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“Terrorism Concerns Results in Chemical Storage Rule Delay” #WestTexasFire #Chemicals

The Trump administration is delaying a new rule tightening safety requirements for companies that store large quantities of dangerous chemicals. The rule was imposed after a fertilizer plant in West, Texas, exploded in 2013, killing 15 people.

Scott Pruitt, the administrator of the Environmental Protection Agency, delayed the effective date of the Obama-era rule until June.

Pruitt’s action late Monday came in response to complaints by the chemical industry and other business groups that the rule could make it easier for terrorists and other criminals to target refineries, chemical plants, and other facilities by requiring companies to make public the types and quantities of chemicals stored on site.

The EPA issued a final rule in January, seven days before President Barack Obama left office. The EPA said at the time that the rule would help prevent accidents and improve emergency preparedness by allowing first responders better data on chemical storage.

A coalition of business groups opposed the rule, saying in a letter to Pruitt that it would do “irreparable harm” to companies that store chemicals and put public safety at risk.

Chet Thompson, president and CEO of the American Fuel and Petrochemical Manufacturers, an industry group, praised Pruitt’s delay of the EPA rule.

“The midnight rulemaking in the final days of the Obama administration would not enhance safety, create security vulnerabilities and divert resources from further enhancing existing safety programs,” Thompson said.

Environmental groups questioned industry claims as “self-interested” and misleading.

Hazardous chemical incidents like the explosion in West, Texas, are “frighteningly common,” according to the Environmental Justice Health Alliance, an advocacy group. More than 1,500 chemical releases or explosions were reported from 20014 to 2013, causing 58 deaths and more than 17,000 injuries, the group said.

Instead of bowing to industry complaints, the EPA should “stand with the first responders, at-risk communities, safety experts, workers, small businesses and others who live at daily risk of a catastrophic chemical release or explosion,” the group wrote in a letter last month to members of Congress.

The Obama-era rule came after a three-year process that included eight public hearings and more than 44,000 public comments, the group said.

The Obama administration said the rule would help prevent chemical incidents such as the 2013 explosion in Texas, while enhancing emergency preparedness requirements, improving management of data on chemical storage and modernizing policies and regulations.

Sen. Jim Inhofe, R-Okla., said the Obama-era rule gives “a blueprint to those who would like to do us harm,” adding that existing regulations will remain in place to continue ensuring the safety of chemical plants and other facilities.

Source: Insurance Journal

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“CSB Releases New Safety Video Detailing Investigation into 2013 Fatal Fire and Explosion at the Williams Olefins Plant in Geismar, LA”

January 25, 2017, Washington, DC –

Today the U.S. Chemical Safety Board (CSB) released a safety video of its investigation of the June 13, 2013 explosion and fire at the Williams Olefins Plant in Geismar, Louisiana, which killed two workers and injured an additional 167.  The deadly explosion and fire occurred when a heat exchanger containing flammable liquid propane violently ruptured.

The CSB’s newly released 12-minute safety video entitled, “Blocked In,” includes a 3D animation of the explosion and fire as well as interviews with CSB investigator Lauren Grim and Chairperson Vanessa Allen Sutherland. The video is based on the CSB’s case study on the Williams incident and can be viewed on the CSB’s website and YouTube.

Chairperson Sutherland said, “Our investigation on the explosion at Williams describes an ineffective process safety management program at the plant at the time of the incident. We urge other companies to incorporate our recommendations at their facilities and to assess the state of their cultures to promote safety at all organizational levels to prevent a similar accident. ”

The CSB’s investigation found many process safety management program deficiencies at Williams, which set the stage for the incident. In particular, the CSB found that the heat exchanger that failed was completely isolated from its pressure relief valve.

In the video, Investigator Lauren Grim said, “When evaluating overpressure protection requirements for heat exchangers, engineers must think about how to manage potential scenarios, including unintentional hazards. In this case, simply having a pressure relief valve available could have prevented the explosion.”

The CSB investigation concluded that in the twelve years leading to the incident, a series of process safety management program deficiencies caused the heat exchanger to be unprotected from overpressure.  As revealed in the investigation, during that time Management of Change Reviews, Pre-Startup Safety Reviews, and Process Hazard Analyses all failed to effectively identify and control the hazard.

In addition, the CSB found that Williams failed to develop a written procedure for activities performed on the day of the incident, nor did the company have a routine maintenance schedule to prevent the operational heat exchanger from needing to be shut down for cleaning.

Finally, the video describes CSB’s recommendations made to the Williams Geismar plant which  encourages similar companies to review and incorporate into their own facilities. These include:

– Conduct safety culture assessments that involve workforce participation, and communicate the results in reports that recommend specific actions to address safety culture weaknesses

– Develop a robust safety indicators tracking program that uses the data identified to drive continual safety improvement

– And perform comprehensive process safety program assessments to thoroughly evaluate the effectiveness of the facility’s process safety programs.

“Managers must implement and then monitor safety programs and encourage a strong culture of safety to protect workers and the environment,” Chairperson Vanessa Allen Sutherland said,

The CSB is an independent federal agency charged with investigating serious chemical accidents. CSB investigations examine all aspects of chemical accidents, including physical causes such as equipment failure as well as inadequacies in regulations, industry standards, and safety management systems.

