- Add explicit coverage of catastrophic reactive hazards (i.e., in addition to toxic and flammable hazards).
- Require inherently safer systems analysis and a hierarchy of controls when facilities establish safeguards for identified process hazards.
What Coordination Between Occupational Safety and Environmental Protection Regulators Does CSB Recommend?
CSB has recommended that EPA and OSHA, and their state counterparts, coordinate PSM and ARP regulatory activities to maximize the benefits of both. Readers should note that President Obama’s Executive Order and subsequent federal activities include these efforts. I’ve written about the Executive Order here, and about a report by an interagency task force coordinating these responses here.
Self-Assessment Checklist
- Do any of my organization’s facilities manage chemicals subject to PSM or ARP?
- Does any facility manage reactive chemicals that pose analogous accident hazards?
- If so, does any facility comply with:
- One of those programs?
- Both of those programs?
- Has the organization developed organizational-level and/or facility-level programs for chemical risk assessment and handling consistent with requirements of PSM and/or ARP requirements?
- Is the organization participating in review and reform activities being undertaken by the implementing agency (or at least tracking them)?
Where Can I Go For More Information?
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 25 years. He was involved in developing 16 existing products, including Environmental Compliance: A Simplified National Guide and The Complete Guide to Environmental Law. This article was republished with permission from Specialty Technical Publishers, which provides a variety of single-law and multi-law services, intended to facilitate clients’ understanding of and compliance with requirements. These include: Federal Toxics Program Commentary; Environmental Compliance: A Simplified National Guide; A range of Air Quality MACT Standards Guides; Environmental Auditing: Federal Compliance Guide; The Complete Guide to Hazardous Materials Enforcement and Liability: California.
