Public Comments Submitted by the CSB

Click here to view comments submitted by the U.S. Chemical Safety and Hazard Investigation Board (CSB)  on July 17, 2024 in response to OSHA’s proposed rule titled Emergency Response, published in the Federal Register on February 5, 2024 (89 CFR 7774). 

Click here to view the  U.S. Chemical Safety and Hazard Investigation Board’s (CSB) comments in response to the Environmental Protection Agency’s (EPA) proposed rule titled, Revisions to Standards for the Open Burning/Open Detonation of Waste Explosives, published in the Federal Register on March 20, 2024.

Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) July 19, 2023, letter to Washington State Department of Labor and Industries

Click here to view The U.S. Chemical Safety and Hazard Investigation Board's (CSB) July 13, 2023, letter to The Federal Energy Regulatory Commission (FERC). 

Click here to view The U.S. Chemical Safety and Hazard Investigation Board's  (CSB's ) February 3, 2023, letter to  support the Environmental Protection Agency’s (EPA) National Enforcement and Compliance Initiative (NECI): Reducing Risks of Accidental Releases at Industrial and Chemical Facilities.  

Click here to view The U.S. Chemical Safety and Hazard Investigation Board’s (CSB) comments (December 29, 2022) on the National Fire Protection Association’s (NFPA) proposed consolidated Combustible Dust standard (NFPA 660: Standards for Combustible Dust).

Click here to view the U.S. Chemical Safety and Hazard Investigation Board’s (CSB) comments on the Occupational Safety and Health Administration’s (OSHA) September 20, 2022, Federal Register Notice (87 Fed. Reg. 57520) to address the agency’s Process Safety Management standard modernization rulemaking project (PSM STD Modernization). The comments address some new issues, as well as supplement our previous submission (CSB letter to OSHA Docket: OSHA-2013-0020 dated March 31, 2014) and applicable recommendations made by the CSB to OSHA and other recipients. November 9, 2022

Click here to view U.S. Chemical Safety and Hazard Investigation Board’s (CSB) comments on the Environmental Protection Agency’s (EPA’s) proposed rule, “Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention” (RMP rule) October 26, 2022.

Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on  the Environmental Protection Agency (EPA) Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act, Section 112(r)(7).  July 30, 2021.

Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB)  comments on the State of Washington Department of Labor and Industries (L&I) Division of Occupational Safety and Health (DOSH) proposed rulemaking to amend Chapter 296-67 WAC, Safety Standards for Process Safety Management of Highly Hazardous Chemicals.

Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the Environmental Protection Agency (EPA) Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act, Section 112(r)(7). July 20, 2018.

Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the State of Washington Department of Labor and Industries Division of Occupational Safety and Health proposed rulemaking in amend Chapter 296-67 WAC, Safety Standards for Process Safety Management of Highly Hazardous Chemicals. May 11, 2018.

Click here to view Public Comments by CSB Board Member Rick Engler before the California Department of Industrial Relations Occupational Safety and Health Standards Board on the Proposed Safety Order for Adoption: Process Safety Management for Petroleum Refineries -- Oakland, California, May 18, 2017.

Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the State of California Occupational Safety and Health Standards Board Notice of Proposed Rulemaking to adopt New Section §5189.1 Process Safety Management for Refineries. Sept. 2, 2016.

Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the Environmental Protection Agency (EPA) Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act, Section 112(r)(7). May 10, 2016.

Click here to view the U.S. Chemical Safety and Hazard Investigation Board’s (CSB) response State of California Department of Industrial Relations (DIR) Division of Occupational Safety and Health Proposed GISO §5189.1, Process Safety Management (PSM) for Petroleum Refineries. Oct. 7, 2015.

Click here to view The U.S. Chemical Safety Board’s (CSB) response to the Bureau of Safety and Environmental Enforcement’s (BSEE’s) April 17, 2015, Proposed Rule, “Oil and Gas and Sulphur Operations in the Other Continental Shelf – Blowout Preventer Systems and Well Control” July 16, 2015. 
 
Click here to view the U.S. Chemical Safety and Hazard Investigation Board's comments on the State of California Department of Industrial Relations (DIR) Division of Occupational Safety and Health Proposed GISO §5189.1 Version 4.5 – May 26, 2015, Process Safety Management (PSM) for Petroleum Refineries. June 22, 2015.
 
Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the joint Department of Defense / General Services Administration / National Aeronautics and Space Administration's "Federal Aquisition Regulations: Fair Pay and Safe Workplaces Proposed Rule" that was published in the Federal Register on May 28, 2015.  
 
Click here to access the U.S. Chemical Safety and Hazard Investigation Board's (CSB) response to the Environmental Protection Agency's (EPA's) July 31 , 2014 Request for Information (at 79 FR 44604) on potential revisions to its Risk Management Program regulations and related program. (Docket No. EPA-HQ-OEM-2014-0328; October 29, 2014).
 

Click here to access the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments to EPA’s proposed revision to require fence line monitoring at refineries and offers the following comments to strengthen the proposal and to make the information collected more accessible to the public. (Docket ID Number EPA-HQ-OAR-2010-0682;  October 28, 2014).

Click here to view the U.S. Chemical Safety and Hazard Investigation Board's (CSB) comments on the U.S. Department of Transportation’s notice, “Hazardous Materials: Revision of Emergency Response Guidebook” (FR Doc. 2014-20683). Oct. 3, 2014.

Click here to access the U.S. Chemical Safety and Hazard Investigation Board's response to OSHA's December 9, 2013 Request for Information (at 78 FR 73756) on potential revisions to several agency standards, including the Process Safety Management standard

 

Public Comments Submitted to the CSB
 
Click here to view public comments on the proposed rule that augments 40 CFR part 1600, which governs the administration of the Chemical Safety and Hazard Investigation Board. June 2015.
 

Click here to access public comments on the CSB's Draft Report, "Regulatory Report: Chevron Richmond Refinery Pipe Rupture (Report No. 2012-03-I-CA). December 2013.

Click here to access public comments on Comments on the Draft Evaluation of Response to the CSB's Fatigue Recommendation to API and USW. April 2013.

Click here to access public comments on National Academy of Sciences (NAS) Study: Inherently Safer Chemical Processes: The Use of Methyl Isocyanate at Bayer CropScience. April 2010.

Click here to access public comments on Advanced Notice of Proposed Rulemaking (ANPR) Chemical Release Reporting. August 2009.