The Board does not issue citations or fines but makes safety recommendations to companies, industry organizations, labor groups, and regulatory agencies such as OSHA and EPA. Please visit our website, http://www.csb.gov.

For more information, contact Communications Manager Hillary Cohen at public@csb.gov or by phone at 202.446.8095.

 

“Transforming EHS Performance Measurement Through Leading Indicators”

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The National Safety Council, Campbell Institute performed a survey and study called “Transforming EHS Performance Measurement Through Leading Indicators” The information for the report was obtained from EHS & Safety Managers from across the country.

The report is an excellent compilation of the survey and the findings are intriguing. You can download a copy of the report here: http://goo.gl/KYAIxi

“Does Your Facility Have An Effective Safety Culture? Is Safety Truly A Priority?

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One way to improve the effectiveness of your safety process is to change the way it is measured.

Measurement is an important part of any management process and forms the basis for continuous improvement. Measuring safety performance is no different and effectively doing so will compound the success of your improvement efforts.

Finding the perfect measure of safety is a difficult task. What you want is to measure both the bottom-line results of safety as well as how well your facility is doing at preventing accidents and incidents. To do this, you will use a combination of lagging and leading indicators of safety performance.

Lagging indicators of safety performance

What is a lagging indicator?

Lagging indicators measure a company’s incidents in the form of past accident statistics.

Examples include:

  • Injury frequency and severity
  • OSHA recordable injuries
  • Lost workdays
  • Worker’s compensation costs

Why use lagging indicators?

Lagging indicators are the traditional safety metrics used to indicate progress toward compliance with safety rules. These are the bottom-line numbers that evaluate the overall effectiveness of safety at your facility. They tell you how many people got hurt and how badly.

The drawbacks of lagging indicators.

The major drawback to only using lagging indicators of safety performance is that they tell you how many people got hurt and how badly, but not how well your company is doing at preventing incidents and accidents.

The reactionary nature of lagging indicators makes them a poor gauge of prevention. For example, when managers see a low injury rate, they may become complacent and put safety on the bottom of their to-do list, when in fact, there are numerous risk factors present in the workplace that will contribute to future injuries.

Leading indicators of safety performance

What is a leading indicator?

A leading indicator is a measure preceding or indicating a future event used to drive and measure activities carried out to prevent and control injury.

Examples include:

  • Safety training
  • Ergonomic opportunities identified and corrected
  • Reduction of MSD risk factors
  • Employee perception surveys
  • Safety audits

Why use leading indicators?

Leading indicators are focused on future safety performance and continuous improvement. These measures are proactive in nature and report what employees are doing on a regular basis to prevent injuries.

Best practices for using leading indicators

Companies dedicated to safety excellence are shifting their focus to using leading indicators to drive continuous improvement. Lagging indicators measure failure; leading indicators measure performance, and that’s what we’re after!

According to workplace safety thought leader Aubrey Daniels, leading indicators should:

  1. Allow you to see small improvements in performance
  2. Measure the positive: what people are doing versus failing to do
  3. Enable frequent feedback to all stakeholders
  4. Be credible to performers
  5. Be predictive
  6. Increase constructive problem solving around safety
  7. Make it clear what needs to be done to get better
  8. Track Impact versus Intention

While there is no perfect or “one size fits all” measure for safety, following these criteria will help you track impactful leading indicators.

How Caterpillar used leading indicators to create world-class safety

An article on EHS Today titled, “Caterpillar: Using Leading Indicators to Create World-Class Safety” recaps an interview with two Caterpillar executives who explained how they were able to successfully transition to a culture that utilizes leading indicators for safety.

According to the execs at Caterpillar, “… traditional metrics can help companies tell the score at the end of the game, but they don’t help employers understand the strengths and weaknesses of their safety efforts and cannot help managers predict future success.”

By utilizing a Safety Strategic Improvement Process (SIP) that emphasized leading indicators of safety, they saw an 85% reduction of injuries and $450 million in direct/indirect cost savings.

According to the article, the critical elements of the SIP included:

  • Enterprise-wide statement of safety culture.
  • Global process, tools and metrics.
  • Top-down leadership of and engagement with the process.
  • Clearly defined and linked roles and responsibilities.
  • Clearly defined accountability.
  • Consistent methods establishing targets and reporting performance.
  • Consistent criteria for prioritizing issues and aligning resources.
  • Recognition for positive behavior and performance.
Conclusion

To improve the safety performance of your facility, you should use a combination of leading and lagging indicators.

When using leading indicators, it’s important to make your metrics based on impact. For example, don’t just track the number and attendance of safety meetings and training sessions – measure the impact of the safety meeting by determining the number of people who met the key learning objectives of the meeting / training.

What metrics do you use to measure your facility’s safety performance? Do you use a combination of leading and lagging indicators?

