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.
2011-5-CS-TX-2
Develop good practice guidance that identifies and describes methodologies to assess and control hazards that can be used successfully in a research laboratory. Status: Closed - Exceeds Recommended Action
Develop good practice guidance that identifies and describes methodologies to assess and control hazards that can be used successfully in a research laboratory.
2011-5-CS-TX-1
Broadly and explicitly communicate to the target audience of research laboratories the findings and recommendations of the CSB Texas Tech report focusing on the message that while the intent of 29 CFR 1910.1450 (Occupational Exposure to Hazardous Chemicals in Laboratories Standard) is to comprehensively address health hazards of chemicals, organizations also need to effectively implement programs and procedures to control physical hazards of chemicals (as defined in 1910.1450(b)). At a minimum: a. Develop a Safety and Health Information Bulletin (SHIB) pertaining to the need to control physical hazards of chemicals; and b. Disseminate the SHIB (and any related products) on the OSHA Safety and Health Topics website pertaining to Laboratories (http://www.osha.gov/SLTC/laboratories/index.html) Status: Closed - Acceptable Action
Broadly and explicitly communicate to the target audience of research laboratories the findings and recommendations of the CSB Texas Tech report focusing on the message that while the intent of 29 CFR 1910.1450 (Occupational Exposure to Hazardous Chemicals in Laboratories Standard) is to comprehensively address health hazards of chemicals, organizations also need to effectively implement programs and procedures to control physical hazards of chemicals (as defined in 1910.1450(b)). At a minimum:
2011-5-CS-TX-3
Revise and expand the university chemical hygiene plan (CHP) to ensure that physical safety hazards are addressed and controlled, and develop a verification program that ensures that the safety provisions of the CHP are communicated, followed, and enforced at all levels within the university. Status: Closed - Acceptable Action
Revise and expand the university chemical hygiene plan (CHP) to ensure that physical safety hazards are addressed and controlled, and develop a verification program that ensures that the safety provisions of the CHP are communicated, followed, and enforced at all levels within the university.
2011-5-CS-TX-4
Develop and implement an incident and near-miss reporting system that can be used as an educational resource for researchers, a basis for continuous safety system improvement, and a metric for the university to assess its safety progress. Ensure that the reporting system has a single point of authority with the responsibility of ensuring that remedial actions are implemented in a timely manner. Status: Closed - Acceptable Action
Develop and implement an incident and near-miss reporting system that can be used as an educational resource for researchers, a basis for continuous safety system improvement, and a metric for the university to assess its safety progress. Ensure that the reporting system has a single point of authority with the responsibility of ensuring that remedial actions are implemented in a timely manner.
2009-03-I-TX-7
Communicate the findings of this report to your membership. Status: Closed - Acceptable Action
Communicate the findings of this report to your membership.
2002-03-I-TX-4
Adopt a fire code, such as the NFPA Uniform Fire Code or the ICC International Fire Code, for application in unincorporated areas. Status: Closed - Acceptable Action
Adopt a fire code, such as the NFPA Uniform Fire Code or the ICC International Fire Code, for application in unincorporated areas.
2002-03-I-TX-6
2002-03-I-TX-10
2002-03-I-TX-3
Revise the International Fire Code to address the following issues: For facilities that are not staffed around the clock, specify circumstances where automatic fire detection is needed. Narrow exemptions for Class IIIB liquids. Expand fire protection analysis requirements to include all areas of a facility where there may be flammable or combustible fire risks. Status: Closed - Unacceptable Action/No Response Received
Revise the International Fire Code to address the following issues: For facilities that are not staffed around the clock, specify circumstances where automatic fire detection is needed. Narrow exemptions for Class IIIB liquids. Expand fire protection analysis requirements to include all areas of a facility where there may be flammable or combustible fire risks.
2002-03-I-TX-8
2002-03-I-TX-9
Communicate the findings of this report to your membership. Status: Closed - No Longer Applicable
2002-03-I-TX-12
2002-03-I-TX-2
Revise NFPA 30, the Flammable and Combustible Liquids Code, to address the following issues For facilities that are not staffed around the clock, specify circumstances where automatic fire detection is needed. Narrow exemptions for Class IIIB liquids. Expand fire protection analysis requirements to include all areas of a facility where there may be flammable or combustible fire risks. Status: Closed - Acceptable Alternative Action
Revise NFPA 30, the Flammable and Combustible Liquids Code, to address the following issues For facilities that are not staffed around the clock, specify circumstances where automatic fire detection is needed. Narrow exemptions for Class IIIB liquids. Expand fire protection analysis requirements to include all areas of a facility where there may be flammable or combustible fire risks.
