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PT Notes

Executive Order Status Report - Enhancing Federal Operational Coordination

PT Notes is a series of topical technical notes provided periodically by Primatech for your benefit. Please feel free to provide feedback.

Executive Order 13650, Improving Chemical Facility Safety and Security, was issued on August 1, 2013 owing to continued catastrophic chemical facility incidents. The Executive Order has the objective of enhancing the safety and security of chemical facilities and reducing risks associated with hazardous chemicals to owners and operators, workers, and communities. A Working Group was appointed to oversee work on the Executive Order.

The Working Group published a status report on June 6, 2014. An analysis of the current operating environment, existing regulatory programs, and stakeholder feedback resulted in immediate actions and a plan for future actions to further minimize risks, organized by five thematic areas:

• Strengthening Community Planning and Preparedness
• Enhancing Federal Operational Coordination
• Improving Data Management
• Modernizing Policies and Regulations
• Incorporating Stakeholder Feedback and Developing Best Practices

This PTNote addresses Enhancing Federal Operational Coordination. Several issues were identified:

• Stakeholders believe stronger collaboration within the Federal community for various chemical facility regulatory program requirements and information collection efforts is a crucial component of success.

• Many stakeholders also want close collaboration between State regulatory programs and other holders of key planning and prevention information.

• State and industry partners believe that enhanced regulatory coordination and outreach across the chemical community would facilitate compliance and address potentially noncompliant facilities.

• First responders, LEPCs, and community residents believe that information and data-sharing efforts need significant improvement. Specifically, they want to be able easily to obtain the most actionable information in a user-friendly format to support planning efforts yet with a recognition of the need to find the right balance for this access with the need to protect information due to safety and security considerations.

The Working Group took a number of actions to address these issues, including:

• Initiating a pilot program in the New York-New Jersey area bringing together regional Federal employees and State and local agencies to serve as a test-bed, confirming lessons learned, collecting and assessing best practices, informing other initiatives directed by the executive order, and developing novel solutions to address safety and security challenges.

• Engaging with the Chemical Safety Board (CSB) to identify possible updates to existing memorandums of understanding between CSB and the EPA, CSB and OSHA, and CSB and the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).

The Working Group identified three priority action areas to help enhance operational coordination, to include:

• Coordinating implementation activities for the executive order.

• Establishing standard operating procedures for Federal coordination at the National and regional levels.

• Cross training Federal chemical facility safety and security field personnel to provide awareness of related regulatory programs.

The Working Group report is available at: https://www.osha.gov/chemicalexecutiveorder/

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