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John L. Henshaw
Center for Chemical Process Safety
18th Annual International Conference
Scottsdale, Arizona
September 23, 2003
- Good morning. Thanks Pete and Scott. Glad to be with you this morning to discuss OSHA's thinking on addressing reactive chemical process safety.
Safety and Health Add Value
- My overall message to workers and employers this year has been very simple: Safety and health add value. To your business. To your workplace. To your life.
- We want every employer and employee in the Nation to build a safety culture at their workplace. The first step is recognizing the value of a safe, healthful work environment.
- The value for business is clear: focusing on safety and health is the right thing to do. It saves money and adds value to the organization. Workplace injuries and illnesses are costly. According to Liberty Mutual Group, U.S. businesses pay $155 billion to $232 billion on workers' compensation losses annually.
- Safety and health also add value to the workplace. Benefits include greater productivity, higher quality, increased morale and reduced turnover.
- Clearly, safety and health add value to life. For workers, getting hurt or sick is not just physically painful. It can reduce income, increase stress and hinder a full family life.
- OSHA has set challenging goals for the next five years:
- Reduce rate of fatalities by 15%
- Reduce rate of injuries/illnesses by 20%
Problems with Reactives
- To do that we need to address many concerns. One of them, as you know, is handling reactive chemicals.
- Chemical manufacturing represents a vital interest for our country. According to the American Chemistry Council, it's a $450 billion enterprise employing more than one million workers. The chemical industry accounts for one-tenth of the dollar value of our nation's exports. And, of course, chemicals are important to many other industries in the U.S. as well.
- All of us share the same goal -- preventing injuries, illnesses and deaths on the job. We need to work together to accomplish this goal.
- Unwanted chemical reactions and resulting incidents pose a serious problem. No one needs to be reminded of the tragedies that have occurred in recent years involving reactives.
- Our goal, our commitment is to work with CCPS and others to prevent these incidents in the future. And, with input from many stakeholders -- through the June Reactive Chemical Roundtable and in other ways -- we have developed a multi-faceted strategy designed to help employers avoid problems.
- As you know, following several investigations, the U.S. Chemical Safety and Hazard Investigation Board sent OSHA a series of formal recommendations on addressing reactive chemicals. OSHA will soon issue a formal response to the CSB outlining our plan for helping employers reduce injuries and deaths involving reactive chemicals.
OSHA's Strategy
- I want to share that plan with you today. First, I want you to know that OSHA's strategy emphasizes a collegial, cooperative approach. We talked with employers and employees, with EPA, and with interested stakeholders such as CCPS, the ACC and SOCMA. OSHA's plan begins with outreach and information -- but it also includes enforcement.
- We all know dealing with reactive chemicals is not an easy issue. There are a multiplicity of views and approaches.
- It was apparent at the June Roundtable that we have yet to reach consensus on how to tackle this issue. Serious differences clearly remain as to what is the best way to anticipate potential problems and deal with them before they get out of control.
- At the same time, we need to move forward. Even though we may prefer different approaches, we cannot simply stand still while waiting for consensus to develop. We need to settle on a course and encourage employers and their workers to adopt safe work practices for handling reactive chemicals.
- As you know, OSHA's Process Safety Management Standard takes a holistic approach -- integrating technologies, procedures and management practices. It focuses on a list of highly hazardous chemicals, as directed by the Clean Air Act Amendments of 1990.
- We believe the current standard provides a basis for addressing most problems that occur as part of chemical processes. Changing the PSM standard is not on OSHA's regulatory agenda at this time. However, we are aware of the proposals to modify the standard and we are still considering them.
CCPS' Reactives Book
- At the same time, we are convinced that employers can benefit immediately from additional information and guidance -- especially those with little experience and limited resources. And we are prepared to assist those who use reactive chemicals in several ways.
- First, we are making final arrangements to make available on our website the new CCPS book on chemical reactivity -- Essential Practices for Managing Chemical Reactivity Hazards. As you know, this book is a compendium of best practices, drawn from leaders in chemical processing and reviewed by experts.
- OSHA will make this book available on the agency's website on a new page devoted specifically to reactive chemical hazards. Any employer, any worker -- actually anyone who visits our website -- can download information from the book -- FREE -- for the next three years.
- This is not the first time OSHA has relied on CCPS's expertise -- and I'm sure it won't be the last. We have a number of references to CCPS materials in our PSM appendix.