2002-03-I-TX-11
2002-03-I-TX-5
2002-03-I-TX-13
2002-03-I-TX-1
Audit the Third Coast Terminals facility in Pearland, Texas, in light of the findings of this report. Take action to ensure that the facility's fire suppression and control procedures meet the relevant requirements of NFPA 30 and OSHA 1910.106. Status: Closed - Unacceptable Action/No Response Received
Audit the Third Coast Terminals facility in Pearland, Texas, in light of the findings of this report. Take action to ensure that the facility's fire suppression and control procedures meet the relevant requirements of NFPA 30 and OSHA 1910.106.
1999-014-I-CA-5
1999-014-I-CA-1
Conduct periodic safety audits of your oil refinery facilities in light of the findings of this report. At a minimum, ensure that: Audits assess the following: - Safe conduct of hazardous nonroutine maintenance - Management oversight and accountability for safety - Management of change program - Corrosion control program. Audits are documented in a written report that contains findings and recommendations and is shared with the workforce at the facility. Audit recommendations are tracked and implemented. Status: Closed - Acceptable Action
Conduct periodic safety audits of your oil refinery facilities in light of the findings of this report. At a minimum, ensure that: Audits assess the following: - Safe conduct of hazardous nonroutine maintenance - Management oversight and accountability for safety - Management of change program - Corrosion control program. Audits are documented in a written report that contains findings and recommendations and is shared with the workforce at the facility. Audit recommendations are tracked and implemented.
1999-014-I-CA-2
Implement a program to ensure the safe conduct of hazardous nonroutine maintenance. At a minimum, require that: A written hazard evaluation is performed by a multidisciplinary team and, where feasible, conducted during the job planning process prior to the day of job execution. Work authorizations for jobs with higher levels of hazards receive higher levels of management review, approval, and oversight. A written decision-making protocol is used to determine when it is necessary to shut down a process unit to safely conduct repairs. Management and safety personnel are present at the job site at a frequency sufficient to ensure the safe conduct of work. Procedures and permits identify the specific hazards present and specify a course of action to be taken if safety requirements such as controlling ignition sources, draining flammables, and verifying isolation are not met. The program is periodically audited, generates written findings and recommendations, and implements corrective actions. Status: Closed - Acceptable Action
Implement a program to ensure the safe conduct of hazardous nonroutine maintenance. At a minimum, require that: A written hazard evaluation is performed by a multidisciplinary team and, where feasible, conducted during the job planning process prior to the day of job execution. Work authorizations for jobs with higher levels of hazards receive higher levels of management review, approval, and oversight. A written decision-making protocol is used to determine when it is necessary to shut down a process unit to safely conduct repairs. Management and safety personnel are present at the job site at a frequency sufficient to ensure the safe conduct of work. Procedures and permits identify the specific hazards present and specify a course of action to be taken if safety requirements such as controlling ignition sources, draining flammables, and verifying isolation are not met. The program is periodically audited, generates written findings and recommendations, and implements corrective actions.
1999-014-I-CA-3
Ensure that MOC reviews are conducted for changes in operating conditions, such as altering feedstock composition, increasing process unit throughput, or prolonged diversion of process flow through manual bypass valves. Status: Closed - Acceptable Action
Ensure that MOC reviews are conducted for changes in operating conditions, such as altering feedstock composition, increasing process unit throughput, or prolonged diversion of process flow through manual bypass valves.
1999-014-I-CA-4
Ensure that your corrosion management program effectively controls corrosion rates prior to the loss of containment or plugging of process equipment, which may affect safety. Status: Closed - Acceptable Action
Ensure that your corrosion management program effectively controls corrosion rates prior to the loss of containment or plugging of process equipment, which may affect safety.
2024-01-I-TN-4
Include physical, protective barriers as part of the standard design for liquid nitriding processes. These protective barriers shall be intended to isolate employees from molten salt releases. Status: Open - Acceptable Response or Alternate Response
Include physical, protective barriers as part of the standard design for liquid nitriding processes. These protective barriers shall be intended to isolate employees from molten salt releases.
