The U.S. Chemical and Safety Hazard Investigation Board (CSB) recently released a Safety Spotlight recommending that employers closely apply industry consensus standards to safeguard employee and public safety. Titled “The Importance of Industry Safety Guidelines, Codes, and Standards,” the report highlights the CSB’s role in accident investigation and focuses on several safety codes and standards that were issued or updated following incidents investigated by the CSB.
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Like the National Transportation Safety Board (NTSB), CSB does not issue fines or citations. The board investigates explosions and other accidents at facilities to determine the root causes or safety management deficiencies that may have led to the accident. After concluding investigations, CSB makes recommendations to:
- Environmental Protection Agency (EPA),
- Industry groups,
- Labor unions,
- Occupational Safety and Health Administration (OSHA),
- Other regulatory agencies, and
- Plant owners and managers.
Standard Developing Organization Involvement
In addition to its investigation work, CSB makes recommendations to standard-developing organizations whenever it concludes there are safety gaps or deficiencies in an existing standard. For example, following its investigation of a series of combustible dust explosions, the board concluded the employer had strictly adhered to an existing standard despite experiencing the explosions.
The three combustible dust explosions took place over a six-month period at a facility in Gallatin, Tennessee, and included:
- An iron dust flash fire on January 31, 2011, that killed two workers;
- A second iron dust flash fire on March 21 that injured one employee; and
- A hydrogen explosion and resulting iron dust flash fire on May 27 that killed three and injured two other workers.
During the course of its investigation, CSB learned the city of Gallatin and state of Tennessee had adopted the International Fire Code (IFC), developed by the International Code Council (ICC) into law. IFC Chapter 13, Combustible Dust-Producing Operations, referred to the National Fire Protection Association’s (NFPA) standard NFPA 484 Combustible Metals, Metal Powders, and Metal Dusts; however, the IFC’s standard did not specify whether NFPA 484 compliance was voluntary or mandatory.
The CSB recommend the ICC revise the language in the IFC. The revised standard clearly states facility owners are responsible for complying with all the referenced standards.
Other Industrial Standards
The CSB found that worker fatigue contributed to a March 23, 2005, explosion at a BP refinery in Texas City, Texas. The board concluded there was no industry standard or safety guideline addressing fatigue as a risk factor. The CSB recommended the American Petroleum Institute (API) and United Steel Workers collaborate on developing a standard for managing fatigue and mitigating the associated risks at petrochemical facilities.
On April 2010, the API issued Recommended Practice (RP) 755 – Fatigue Risk Management Systems for Personnel in the Refining and Petrochemical Industries. The API then invited CSB staff to participate in the revision of the recommended practice. A second edition of RP 755 is slated for release this year.
Other standards have been revised or updated based on CSB recommendations, including:
- National Fuel Gas Code, NFPA 54/ANSI Z223.1 revisions, after a June 9, 2009, explosion at a ConAgra Foods SlimJim meat processing facility when natural gas was purged indoors from pipes connected to a newly installed water heater and a February 7, 2010, explosion at a Kleen Energy facility where workers forced natural gas through the piping at a high pressure and volume to clear debris; and
- American Chemical Society recommended practices for hazard evaluation in academic laboratories after a student at Texas Tech lost three fingers and experienced burns to the hands and face when the chemical he was working with detonated.
Standards Made More Useful for Employers
While employers must comply with federal occupational safety and health standards, adhering to industry consensus standards can help ensure safety and prevent accidents. Many consensus standards formed the basis of federal regulations, and some have been incorporated by reference in OSHA standards.
CSB’s work has contributed to the ongoing improvement of industry standards.