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ASSE Questions CSB Approach to Chemical Release Reporting

Commenting on the Chemical Safety Board’s chemical release reporting rulemaking, ASSE is urging the CSB to adopt an approach that would avoid adding one more chemical incident reporting requirement, when CSB is already effective in obtaining timely chemical incident information.

ASSE says layers of chemical incident reporting requirements already exist, and expressed concern that the incident reporting comes at a time when a site supervision team is working to mitigate the impact of an emergency. ASSE is responding to an advanced notice of a proposed rulemaking that seeks input on possible approaches to a regulation on chemical release reporting.

The Clean Air Act requires the CSB to establish a regulation requiring accidental chemical releases be reported to the CSB or to the National Response Center. Also, a 2004 Inspector General report recommended CSB implement the regulation.

“The CSB needs to refine its mechanism for learning of chemical incidents, and it should publish a regulation describing how the CSB will receive the notifications it needs,” according to “A Report on the Continuing Development of the U.S. Chemical Safety and Hazard Investigation Board.”

With this advance notice of proposed rulemaking, the CSB seeks comments on how best to proceed with implementing this requirement, and says it will use this information in the development of a proposed and then final rule.

In the letter, ASSE President C. Christopher Patton, CSP, noted, “While supportive of CSB’s intent to be thorough in learning all it can about chemical incidents in furtherance of its mission, our members on the front line of managing safety and health report that industry is already reporting sufficient information to regulatory authorities.

“As the advanced notice of proposed rulemaking itself recognizes, chemical incidents are already required to be reported through the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the Emergency Planning and Community Right-to-Know Act (EPCRA), the Occupational Safety and Health Act (OSH), the Clean Water Act, the Clean Air Act, and the Toxic Substances Control Act (TSCA). Additionally, industry is required to report to various state and local agencies.”

Fulfilling these reporting requirements comes at a time when a facility’s supervision team is in the midst of managing an emergency, making immediate notifications to local emergency responders, making calls for assistance to off-shift employees and contractors for help in responding to the emergency and otherwise taking immediate actions to ensure the safety and health of employees and the community.

ASSE is concerned that adding another reporting requirement solely for the purpose of informing the CSB of an event would only add unnecessary burden and distraction to a supervision team working to mitigate the impact of an emergency.

“For these reasons, ASSE supports the third approach outlined by CSB in the proposed rulemaking, which would have the CSB rely primarily on existing sources for initially learning of chemical incidents, but would follow up on a subset of the incidents to gather additional information through a questionnaire or on-line form that the reporting party would be required by the rule to complete and submit to the CSB,” Patton noted. “ASSE and its members will work with the CSB to help ensure that this rulemaking is effective and continues CSB’s established record of helping industry better protect workers through the lessons learned from its investigations.”

ISO Addresses Safety for Gas Turbine Applications

A new ISO standard addresses the major safety considerations to be taken into account when designing, packaging and installing gas turbine applications.

ISO 21789:2009, Gas turbine applications – Safety, covers the safety requirements when using liquid or gaseous fuels, as well as the safety-related control and detection systems and essential auxiliaries for all types of open-cycle gas turbines used in onshore and offshore applications, including floating production platforms.

The standard addresses the risks of injury or death to humans and risks to the environment. In this respect, it details the anticipated significant hazards associated with gas turbines and specifies the appropriate preventative measures and processes for reducing or eliminating them.

“The prime motivation for developing this standard was an identified need to facilitate a common industry approach towards the application of safety methodology and its integration into best practice,” said Roger Santon, convenor of the ISO working group that developed ISO 21789. “International standardization in this area gives both manufacturer and purchaser a clear set of globally accepted requirements against which to assess the risks associated with each gas turbine installation, and ensures a single point of reference for all stakeholders.”

In addition to covering the relevant safety requirements, ISO 21789:2009 will also assist designers, manufacturers and others by providing methods of compliance with the relevant, essential safety requirements of key European Directives for gas turbine applications related to machinery, ATEX and pressure equipment.

Moreover, and as far as practical, ISO 21789 also provides methods for compliance with the relevant, essential safety requirements of related European legislation concerned with the workplace, electromagnetic compatibility, pollution prevention, environmental noise, classification, packaging and labeling of dangerous substances, among others.

The ISO says the standard’s focus on European legislation does not prejudice its application outside the European Union.

Insource Safety Acquired by Top Exec, Advocates Group

Insource Safety Associates, an environmental, health and safety services provider, has been acquired by The Advocates Group, Salt Lake City, and its top executive, who led the company to 500 percent growth over the last four years.

James E. Eaton, who has been serving as president and general manager of Insource North Carolina, Inc. and its operating units, has been named CEO.

“Now Insource is strategically positioned for accelerated expansion and we feel it is fitting at this point for Jim (and the new ownership group) to acquire the firm,” said Chad Hoggan, speaking for the outgoing group of owners. “We have achieved our objectives as the original owners of Insource, and Jim can continue his dedicated efforts to build the firm, not as an employee, but as an owner.”

Insource is a professional services firm headquartered in Charlotte, NC that provides comprehensive on-site services in support of the Environmental Health and Safety programs of clients nationwide, as well as focused Transformative Culture (behavioral-based) initiatives and specialized HR strategies.

The company was formed in 1998 and has remained a privately-held corporation. Eaton became president of the firm in 2005.

“We take this opportunity to express our gratitude to the clients of Insource for many years of loyalty,” said Hoggan. “Some of them have been with us from the very beginning and have become good friends.

Further we are confident that services provided by the firm will continue to be of the utmost quality and professionalism.”

Under Eaton’s leadership, Insource grew 500 percent over a four-year period, said Hoggan. “We’ve enjoyed healthy growth, and it would be nice to say that it was because of a ‘brilliant business plan’ that we developed and implemented. That’s not the case,” said Eaton.

“We’ve grown, expanded capabilities, and even improved processes, primarily as a result of the influence of our larger clients.

“We felt that our approach was unique and even powerful: ‘We will provide the same highly-focused, high quality support to your facilities wherever they might be…coordinated, consistent, costeffective.’

This message has been well-received and afforded us the opportunity to establish extended term relationships with major corporations and organizations. But our plan also included building our base of small to mid-size clients in primary markets. We have not gotten this done,” said Eaton.

Expect Insource to continue seeking to partner with large, multi-facility companies as it increases “emphasis on supporting clients in dealing with the emerging pressures from government and world political influences, such as being ‘green,’ crisis and incident management, and advanced security concerns.

 

 

   

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