
2008-05-I-GA-11
(Superseded by 2017-07-I-WI-R10 from the Didion Milling Co. investigation)
Proceed expeditiously, consistent with the Chemical Safety Board’s November 2006 recommendation and OSHA’s announced intention to conduct rulemaking, to promulgate a comprehensive standard to reduce or eliminate hazards from fire and explosion from combustible powders and dust.
2008-05-I-GA-9
Require member companies to:
2008-05-I-GA-10
Ensure that all risk engineers are trained in the hazards of combustible dust, and that refresher training occurs at regular intervals. Provide a copy of your combustible dust hazard awareness training materials to your clients who deal with combustible dust.
2001-01-H-8
Expand the Responsible Care Process Safety Code to emphasize the need for managing reactive hazards. Ensure that: · Member companies are required to have programs to manage reactive hazards that address, at a minimum, hazard identification, hazard evaluation, management of change, inherently safer design, and adequate procedures and training. · There is a program to communicate to your membership the availability of existing tools, guidance, and initiatives to aid in identifying and evaluating reactive hazards.
2001-01-H-9
Develop and implement a program for reporting reactive incidents that includes the sharing of relevant safety knowledge and lessons learned with your membership, the public, and government to improve safety system performance and prevent future incidents.
2001-01-H-10
Work with NIST in developing and implementing a publicly available database for reactive hazard test information. Promote submissions of data by your membership.
2001-01-H-11
Communicate the findings and recommendations of this report to your membership.
2001-01-H-24
2001-01-H-23
2001-01-H-6
Publish comprehensive guidance on model reactive hazard management systems. At a minimum, ensure that these guidelines cover: · For companies engaged in chemical manufacturing: reactive hazard management, including hazard identification, hazard evaluation, management of change, inherently safer design, and adequate procedures and training. · For companies engaged primarily in the bulk storage, handling, and use of chemicals: identification and prevention of reactive hazards, including the inadvertent mixing of incompatible substances.
2001-01-H-7
2001-01-H-3
Revise the Accidental Release Prevention Requirements, 40 CFR 68, to explicitly cover catastrophic reactive hazards that have the potential to seriously impact the public, including those resulting from self-reactive chemicals and combinations of chemicals and process-specific conditions. Take into account the recommendations of this report to OSHA on reactive hazard coverage. Seek congressional authority if necessary to amend the regulation.
2001-01-H-4
Modify the accident reporting requirements in RMP* Info to define and record reactive incidents. Consider adding the term "reactive incident" to the four existing "release events" in EPA's current 5-year accident reporting requirements (Gas Release, Liquid Spill/Evaporation, Fire, and Explosion). Structure this information collection to allow EPA and its stakeholders to identify and focus resources on industry sectors that experienced the incidents; chemicals and processes involved; and impact on the public, the workforce, and the environment.
2001-01-H-18
2001-01-H-16
Expand the existing Responsible Distribution Process to include reactive hazard management as an area of emphasis. At a minimum, ensure that the revisions address storage and handling, including the hazards of inadvertent mixing of incompatible chemicals.
2001-01-H-17
2001-01-H-5
Develop and implement a publicly available database for reactive hazard test information. Structure the system to encourage submission of data by individual companies and academic and government institutions that perform chemical testing.
2001-01-H-1
(Superseded by 2021-02-I-WV-R13 from the Optima Belle report)
Amend the Process Safety Management Standard (PSM), 29 CFR 1910.119, to achieve more comprehensive control of reactive hazards that could have catastrophic consequences.
- Literature surveys (e.g., Bretherick's Handbook of Reactive Chemical Hazards, Sax's Dangerous Properties of Industrial Materials).
- Information developed from computerized tools (e.g., ASTM's CHETAH, NOAA's The Chemical Reactivity Worksheet).
- Chemical reactivity test data produced by employers or obtained from other sources (e.g., differential scanning calorimetry, thermogravimetric analysis, accelerating rate calorimetry).
- Relevant incident reports from the plant, the corporation, industry, and government.
- Chemical Abstracts Service.
- Rate and quantity of heat or gas generated.
- Maximum operating temperature to avoid decomposition.
- Thermal stability of reactants, reaction mixtures, byproducts, waste streams, and products.
- Effect of variables such as charging rates, catalyst addition, and possible contaminants.
