The CSB issues safety recommendations to prevent the recurrence or reduce the likelihood or consequences of similar incidents or hazards in the future. Recommendations are issued to a variety of parties, including government entities, safety organizations, trade unions, trade associations, corporations, emergency response organizations, educational institutions, and public interest groups. Recommendations are published in CSB reports and are closed only by vote of the Board. The CSB tracks all recommendations and communicates regularly with recommendations recipients to ensure that the recommended corrective actions are implemented. For more information, see Frequently Asked Questions about CSB recommendations.
2019-01-I-TX-6
Update API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities, or other appropriate products to include flammable gas detection systems within the leak detection section or where appropriate. The discussion of flammable gas and/or leak detection should address both engineering and administrative controls, including actions associated with responding to a catastrophic or emergency leak. Status: Open - Awaiting Response or Evaluation/Approval of Response
Update API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities, or other appropriate products to include flammable gas detection systems within the leak detection section or where appropriate. The discussion of flammable gas and/or leak detection should address both engineering and administrative controls, including actions associated with responding to a catastrophic or emergency leak.
2019-01-I-TX-8
Modify 40 C.F.R. §68.115(b)(2)(i) to expand coverage of the RMP rule to include all flammable liquids, including mixtures, with a flammability rating of NFPA-3 or higher. (Superseded 2010-02-I-PR-R1 from the Caribbean Petroleum (CAPECO) report) Status: Open - Awaiting Response or Evaluation/Approval of Response
Modify 40 C.F.R. §68.115(b)(2)(i) to expand coverage of the RMP rule to include all flammable liquids, including mixtures, with a flammability rating of NFPA-3 or higher.
(Superseded 2010-02-I-PR-R1 from the Caribbean Petroleum (CAPECO) report)
2019-01-I-TX-1
Develop and implement a process safety management system for the ITC Deer Park terminal applicable to all atmospheric storage tanks and associated equipment in highly hazardous chemical service.a The program should follow industry guidance provided in publications such as the American Petroleum Industry's API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities and the Center for Chemical Process Safety’s Guidelines for Risk Based Process Safety. Status: Open - Acceptable Response or Alternate Response
Develop and implement a process safety management system for the ITC Deer Park terminal applicable to all atmospheric storage tanks and associated equipment in highly hazardous chemical service.a The program should follow industry guidance provided in publications such as the American Petroleum Industry's API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities and the Center for Chemical Process Safety’s Guidelines for Risk Based Process Safety.
2019-01-I-TX-2
Develop and implement a condition monitoring program for all pumps in highly hazardous chemical service at the ITC Deer Park terminal. Ensure that condition monitoring equipment is programmed with control limits, including but not limited to vibration, consistent with ANSI/HI 9.6.9.-2018, that trigger alarms when control limits are exceeded, and that operating procedures and training reflect the appropriate actions to take when an alarm is triggered. Status: Open - Acceptable Response or Alternate Response
Develop and implement a condition monitoring program for all pumps in highly hazardous chemical service at the ITC Deer Park terminal. Ensure that condition monitoring equipment is programmed with control limits, including but not limited to vibration, consistent with ANSI/HI 9.6.9.-2018, that trigger alarms when control limits are exceeded, and that operating procedures and training reflect the appropriate actions to take when an alarm is triggered.
2019-01-I-TX-3
Install flammable gas detection systems with associated alarm functions in product storage and transfer areas at the ITC Deer Park terminal where flammable substance releases could occur. Develop and implement a response plan and operator training for actions to take when an alarm sounds. Status: Open - Acceptable Response or Alternate Response
Install flammable gas detection systems with associated alarm functions in product storage and transfer areas at the ITC Deer Park terminal where flammable substance releases could occur. Develop and implement a response plan and operator training for actions to take when an alarm sounds.
2019-01-I-TX-4
Install remotely operated emergency isolation valves configured to “Fail-Closed” for all atmospheric storage tanks that contain highly hazardous chemicals or liquids with a flammability rating of NFPA-3 or higher at the ITC Deer Park terminal. Status: Open - Acceptable Response or Alternate Response
Install remotely operated emergency isolation valves configured to “Fail-Closed” for all atmospheric storage tanks that contain highly hazardous chemicals or liquids with a flammability rating of NFPA-3 or higher at the ITC Deer Park terminal.
