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PT Notes

Executive Order Status Report Highlights - Promoting Safer Technology and Alternatives

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 Federal Action Plan for future actions to further minimize risks.

This PT Note highlights actions from the Plan relating to promoting safer technology and alternatives. EPA and OSHA have developed a plan to encourage chemical facilities to integrate safer technology and alternatives into a facility's process safety programs. The plan consists of three steps:

  • Issue an alert on safer technology and alternatives and work with industries to publicize examples of best practices.

EPA and OSHA believe that many chemical facility operators may not be aware of the safer technology and alternatives solutions available to reduce the overall risk from their facilities. EPA and OSHA will issue a joint alert illustrating the concepts, principles, and examples of safer technology and alternatives in order to make industry more aware of the need to consider this approach. The alert will provide:

    • Nonregulatory insights and suggestions.
    • Best practices for facility implementation.
    • References to existing scientific and engineering literature on the subject.
  • Develop voluntary guidance to make chemical operators aware of safer technology, processes, and alternative solutions to reduce the overall risk of their facilities.

To further raise awareness regarding existing inherent safety practices, EPA and OSHA will develop voluntary guidance for operators on how to reduce risks by employing safer technology, processes, and alternatives. The guidance will:

    • Serve as an advisory to the regulated community as to how EPA and OSHA view safer technology and alternatives.
    • Be based on feedback from the alert.
    • Offer a more thorough examination of alternative measures and safety techniques.
    • Include examples of safer technology and alternatives or practices.
    • Not impose any particular requirements on a facility that are not part of existing industry safety standards and best practices.
    • Not compel compliance with guidance or require consideration of findings in a PHA.
  • Based on experience with the alert, guidance, and public input, consider potential modification of RMP and/or PSM requirements to include specific safer alternatives analysis and documentation of actions taken to implement feasible alternatives.

This may include adding a mandatory risk-reduction analysis step to the PHA element already required in the standards. EPA or OSHA would not, however, determine specific technology, design, or process selection by chemical facility owners or operators.

EPA and OSHA are also considering other avenues available to reinforce and further spread the use of safer technology and alternatives in managing chemical risk throughout industry. Such options include a partnership with industry in order to encourage such approaches through existing stewardship programs, work with industry on a safer technology and alternatives / inherent safety clearinghouse, and recognition programs.

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

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