- Understanding the consequences of runaway reactions or toxic gas evolution.
2001-01-H-2
Implement a program to define and record information on reactive incidents that OSHA investigates or requires to be investigated under OSHA regulations. Structure the collected information so that it can be used to measure progress in the prevention of reactive incidents that give rise to catastrophic releases.
2001-01-H-19
2001-01-H-12
Expand the Responsible Care Process Safety Code to emphasize the need for managing reactive hazards. Ensure that: · Member companies are required to have programs to manage reactive hazards that address, at a minimum, hazard identification, hazard evaluation, management of change, inherently safer design, and adequate procedures and training. · There is a program to communicate to your membership the availa bility of existing tools, guidance, and initiatives to aid in identifying and evaluating reactive hazards.
2001-01-H-13
2001-01-H-14
2001-01-H-15
2001-01-H-21
2001-01-H-22
2001-01-H-20
2019-01-I-TX-6
Update API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities, or other appropriate products to include flammable gas detection systems within the leak detection section or where appropriate. The discussion of flammable gas and/or leak detection should address both engineering and administrative controls, including actions associated with responding to a catastrophic or emergency leak.
2019-01-I-TX-8
Modify 40 C.F.R. §68.115(b)(2)(i) to expand coverage of the RMP rule to include all flammable liquids, including mixtures, with a flammability rating of NFPA-3 or higher.
(Superseded 2010-02-I-PR-R1 from the Caribbean Petroleum (CAPECO) report)
2019-01-I-TX-1
Develop and implement a process safety management system for the ITC Deer Park terminal applicable to all atmospheric storage tanks and associated equipment in highly hazardous chemical service.a The program should follow industry guidance provided in publications such as the American Petroleum Industry's API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities and the Center for Chemical Process Safety’s Guidelines for Risk Based Process Safety.
2019-01-I-TX-2
Develop and implement a condition monitoring program for all pumps in highly hazardous chemical service at the ITC Deer Park terminal. Ensure that condition monitoring equipment is programmed with control limits, including but not limited to vibration, consistent with ANSI/HI 9.6.9.-2018, that trigger alarms when control limits are exceeded, and that operating procedures and training reflect the appropriate actions to take when an alarm is triggered.
2019-01-I-TX-3
Install flammable gas detection systems with associated alarm functions in product storage and transfer areas at the ITC Deer Park terminal where flammable substance releases could occur. Develop and implement a response plan and operator training for actions to take when an alarm sounds.
2019-01-I-TX-4
Install remotely operated emergency isolation valves configured to “Fail-Closed” for all atmospheric storage tanks that contain highly hazardous chemicals or liquids with a flammability rating of NFPA-3 or higher at the ITC Deer Park terminal.
2019-01-I-TX-5
Conduct an evaluation of the design of all new and existing tank farms at the ITC Deer Park terminal against the applicable sections of the Third Edition of API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities and the 2021 Edition of NFPA 30, Flammable and Combustible Liquids Code. At a minimum the evaluation should include, but is not limited to the following sections of API STD 2610:
Section 4 Site Selection and Spacing Requirements Section 7 Fire Prevention and Protection Section 8.1 Aboveground Petroleum Storage Tanks Section 9 Dikes and Berms Section 10 Pipe, Valves, Pumps, and Piping Systems Section 11 Loading, Unloading, and Product Transfer Facilities
and the following chapters of NFPA 30:
Chapter 21 Storage of Ignitible (Flammable or Combustible) Liquids in Tanks – Requirements for All Storage Tanks and Chapter 22 Storage of Ignitible (Flammable or Combustible) Liquids in Tanks – Aboveground Storage Tanks
The evaluation should identify additional engineering controls needed to address minimal tank spacing, subdivisions between tanks, and placement of process equipment in containment areas. In addition, the evaluation should assess the adequacy of the containment wall and drainage system designs, accounting for the impact of firefighting activities, including the application of firewater and foam on these systems. Develop and implement recommendations based on findings from the evaluation.
2019-01-I-TX-7
Eliminate the atmospheric storage tank exemption from the PSM standard.
(Superseded 2001-05-I-DE-R1 from the Motiva report and 2010-02-I-PR-R4 from the Caribbean Petroleum (CAPECO) report)