OSHA, EPA and Other Stakeholder Responses to the Conclusions and Recommendations of the Chemical Safety Board’s Report on “Improving Reactive Hazard Management” and Some Approaches Towards Resolving Remaining Recommendation Issues

The USA Chemical Safety and Hazard Investigation Board (CSB) conducted a study of the chemical safety risks posed by the class of reactive hazards. This report, “IMPROVING REACTIVE HAZARD MANAGEMENT” (Report), was issued in October 2002 and its conclusions and recommendations have had significant impacts on how stakeholders view the adequacy of industry and government management of reactive hazards. The continued stream of high profile accidents due to reactive hazards such as Concept Sciences and Toulouse) cause people to also remember that realization of a reactive hazard also led to the accidents at Bhopal and Seveso and consequent major legal and social impacts in India, the United States and Europe. After a discussion of the congruence between the Report’s Objectives and Conclusions and the major thrusts of the Reactive Report’s ‘Recommendations’, to government agencies and other stakeholders, the paper will provide an update on the positive impacts that the CSB Report has already had on activities by professional societies, government and industry and examine some of the major unresolved recommendations, particularly those directed to OSHA to broaden PSM regulatory coverage of reactive chemicals. The paper will conclude with observations on various approaches to broadening coverage of reactive hazards along the lines recommended by the CSB to OSHA and EPA. Among the approaches reviewed will be the one embodied in New Jersey’s very recently modified TCPA regulation, selected proposals in the literature, and voluntary guidelines such as those under development by the newly formed Reactive Management Roundtable group of AIChE.