2019-01-I-TX-5
Conduct an evaluation of the design of all new and existing tank farms at the ITC Deer Park terminal against the applicable sections of the Third Edition of API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities and the 2021 Edition of NFPA 30, Flammable and Combustible Liquids Code. At a minimum the evaluation should include, but is not limited to the following sections of API STD 2610: Section 4 Site Selection and Spacing Requirements Section 7 Fire Prevention and Protection Section 8.1 Aboveground Petroleum Storage Tanks Section 9 Dikes and Berms Section 10 Pipe, Valves, Pumps, and Piping Systems Section 11 Loading, Unloading, and Product Transfer Facilities and the following chapters of NFPA 30: Chapter 21 Storage of Ignitible (Flammable or Combustible) Liquids in Tanks – Requirements for All Storage Tanks and Chapter 22 Storage of Ignitible (Flammable or Combustible) Liquids in Tanks – Aboveground Storage Tanks The evaluation should identify additional engineering controls needed to address minimal tank spacing, subdivisions between tanks, and placement of process equipment in containment areas. In addition, the evaluation should assess the adequacy of the containment wall and drainage system designs, accounting for the impact of firefighting activities, including the application of firewater and foam on these systems. Develop and implement recommendations based on findings from the evaluation. Status: Open - Acceptable Response or Alternate Response
Conduct an evaluation of the design of all new and existing tank farms at the ITC Deer Park terminal against the applicable sections of the Third Edition of API STD 2610, Design, Construction, Operation, Maintenance, and Inspection of Terminal and Tank Facilities and the 2021 Edition of NFPA 30, Flammable and Combustible Liquids Code. At a minimum the evaluation should include, but is not limited to the following sections of API STD 2610:
Section 4 Site Selection and Spacing Requirements Section 7 Fire Prevention and Protection Section 8.1 Aboveground Petroleum Storage Tanks Section 9 Dikes and Berms Section 10 Pipe, Valves, Pumps, and Piping Systems Section 11 Loading, Unloading, and Product Transfer Facilities
and the following chapters of NFPA 30:
Chapter 21 Storage of Ignitible (Flammable or Combustible) Liquids in Tanks – Requirements for All Storage Tanks and Chapter 22 Storage of Ignitible (Flammable or Combustible) Liquids in Tanks – Aboveground Storage Tanks
The evaluation should identify additional engineering controls needed to address minimal tank spacing, subdivisions between tanks, and placement of process equipment in containment areas. In addition, the evaluation should assess the adequacy of the containment wall and drainage system designs, accounting for the impact of firefighting activities, including the application of firewater and foam on these systems. Develop and implement recommendations based on findings from the evaluation.
2019-01-I-TX-7
Eliminate the atmospheric storage tank exemption from the PSM standard. (Superseded 2001-05-I-DE-R1 from the Motiva report and 2010-02-I-PR-R4 from the Caribbean Petroleum (CAPECO) report) Status: Open - Awaiting Response or Evaluation/Approval of Response
Eliminate the atmospheric storage tank exemption from the PSM standard.
(Superseded 2001-05-I-DE-R1 from the Motiva report and 2010-02-I-PR-R4 from the Caribbean Petroleum (CAPECO) report)
2009-02-I-NY-11
Communicate the findings of this report to your membership. Status: Closed - Acceptable Action
Communicate the findings of this report to your membership.
2002-02-I-NY-12
Communicate the findings of this report to your membership. Status: Closed - No Longer Applicable
2002-02-I-NY-6
Develop and implement a written hazard communication program that includes the following requirements: Maintaining a list of hazardous materials used in the workplace. Labeling of hazardous materials. Maintaining material safety data sheets and making them available to the workforce. Training of employees on chemical hazards and their safeguards in languages understood by the workforce. Status: Closed - Acceptable Action
Develop and implement a written hazard communication program that includes the following requirements: Maintaining a list of hazardous materials used in the workplace. Labeling of hazardous materials. Maintaining material safety data sheets and making them available to the workforce. Training of employees on chemical hazards and their safeguards in languages understood by the workforce.
2002-02-I-NY-7
Implement hazardous waste management practices that include the following: Characterization of unknown waste materials prior to mixing or disposal. Labeling of all waste containers with the words ?Hazardous Waste? and any other wording necessary to communicate the specific hazards associated with the material. Formal hazardous waste management training program. Status: Closed - Unacceptable Action/No Response Received
Implement hazardous waste management practices that include the following: Characterization of unknown waste materials prior to mixing or disposal. Labeling of all waste containers with the words ?Hazardous Waste? and any other wording necessary to communicate the specific hazards associated with the material. Formal hazardous waste management training program.