2024-01-I-TN-5
Develop a safety management system that incorporates industry guidance and includes, but is not limited to: a. A hazard analysis program for assessing the nitriding process. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety, the National Fire Protection Association’s (NFPA) Standard for Ovens and Furnaces, and ASM International’s Handbook. The program shall apply to new and existing parts, assess parts for accumulation hazards and sealed cavities, and include non-routine tasks such as reprocessing unsatisfactory parts. b. Written operating procedures for the nitriding process. The procedures shall be based on the information gathered from the hazard analysis program. The procedures shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Writing Effective Operating and Maintenance Procedures. c. A training program, including written materials, for the employees involved in the nitriding process. This program shall be based on the nitriding facility’s operating procedures and other relevant information from the hazard analysis program. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety. d. An incident investigation program. This program shall include requirements for performing causal analysis, producing written reports, and communicating findings and corrective actions throughout the entire HEF Groupe organization. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Investigating Process Safety Incidents. Status: Open - Acceptable Response or Alternate Response
Develop a safety management system that incorporates industry guidance and includes, but is not limited to:
a. A hazard analysis program for assessing the nitriding process. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety, the National Fire Protection Association’s (NFPA) Standard for Ovens and Furnaces, and ASM International’s Handbook. The program shall apply to new and existing parts, assess parts for accumulation hazards and sealed cavities, and include non-routine tasks such as reprocessing unsatisfactory parts.
b. Written operating procedures for the nitriding process. The procedures shall be based on the information gathered from the hazard analysis program. The procedures shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Writing Effective Operating and Maintenance Procedures.
c. A training program, including written materials, for the employees involved in the nitriding process. This program shall be based on the nitriding facility’s operating procedures and other relevant information from the hazard analysis program. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety.
d. An incident investigation program. This program shall include requirements for performing causal analysis, producing written reports, and communicating findings and corrective actions throughout the entire HEF Groupe organization. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Investigating Process Safety Incidents.
2024-01-I-TN-6
Develop and implement an effective and comprehensive Knowledge Management program for sharing knowledge throughout the HEF Groupe organization. Knowledge shall include all information from audits, hazard analyses, and incident investigations, including causal analyses and corrective actions recommended and taken. This program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Process Safety Knowledge Management. Status: Open - Acceptable Response or Alternate Response
Develop and implement an effective and comprehensive Knowledge Management program for sharing knowledge throughout the HEF Groupe organization. Knowledge shall include all information from audits, hazard analyses, and incident investigations, including causal analyses and corrective actions recommended and taken. This program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Process Safety Knowledge Management.
2024-01-I-TN-7
Develop and implement a comprehensive and effective Corporate Governance program. This program shall include regular audits of subordinate facilities throughout the organization, with tracking and accountability for implementation of all recommendations and corrective actions identified in the audits. Facility adherence to the safety management system recommended above shall be evaluated during the audits. The program shall require documentation of audit findings, prompt responses to deficiencies, development of corrective actions, and implementation of the corrective actions throughout the organization. This program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Implementing Process Safety Management. Status: Open - Acceptable Response or Alternate Response
Develop and implement a comprehensive and effective Corporate Governance program. This program shall include regular audits of subordinate facilities throughout the organization, with tracking and accountability for implementation of all recommendations and corrective actions identified in the audits. Facility adherence to the safety management system recommended above shall be evaluated during the audits. The program shall require documentation of audit findings, prompt responses to deficiencies, development of corrective actions, and implementation of the corrective actions throughout the organization. This program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Implementing Process Safety Management.
2024-01-I-TN-1
Implement physical, protective barriers around the molten salt baths that isolate employees from hazardous releases at all locations that perform liquid nitriding. Status: Open - Acceptable Response or Alternate Response
Implement physical, protective barriers around the molten salt baths that isolate employees from hazardous releases at all locations that perform liquid nitriding.
