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This page contains previous items from our Latest News feature.

CSB Recommends Improvements to the U.S. DOT Emergency Response Guidebook

Publish Date: 2014-10-08
Category: Industry News

October 8, 2014—The U.S. Chemical Safety Board (CSB) is recommending critical safety improvements to the widely-used Emergency Response Guidebook published by the U.S. Department of Transportation (DOT) for emergency responders to use when confronting chemical fires, explosions and releases of hazardous materials. The CSB noted that while the manual is provided for responders to use in transportation incidents, CSB investigators have found over the years that the guidebook is often used by emergency responders - firefighters, medical technicians and police officers - dealing with chemical accidents at fixed facilities. However, the CSB found some of the directions given in the manual are vague. The CSB document specifically cited guidebook changes needed for handling ammonium nitrate fires such as the one that led to a massive explosion at a fertilizer storage facility in West, Texas last year.

Further details can be found at www.csb.gov.

CSB Video Safety Message On Recommendations Program

Publish Date: 2014-10-08
Category: Industry News

October 8, 2014 – The U.S. Chemical Safety Board (CSB) today released a video safety message discussing the role that the CSB recommendations program plays in ensuring that the Board's accident investigations have a lasting impact on industrial safety. The safety message discusses the CSB's process for following up on the over 700 safety recommendations that have been issued and achieving the agency's nearly 70% rate of acceptably closed recommendations.

The CSB is now creating a list of "Most Wanted" safety improvements which will result in increased advocacy measures. In 2013, the Board voted to designate the development of an OSHA combustible dust standard as the agency's first Most Wanted Safety Improvement.

The video can be viewed or downloaded at:


Chemical Reaction Hazards

Publish Date: 2014-08-19
Category: Industry News

In August, 2014, the U.K. Health and Safety Executive reissued publication INDG254, Chemical Reaction Hazards and the Risk of Thermal Runaway. It identifies the main hazards of carrying out chemical reactions, provides guidance on how to ensure a safe operation, and identifies some sources of further information and advice.

A free copy can be downloaded at:


Primatech's Dr. Paul Baybutt authors three articles in the September, 2014 issue of Process Safety Progress

Publish Date: 2014-08-13
Category: Primatech News

The following articles by Dr. Paul Baybutt were published in Volume 33, Issue 3 of Process Safety Progress:

Initiating events, levels of causality, and process hazard analysis


Process hazard analysis (PHA) is used to identify hazard scenarios for a process and determine if the risk from the scenarios is tolerable. Each scenario begins with an initiating event that is made up of one or more causes. These causes must be recorded in sufficient detail to allow the PHA team to determine the particulars of the scenarios and develop any needed risk reduction measures. There is a hierarchy of causality wherein there are immediate, basic, underlying, and root causes of events. A suitable level of causality must be used in PHA. This article describes the hierarchy, recommends the level that should be used in PHA, and provides guidelines for the information that should be recorded in a PHA worksheet for different types of causes.

Addressing enablers in layers of protection analysis


Layers of protection analysis (LOPA) is used to evaluate the risk of individual hazard scenarios by combining initiating event frequencies with failure probabilities of protection layers. Some practitioners include events and conditions that enable the occurrence of hazard scenarios in the analysis, such as conditional modifiers, but sometimes they are excluded to ensure conservative results. However, these events and conditions, and other factors that enable scenarios, are often key parts of hazard scenarios and their exclusion from the analysis can result in overly conservative results. This paper broadens the definition of enabling events and conditions to include other factors that can have a significant impact on the risk of hazard scenarios. Such other factors include management systems to account for inadequacies in, and failure to follow, policies, procedures and work instructions; at-risk factors to account for the time period in which a process is at risk; incident outcomes to represent different possible consequences for the same initiating event; and release conditions to account for different release conditions or circumstances. Their inclusion in LOPA studies is described with examples. The determination of adjustment factors to account for their effect on scenario risk is also demonstrated.

Allocation of risk tolerance criteria


Risk analysis evaluates the risk of individual hazard scenarios and hazardous events that contribute to the overall risk of a hazardous facility. Therefore, some practitioners employ risk tolerance criteria for hazard scenarios or hazardous events by allocating or apportioning overall facility risk to the scenarios or events. Issues encountered in allocating facility risk tolerance criteria are discussed in this article, including estimating the number of scenarios or events to which a person may be exposed, introducing uncertainty into risk tolerance criteria, and defining scenarios or events uniquely and equivalently. Recommendations are made for using risk tolerance criteria appropriately.

Consultation on the Offshore Safety Directive

Publish Date: 2014-08-05
Category: Industry News

The UK Health and Safety Executive (HSE) has issued a consultation document, CD272, seeking views on the implementation of Directive 2013/30/EU on the safety of offshore oil and gas operations and amending Directive 2004/35/EC, and on the review of offshore Approved Codes of Practice and the updating of UK onshore oil and gas safety legislation to cover emerging energy technologies.

The consultation document seeks views on the UK's proposed approach to implementing the Offshore Safety Directive, and includes proposals on amendments to existing legislation, new requirements, new administrative procedures, and the establishment of an offshore competent authority. It also seeks views on HSE's proposals to update onshore oil and gas health and safety legislation to take account of emerging energy technologies and the review of two Approved Codes of Practice: Prevention of Fire and Explosion, and Emergency Response on Offshore Installations (PFEER); and Health Care and First Aid on Offshore Installations and Pipeline Works.