2002-02-I-NY-1
Revise the Fire Prevention Code, Title 27, Chapter 4, of the New York City Administrative Code, to achieve more comprehensive control over the storage and use of hazardous materials, such as nitric acid, that could cause a fire or explosion when inadvertently mixed with incompatible substances. Base these revisions on model fire codes such as the International Code Council International Fire Code and the National Fire Protection Association Fire Protection Code. Require that: All hazardous materials be identified and labeled. Hazardous materials permit applications include the submission of a management plan and inventory statement. Material safety data sheets be accessible to the workforce. Personnel working with hazardous materials be trained on hazards and safe handling techniques in languages understood by the workforce. Incompatible chemicals be adequately separated to improve safety in manufacturing facilities. New York City fire inspectors receive sufficient training to meet the requisite skills and knowledge to verify code compliance and recognize problems regarding the storage, handling, and use of hazardous materials. Include in the training: Hazard communication requirements. Identification of hazardous materials storage and use areas. Safe storage and handling practices, such as the need to separate incompatible chemicals and to limit quantities. Status: Closed - Acceptable Action
Revise the Fire Prevention Code, Title 27, Chapter 4, of the New York City Administrative Code, to achieve more comprehensive control over the storage and use of hazardous materials, such as nitric acid, that could cause a fire or explosion when inadvertently mixed with incompatible substances. Base these revisions on model fire codes such as the International Code Council International Fire Code and the National Fire Protection Association Fire Protection Code. Require that: All hazardous materials be identified and labeled. Hazardous materials permit applications include the submission of a management plan and inventory statement. Material safety data sheets be accessible to the workforce. Personnel working with hazardous materials be trained on hazards and safe handling techniques in languages understood by the workforce. Incompatible chemicals be adequately separated to improve safety in manufacturing facilities. New York City fire inspectors receive sufficient training to meet the requisite skills and knowledge to verify code compliance and recognize problems regarding the storage, handling, and use of hazardous materials. Include in the training: Hazard communication requirements. Identification of hazardous materials storage and use areas. Safe storage and handling practices, such as the need to separate incompatible chemicals and to limit quantities.
2002-02-I-NY-2
Amend the New York City Administrative Code § 27-4267 to require that: The owner or other person having charge of a mixed occupancy building with a hazardous occupancy be required to develop a building hazardous materials safety plan and designate a responsible individual to ensure that the plan is implemented. The building hazardous materials safety plan incorporate information from the hazardous materials management plans, inventory statements, right-to-know facility inventory forms, and Fire Prevention Code permits of any tenants who use hazardous materials. The building hazardous materials safety plan be distributed to all tenants. Status: Closed - Acceptable Action
Amend the New York City Administrative Code § 27-4267 to require that: The owner or other person having charge of a mixed occupancy building with a hazardous occupancy be required to develop a building hazardous materials safety plan and designate a responsible individual to ensure that the plan is implemented. The building hazardous materials safety plan incorporate information from the hazardous materials management plans, inventory statements, right-to-know facility inventory forms, and Fire Prevention Code permits of any tenants who use hazardous materials. The building hazardous materials safety plan be distributed to all tenants.
2002-02-I-NY-3
Ensure that the New York City Fire Department (FDNY) and the Department of Environmental Protection (NYCDEP) establish a program to exchange facility information regarding hazardous chemical inventories to enhance inspection and enforcement activities. Status: Closed - Acceptable Action
Ensure that the New York City Fire Department (FDNY) and the Department of Environmental Protection (NYCDEP) establish a program to exchange facility information regarding hazardous chemical inventories to enhance inspection and enforcement activities.
2002-02-I-NY-14
2002-02-I-NY-15
2002-02-I-NY-17
2002-02-I-NY-13
2002-02-I-NY-10
Establish a complaint and referral system with the Occupational Safety and Health Administration (OSHA; Region II) to provide for a coordinated enforcement effort that addresses the following issues: Policy and practice for referring to OSHA possible health and safety violations or unsafe conditions observed by FDNY personnel in the course of conducting inspections, but outside the scope of FDNY responsibility. Periodic training programs for FDNY personnel on how to recognize and refer serious workplace safety and health problems. Status: Closed - Acceptable Action
Establish a complaint and referral system with the Occupational Safety and Health Administration (OSHA; Region II) to provide for a coordinated enforcement effort that addresses the following issues: Policy and practice for referring to OSHA possible health and safety violations or unsafe conditions observed by FDNY personnel in the course of conducting inspections, but outside the scope of FDNY responsibility. Periodic training programs for FDNY personnel on how to recognize and refer serious workplace safety and health problems.