“The “Vert Alert” Lanyard Attachment Warning System Saves Lives”

VertAlertSCA_full

The VertAlert verbally warns the lift operator if the safety harness lanyard has not been properly attached to the lift anchor point. The VertAlert will not allow the lift to proceed UP until it has verified this proper attachment.

It will also collect and store data on lift activity including safety violations and if any attempts were made by the operator to circumvent this safety system. See more information about this unique and excellent system at: http://millennialplatform.com/ or email Paul Baillergian at  paul@suncook-intl.com 

“RMP Changes Are Almost Here, Stay A Step Ahead”

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By Timothy P Fagan, Senior Legal Editor

It has been 3 years since the ammonium nitrate explosion in West, Texas, killed 15 people, injured hundreds, and caused widespread damage.  Just a few months after that event, President Obama’s Executive Order (EO) 13650 set into motion actions by numerous government agencies designed to enhance the safety and security of chemical facilities and reduce the risks that hazardous chemicals pose to owners and operators, workers, and communities.

In addition to enhancing cooperation and information sharing among federal agencies and state and local authorities, the activities stemming from EO 13650 included modernizing key regulations, such as U.S. Environmental Protection Agency’s (EPA) Risk Management Program (RMP) and OSHA’s Process Safety Management (PSM) Program.  To that end, the EPA recently proposed amendments to RMP regulations under 40 CFR 68, and the Occupational Safety and Health Administration (OSHA) has made policy changes with respect to PSM that will impact how facilities comply with the RMP.

What changes are coming?

The changes to RMP regulations being proposed by the EPA impact the implementation of release prevention programs, the development of emergency response plans, and the sharing of information.

Release prevention programs.  The proposed changes to the accidental release prevention programs include:

  • Requiring all facilities with Program Level 2 or 3 processes to conduct root cause analyses as part of any incident investigation of a catastrophic release or a “near miss.” Identifying the root cause rather than the immediate cause will be more beneficial in preventing similar accidents in the future.
  • Requiring all facilities with Program Level 2 or 3 processes to hire an independent third party to perform a compliance audit after the facility has a reportable release.  Currently, such audits are self-audits, so requiring a third party increases the objectivity of the audit.
  • Requiring facilities in the paper manufacturing, petroleum and coal products manufacturing, and chemical manufacturing sectors with Program 3 processes to conduct a safer technology and alternatives analysis (STAA) as part of the process hazard analysis that must be updated every 5 years.  The facilities must then evaluate the feasibility of any inherently safer technology (IST) identified in the STAA.   The implementation of IST potentially reduces the risk of accidental releases within these industries, which the EPA has identified as having a disproportionate share of reportable releases.

Emergency response plans.  The proposed changes to emergency response plans include:

  • Requiring all facilities with Program Level 2 or 3 processes to coordinate with the local emergency response agencies at least once a year to ensure that resources and capabilities are in place to respond to an accidental release and to ensure that emergency contact information is up to date.  Effective coordination and communication between facilities and emergency responders can reduce the severity of accidental chemical releases.
  • Requiring all facilities with Program Level 2 or 3 processes that have developed their own emergency response plan to conduct a full field exercise at least once every 5 years and one tabletop exercise annually in the other years.   In addition, such facilities that have a reportable accident would be required to conduct a full field exercise within 1 year of the accident.  Such exercises will help ensure that all emergency response personnel understand their roles and responsibilities and be better prepared in the event of a real accident.

Access to information.  The proposed changes to accessing RMP information include:

  • Requiring RMP facilities to provide certain basic information to the public through easily accessible means such as a facility website.  If no website exists, the owner or operator may provide the information at public libraries or government offices or use other means appropriate for particular locations and facilities.
  • Requiring RMP facilities to hold a public meeting after an RMP reportable accident.
  • Requiring certain facilities to provide, on request, local emergency response agencies with summaries of audits, emergency response exercises, investigation reports, and implemented ISTs.
The surprising omission

After the issuance of EO 13650, there was significant speculation that the modernization of RMP regulations would involve additions to the listed chemicals regulated under 40 CFR 68 and a reevaluation of the thresholds at which chemicals became subject to the RMP.  However, the EPA opted not to regulate any additional chemicals under the RMP, nor did the agency change any of the thresholds as part of the recently released proposed regulations.

OSHA’s impact on RMP

Any RMP process that is subject to OSHA’s PSM must comply with Program Level 3 requirements, the most stringent requirements.  Last year OSHA revised its interpretation of the PSM standard’s retail facility exemption, which will result in thousands of facilities no longer being exempt from PSM.  Most of these facilities are already subject to the RMP under Program Level 2, but the change in the exemption interpretation will result in these facilities becoming Program Level 3 facilities.  OSHA will begin enforcing the new exemption interpretation on September 30, 2016, and the EPA will require risk management plan updates within the following 6 months.

What happens next?

For several years there has been speculation about what changes would be made to RMP regulations and how facilities would be impacted.  Now the proposed regulations are here, and facilities must begin the evaluation process.  Facilities must evaluate the proposed regulations and provide comments to the EPA, if necessary, and facilities must evaluate their own programs, procedures, and plans to determine what changes must be implemented to ensure continued compliance with a changing RMP.

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