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PT Notes

Executive Order Status Report Highlights - Guidance and Outreach to Help Industry Understand Requirements and Best Practices

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 developing guidance and outreach programs to help industry understand process safety and security requirements and best practices which are viewed by the Working Group as an integral part of a comprehensive approach to chemical facility safety and security. The Plan calls for these actions prior to the end of FY2016:

  • Develop and publish an EPA alert to help improve public safety at remote oil and gas storage facilities where unauthorized public access has resulted in a number of fatal incidents.
  • Develop an EPA and OSHA process safety terminology guidance.

Several agencies have similar safety system requirements but differences in terminology have created confusion among the regulated community. EPA and OSHA will collaborate and develop guidance for terminology in EPA and OSHA process safety regulations. This will identify where better harmonization is needed and assist the regulated community in ensuring their programs / actions meet requirements across all regulatory programs.

  • Develop a fact sheet on existing resources detailing how to conduct root cause analyses so the regulated community can better understand the causes of incidents and can increase its capability to effectively prevent future occurrences.

OSHA's PSM standard requires facilities to investigate incidents. However, the PSM standard does not specify the use of root cause analysis or the investigation of near-miss incidents. Without proper root cause analysis, lessons learned will fall short of their potential for preventing future occurrences.

  • Develop guidance for PSM at small businesses and storage facilities.
  • Consolidate best practices for process safety and metrics from OSHA Voluntary Protection Program (VPP) facilities.
  • Develop guidance for PSM at explosive facilities.

OSHA has discovered through its enforcement activities that differences in explosive manufacturing hazards require a unique approach to implementing PSM. Guidance will help to ensure effective implementation of a PSM program.

  • Develop best practice guidance for CFATS risk-based performance standards to increase stakeholder understanding and compliance with the CFATS regulation.
  • Develop a comprehensive regulatory fact sheet covering EPA, OSHA, and DHS programs for State regulators, facilities, stakeholders, and other non-Working Group Federal agencies that will describe the relevant Federal programs to increase their awareness of the programs.
  • Develop a checklist of Federal Regulations in coordination with industry associations that stakeholders can use to determine regulations applicable to their facilities.
  • Develop best practice guidance for implementing the framework for improving critical infrastructure cybersecurity at chemical facilities.

DHS will coordinate with industry to develop a voluntary guidance document for chemical facilities that increases awareness and use of the cybersecurity framework developed by the National Institute of Standards and Technology (NIST) to help critical infrastructure sectors and organizations reduce and manage their cyber risk.

  • Work with standards-setting organizations to expand information sharing and provide other actions to enhance the safety and security of chemical facilities.

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

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