2002-02-I-NY-16
2002-02-I-NY-4
Raise the priority of inspections of large quantity generators located in mixed-occupancy facilities within densely populated areas. Status: Closed - Acceptable Action
Raise the priority of inspections of large quantity generators located in mixed-occupancy facilities within densely populated areas.
2009-02-I-NY-5
Share data, such as the Resource Conservation and Recovery Act (RCRA) biennial report, with the New York City Fire Department (FDNY) and Department of Environmental Protection (NYCDEP) concerning the identity, location, and hazardous waste inventories of large quantity generators within the City to enhance inspection and enforcement activities. Status: Closed - Acceptable Action
Share data, such as the Resource Conservation and Recovery Act (RCRA) biennial report, with the New York City Fire Department (FDNY) and Department of Environmental Protection (NYCDEP) concerning the identity, location, and hazardous waste inventories of large quantity generators within the City to enhance inspection and enforcement activities.
2002-02-I-NY-8
Disseminate information on the requirements of the Hazard Communication Standard, 29 CFR 1910.1200, in the major languages spoken by workers in New York City with limited or no English speaking proficiency. Status: Closed - Acceptable Action
Disseminate information on the requirements of the Hazard Communication Standard, 29 CFR 1910.1200, in the major languages spoken by workers in New York City with limited or no English speaking proficiency.
2002-02-I-NY-9
Establish a complaint and referral system with the New York City Fire Department (FDNY) to provide for a coordinated enforcement effort that addresses the following issues: Policy and practice for referring to OSHA possible health and safety violations or unsafe conditions observed by FDNY personnel in the course of conducting inspections, but outside the scope of FDNY responsibility. Periodic training programs for FDNY personnel on how to recognize and refer serious workplace safety and health problems. Status: Closed - Acceptable Action
Establish a complaint and referral system with the New York City Fire Department (FDNY) to provide for a coordinated enforcement effort that addresses the following issues: Policy and practice for referring to OSHA possible health and safety violations or unsafe conditions observed by FDNY personnel in the course of conducting inspections, but outside the scope of FDNY responsibility. Periodic training programs for FDNY personnel on how to recognize and refer serious workplace safety and health problems.
2002-02-I-NY-18
2002-02-I-NY-19
2010-07-I-CT-3 URGENT!
Make appropriate changes to the 2012 version of Power Piping, ASME B31.1, to require the use of inherently safer fuel gas piping cleaning methodologies rather than natural gas blows. At a minimum, for the cleaning or flushing methods discussed in B31.1 paragraph 122.10, require the use of inherently safer alternatives such as air blows and pigging with air as the motive force in lieu of flammable gas. Status: Closed - Acceptable Action
Make appropriate changes to the 2012 version of Power Piping, ASME B31.1, to require the use of inherently safer fuel gas piping cleaning methodologies rather than natural gas blows. At a minimum, for the cleaning or flushing methods discussed in B31.1 paragraph 122.10, require the use of inherently safer alternatives such as air blows and pigging with air as the motive force in lieu of flammable gas.
2010-07-I-CT-18 URGENT!
Work with the six turbine manufacturers identified in this document – General Electric, Siemens, Solar, Mitsubishi Power Systems, Pratt & Whitney, and Rolls-Royce – to publish technical guidance addressing the safe cleaning of fuel gas piping supplying gas turbines. At minimum: a. For cleaning methodology, require the use of inherently safer alternatives such as air blows and pigging with air in lieu of flammable gas. b. Provide comprehensive technical guidance on inherently safer methods for cleaning fuel gas piping, such as the use of air or pigging with air. Status: Closed - Acceptable Action
Work with the six turbine manufacturers identified in this document – General Electric, Siemens, Solar, Mitsubishi Power Systems, Pratt & Whitney, and Rolls-Royce – to publish technical guidance addressing the safe cleaning of fuel gas piping supplying gas turbines. At minimum: a. For cleaning methodology, require the use of inherently safer alternatives such as air blows and pigging with air in lieu of flammable gas. b. Provide comprehensive technical guidance on inherently safer methods for cleaning fuel gas piping, such as the use of air or pigging with air.
2010-07-I-CT-4 URGENT!
Provide to your customers: a. Comprehensive technical guidance on inherently safer methods for cleaning fuel gas piping, such as the use of air or pigging with air. b. Comprehensive Cleaning Force Ratio (CFR) guidelines, specifying both the upper and lower limits required to obtain satisfactory cleaning for the fuel gas piping for purposes of the warranties of the turbines. c. Warnings against the use of fuel gas to clean pipes. Status: Closed - Acceptable Action
Provide to your customers: a. Comprehensive technical guidance on inherently safer methods for cleaning fuel gas piping, such as the use of air or pigging with air. b. Comprehensive Cleaning Force Ratio (CFR) guidelines, specifying both the upper and lower limits required to obtain satisfactory cleaning for the fuel gas piping for purposes of the warranties of the turbines. c. Warnings against the use of fuel gas to clean pipes.