- I know that this book will be a vital resource for employers who need more guidance in managing reactive chemicals. That includes people who design, manage, operate or support facilities that store, handle or process materials that pose chemical reactivity hazards.
- The CCPS book is user friendly and it covers all the bases -- how to identify reactive hazards and how to manage them in different industries -- from chemical production to warehousing. This reference offers very practical information to help employers understand situations that can contribute to uncontrolled reactions-and what to do about them!
- I believe the "preliminary screening tool" is especially helpful. This is a diagnostic tool that helps employers determine whether they have chemical reactive hazards in their workplace. Beyond that, the book includes sample reactive programs and information on real reactive incidents.
- We hope to make the book available very shortly -- within the next several weeks. If you haven't taken a look at it, I hope you will -- and recommend it to others as well.
OSHA Guidance
- We're also developing an OSHA guidance document on reactives, which will complement the CCPS reference. Our goal is to make this material available on our website by next spring.
- The agency's focus will be single, noncomplex processes. This will be helpful to employers who may have only one process. It will also be helpful to smaller employers with operations that generally involve simpler processes.
- I think it's especially important that OSHA's guidance will also be useful to employers beyond chemical manufacturing -- such as those involved in storage, repackaging, blending and formulating. We want to be sure these employers receive the guidance they need to handle processes that may be simple, yet pose risks for employees.
- Our guidance will emphasize the importance of screening for reactive hazards. And it will encourage employers to seek out additional information as needed in the CCPS reference book.
- Also, OSHA is working on additional guidance on hazard communication, including Material Safety Data Sheets. We have been concerned about the accuracy of MSDSs, and CSB has also stressed the importance of accurate hazard information. To help improve accuracy, OSHA is developing guidance and training documents, exploring possibility of alliances and considering Globally Harmonized System standardized format for MSDS.
- In addition, OSHA plans to revise our compliance directive for the Process Safety Management standard. There are a couple of issues that we know we need to clarify.
- One of them is better explaining the difference between storage tanks and process tanks. We want to make sure employers understand that any tank used for something other than storage only is considered a process tank. And process tanks are clearly covered under the PSM standard.
- There has been some confusion about this as a result of the Meer case. But OSHA will clarify the original intent of the standard -- which is that any tank that has a function other than storage exclusively -- such as mixing or settling -- is considered a process tank. And it is covered.
- We will clarify process safety information and process hazard analysis elements of PSM as well. This will address both items recommended by CSB in their reactives investigation and others that OSHA deems important.
- We've begun initial work on the directive, and we plan to complete the changes next year. Of course, the directive will also be available on OSHA's website -- on both the reactives and the PSM pages.
Outreach
- OSHA plans to participate in the Reactivity Management Roundtable. As you know, the purpose of the roundtable is to reduce the frequency and consequences of uncontrolled reactions that lead to accidents.
- The particular focus is companies with limited technical and financial resources. And the group's agenda meshes well with OSHA's strategy -- to cooperatively assimilate, implement, maintain and update best practices for managing chemical reactivity. We plan to participate in the October session of the Reactivity Management Roundtable when these efforts will be addressed.
- OSHA is also developing an Alliance with a number of groups in the chemical industry. We've specifically been working with EPA, SOCMA and ACC. We'd welcome AIChE also. And we've been talking with the National Association of Chemical Distributors. Others may want to participate as well.
- The goal of the Alliance would be to further educate employers and employees on best practices in handling reactive chemicals. And one of the vehicles will be the CCPS reactives book.
Enforcement
- In addition, to guidance and outreach, OSHA's strategy for reactives includes an enforcement component. We expect to rely on the general duty clause to address reactive hazards not covered by the PSM standards.
- The bottom line is that reactivity is an issue workplaces must address. Where employers have failed to take appropriate steps to prevent serious reactive hazards, we will issue citations.
Closing
- In summary, OSHA is fully committed to a comprehensive approach for addressing the hazards posed by reactive chemicals. We intend to focus on expanding the universe of information and guidance available to employers. We want to insure that information on best practices is widely known and easily available.
- We will work cooperatively with stakeholders through the Reactive Chemical Roundtable, Alliances and other groups. And, where appropriate, we will issue citations under the general duty clause.
- I believe this is a well-rounded strategy that will move us forward toward the results we are all looking for: fewer reactive chemical incidents and fewer worker injuries and deaths. I look forward to working with you toward this end.
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