The consultation began on July 28, 2014 and will end on September 21, 2014.

Further information and the consultation document are available at: http://www.hse.gov.uk/consult/condocs/cd272.htm?ebul=hsegen&cr=4/04-aug-14

EPA RFI Published in the Federal Register

Publish Date: 2014-07-31
Category: Industry News

A Request For Information (RFI) from the Environmental Protection Agency (EPA) requesting comment on potential revisions to its Risk Management Program regulations and related programs was published in the Federal Register on 07/31/2014.

EPA is asking for information and data on specific regulatory elements and process safety management approaches, the public and environmental health and safety risks they address, and the costs and burdens they may entail. EPA will use the information received in response to the RFI to inform what action, if any, it may take.

There is a 90-day comment period that ends on 10/29/2014.

Primatech is issuing a series of PT Notes relating to various aspects of EPA's RFI. An archive of PT Notes is available by clicking here.

The RFI can be accessed by clicking here.

Copyright © 2014, Primatech Inc. All rights reserved.

EPA Seeks Comments on Potential Revisions to its Risk Management Program

Publish Date: 2014-07-24
Category: Industry News

On July 24, 2014, the U.S. Environmental Protection Agency (EPA) made available a pre-publication version of a Request for Information (RFI) seeking comments on potential revisions to its Risk Management Program (RMP) regulations and related programs to modernize its regulations as required under Executive Order (EO) 13650: Improving Chemical Facility Safety and Security. The EPA will use the information received in response to the RFI to inform what action, if any, it may take.

EPA's RFI closely coordinates with potential changes to the Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) program for accident prevention measures. OSHA issued an RFI on potential changes to its PSM standard on December 9, 2013. OSHA's RFI requested information on 17 potential policy and rulemaking topics relating to modernization of the PSM standard and other related OSHA standards.

Topics are divided into two categories in EPA's RFI: those addressed in parallel to OSHA's RFI, and additional topics not raised by OSHA.

Items in OSHA's RFI relevant to EPA's RMP regulation include:

  • Update the list of regulated substances
  • Additional risk management program elements
  • Define and require evaluation of updates to applicable recognized and generally accepted good engineering practices
  • Extend mechanical integrity requirements to cover any safety critical equipment
  • Require owners and operators to manage organizational changes
  • Require third party compliance audits
  • Effects of OSHA PSM coverage on RMP applicability

Additional items for which EPA is requesting information include:

  • Safer technology and alternatives analysis
  • Emergency drills to test a source's emergency response program or plan
  • Automated detection and monitoring for releases of regulated substances
  • Additional stationary source location requirements
  • Compliance with emergency response program requirements in coordination with local responders
  • Incident investigation and accident history requirements
  • Worst case release scenario quantity requirements for processes involving numerous small vessels stored together
  • Public disclosure of information to promote regulatory compliance and improve community understanding of chemical risks
  • Threshold quantities and off site consequence analysis endpoints for regulated substances based on acute exposure guideline level toxicity values
  • Program 3 NAICS codes based on RMP accident history data
  • The "safety case" regulatory model
  • Streamlining RMP requirements

Once EPA's RFI is published in the Federal Register, there will be a 90 day period for commenters to provide information and data on specific regulatory elements and process safety management approaches, the public and environmental health and safety risks they address, and the costs and burdens they may entail.

Primatech will be issuing a series of PTNotes elaborating on various aspects of EPA's RFI. For more information, click on these links:



Executive Order 13650, Report for the President, Actions to Improve Chemical Facility Safety and Security - A Shared Commitment

Report to the President: Actions to Improve Chemical Facility Safety and Security

Publish Date: 2014-06-12
Category: Industry News

A status report was released on June 6, 2014 by the Working Group set up to respond to the Executive Order (EO) 13650 issued on August 1, 2013 to address the improvement of the safety and security of chemical facilities and reduce the risks of hazardous chemicals to facility workers and operators, communities, and responders.

The report, Actions to Improve Chemical Facility Safety and Security – A Shared Commitment, summarizes the Working Group's progress, focusing on actions to date, findings and lessons learned, challenges, and short and long-term priority actions. It is available at:


CSB Video on Deepwater Horizon Blowout

Publish Date: 2014-06-09
Category: Industry News

On June 5, 2014, the U. S. Chemical Safety Board released a computer animation recreating the Deepwater Horizon blowout that occurred on April 20, 2010. The video depicts how high-pressure oil and gas from the Macondo well in the Gulf of Mexico caused an explosion on the drilling rig that killed 11 workers, seriously injured 17 other workers, triggered the largest oil spill in U.S. history, and destroyed the drilling rig.

The video illustrates how the Deepwater Horizon's blowout preventer failed to seal the well owing to buckling of the drill pipe caused by a mechanism known as effective compression. The video warns that this could make existing blowout preventer designs less effective in emergency situations.

The video can be viewed or downloaded at:


Primatech's Dr. Paul Baybutt authors paper on the use of risk matrices and risk graphs for SIL determination

Publish Date: 2014-06-09
Category: Primatech News

The paper was published in Process Safety Progress, Vol. 33, Issue 2, Pages 179–182, June 2014.


Risk matrices and risk graphs are used to determine safety integrity levels for safety instrumented functions. Their simplicity makes them appealing but various difficulties militate against their use for this purpose. These difficulties include the accommodation of hazardous events, allocation of risk tolerance criteria for calibration, and consideration of overall facility risk. Layers of protection analysis and other more quantitative methods are better able to handle these issues.