2024-01-I-TN-2
Develop a safety management system that incorporates industry guidance and includes, but is not limited to: a. A hazard analysis program for assessing the nitriding process. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety, the National Fire Protection Association’s (NFPA) Standard for Ovens and Furnaces, and ASM International’s Handbook. The program shall apply to new and existing parts, assess parts for accumulation hazards and sealed cavities, and include non-routine tasks such as reprocessing unsatisfactory parts. b. Written operating procedures for the nitriding process. The procedures shall be based on the information gathered from the hazard analysis program. The procedures shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Writing Effective Operating and Maintenance Procedures. c. A training program, including written materials, for the employees involved in the nitriding process. This program shall be based on the nitriding facility’s operating procedures and other relevant information from the hazard analysis program. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety. d. An incident investigation program. This program shall include requirements for performing causal analysis, producing written reports, and communicating findings and corrective actions throughout the entire TS USA organization. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Investigating Process Safety Incidents. Status: Open - Acceptable Response or Alternate Response
d. An incident investigation program. This program shall include requirements for performing causal analysis, producing written reports, and communicating findings and corrective actions throughout the entire TS USA organization. The program shall incorporate industry guidance, such as the Center for Chemical Process Safety’s (CCPS) Guidelines for Risk-Based Process Safety and the CCPS’s Guidelines for Investigating Process Safety Incidents.
2024-01-I-TN-3
For each TS USA facility, establish a position with specific professional expertise and experience in safety management systems, such as risk-based process safety. This position shall be responsible for TS USA’s safety management system, ensuring that HEF Groupe’s safety information is incorporated at the site level, and implementing regulatory and industry safety guidance. Status: Closed - Acceptable Action
For each TS USA facility, establish a position with specific professional expertise and experience in safety management systems, such as risk-based process safety. This position shall be responsible for TS USA’s safety management system, ensuring that HEF Groupe’s safety information is incorporated at the site level, and implementing regulatory and industry safety guidance.
2009-05-I-LA-5
1998-05-I-LA-6
1998-05-I-LA-3
Conduct a study concerning the appropriateness and feasibility of odorizing nitrogen in order to warn personnel of the presence of nitrogen when it is used in confined spaces. Status: Closed - Acceptable Action
Conduct a study concerning the appropriateness and feasibility of odorizing nitrogen in order to warn personnel of the presence of nitrogen when it is used in confined spaces.
1998-05-I-LA-4
Issue a safety alert that addresses the hazards and provides safety guidelines for the use of temporary enclosures that are erected around equipment containing hazardous substances. Status: Closed - Acceptable Action
Issue a safety alert that addresses the hazards and provides safety guidelines for the use of temporary enclosures that are erected around equipment containing hazardous substances.
1998-05-I-LA-1
Post signs containing the warning "Danger, Confined Space: Do Not Enter Without Authorization" or similar wording at potential entryways when tanks, vessels, pipes, or other similar chemical industry equipment are opened. When nitrogen is added to a confined space, post an additional sign that warns personnel of the potential nitrogen hazard. Status: Closed - Acceptable Action
Post signs containing the warning "Danger, Confined Space: Do Not Enter Without Authorization" or similar wording at potential entryways when tanks, vessels, pipes, or other similar chemical industry equipment are opened. When nitrogen is added to a confined space, post an additional sign that warns personnel of the potential nitrogen hazard.
1998-05-I-LA-2
Ensure that the plant safety program addresses the control of hazards created by erecting temporary enclosures around equipment that may trap a dangerous atmosphere in the enclosure if the equipment leaks or vents hazardous material. Status: Closed - Acceptable Action
Ensure that the plant safety program addresses the control of hazards created by erecting temporary enclosures around equipment that may trap a dangerous atmosphere in the enclosure if the equipment leaks or vents hazardous material.
2006-8-I-IL-1
Amend 1910.106 Flammable and Combustible Liquids to require facilities that handle flammable and combustible liquids to implement the requirements of 1910.38 Emergency Action Plans. Status: Closed - Reconsidered/Superseded
Amend 1910.106 Flammable and Combustible Liquids to require facilities that handle flammable and combustible liquids to implement the requirements of 1910.38 Emergency Action Plans.
2006-8-I-IL-2
Amend 1910.38 Emergency Action Plans to require employers to conduct practice evacuation drills at least annually, but more frequently if necessary to ensure employees are prepared for emergencies. Status: Closed - Reconsidered/Superseded
Amend 1910.38 Emergency Action Plans to require employers to conduct practice evacuation drills at least annually, but more frequently if necessary to ensure employees are prepared for emergencies.