2010-07-I-CT-10 URGENT!
Work with the Electric Power Research Institute to publish technical guidance addressing the safe cleaning of fuel gas piping supplying gas turbines. At minimum: a. For cleaning methodology, require the use of inherently safer alternatives such as air blows and pigging with air in lieu of flammable gas. b. Provide technical guidance for the safe and effective use of alternative methods for cleaning such as air and pigging with air. Status: Closed - Acceptable Action
Work with the Electric Power Research Institute to publish technical guidance addressing the safe cleaning of fuel gas piping supplying gas turbines. At minimum: a. For cleaning methodology, require the use of inherently safer alternatives such as air blows and pigging with air in lieu of flammable gas. b. Provide technical guidance for the safe and effective use of alternative methods for cleaning such as air and pigging with air.
2010-07-I-CT-16 URGENT!
Enact legislation applicable to power plants in the state that prohibits the use of flammable gas that is released to the atmosphere to clean fuel gas piping. Status: Closed - Acceptable Action
Enact legislation applicable to power plants in the state that prohibits the use of flammable gas that is released to the atmosphere to clean fuel gas piping.
2010-07-I-CT-17 URGENT!
Adopt the current version of NFPA 54 as amended pursuant to 2010-01-I-CT-R2. Status: Closed - No Longer Applicable
Adopt the current version of NFPA 54 as amended pursuant to 2010-01-I-CT-R2.
2010-07-I-CT-7 URGENT!
2010-07-I-CT-13 URGENT!
2010-07-I-CT-2 URGENT!
Enact a Tentative Interim Amendment and permanent changes to the National Fuel Gas Code (NFPA 54/ANSI Z223.1) that address the safe conduct of fuel gas piping cleaning operations. At a minimum: a. Remove the existing NFPA 54 fuel gas piping exemptions for power plants and systems with an operating pressure of 125 pounds per square inch gauge (psig) or more. b. For cleaning methodology, require the use of inherently safer alternatives such as air blows or pigging with air in lieu of flammable gas. Status: Closed - Exceeds Recommended Action
Enact a Tentative Interim Amendment and permanent changes to the National Fuel Gas Code (NFPA 54/ANSI Z223.1) that address the safe conduct of fuel gas piping cleaning operations. At a minimum: a. Remove the existing NFPA 54 fuel gas piping exemptions for power plants and systems with an operating pressure of 125 pounds per square inch gauge (psig) or more. b. For cleaning methodology, require the use of inherently safer alternatives such as air blows or pigging with air in lieu of flammable gas.
2010-07-I-CT-1 URGENT!
Promulgate regulations that address fuel gas safety for both construction and general industry. At a minimum: a. Prohibit the release of flammable gas to the atmosphere for the purpose of cleaning fuel gas piping. b. Prohibit flammable gas venting or purging indoors. Prohibit venting or purging outdoors where fuel gas may form a flammable atmosphere in the vicinity of workers and/or ignition sources. c. Prohibit any work activity in areas where the concentration of flammable gas exceeds a fixed low percentage of the lower explosive limit (LEL) determined by appropriate combustible gas monitoring. d. Require that companies develop flammable gas safety procedures and training that involves contractors, workers, and their representatives in decision-making. Status: Closed - Unacceptable Action/No Response Received
Promulgate regulations that address fuel gas safety for both construction and general industry. At a minimum: a. Prohibit the release of flammable gas to the atmosphere for the purpose of cleaning fuel gas piping. b. Prohibit flammable gas venting or purging indoors. Prohibit venting or purging outdoors where fuel gas may form a flammable atmosphere in the vicinity of workers and/or ignition sources. c. Prohibit any work activity in areas where the concentration of flammable gas exceeds a fixed low percentage of the lower explosive limit (LEL) determined by appropriate combustible gas monitoring. d. Require that companies develop flammable gas safety procedures and training that involves contractors, workers, and their representatives in decision-making.
2010-07-I-CT-8 URGENT!
2010-07-I-CT-14 URGENT!
2010-07-I-CT-9 URGENT!
2010-07-I-CT-15 URGENT!
2010-07-I-CT-5 URGENT!
2010-07-I-CT-12 URGENT!
2010-07-I-CT-6 URGENT!
2010-07-I-CT-11 URGENT!