NACD Comments on OSHA's Request for Information on Process Safety Management
ARLINGTON, Va., April 1, 2014 /PRNewswire-USNewswire/ -- The National Association of Chemical Distributors (NACD) submitted comments yesterday in response to the Occupational Safety and Health Administration's (OSHA) Request for Information (RFI) on process safety management (PSM) and prevention of major chemical accidents regulations. Through the RFI, which is an initiative related to Executive Order 13650 – Improving Chemical Facility Safety and Security, OSHA proposed several options for expanding the scope of the PSM standard.
NACD urged a formal and thorough rulemaking process to determine whether changes should be made, stressing the significant impact such rule changes would have on small businesses.
The association highlighted that OSHA would need to follow the Small Business Regulatory Enforcement Fairness Act (SBREFA) and convene a Small Business Advocacy Review Panel to thoroughly assess the proposal's impact.
Among the changes, OSHA proposed expanding PSM coverage and the requirements for reactivity hazards. In its comments, NACD urged the agency to refrain from attempting to define or specifically cover chemical reactivity hazards in the PSM standard, stating, "Chemical reactivity involves too many factors and is too complex to be effectively defined…PSM already covers several substances that are highly reactive, and PSM-regulated facilities evaluate reactivity during Process Hazard Analyses."
The association also recommended that OSHA and other agencies partner with process safety experts and industry organizations to provide more education and resources on reactive hazards, including reinstituting an alliance among OSHA, the Environmental Protection Agency, universities, and major chemical industry trade organizations to improve information sharing on reactive hazards.
"Rather than making the PSM standard even more complex, NACD strongly recommends that OSHA focus its efforts on outreach, compliance assistance, and effective enforcement of the current standard. This would be the most effective way to bring facilities into compliance and prevent future accidents," wrote NACD Vice President of Regulatory Affairs Jennifer Gibson.
NACD's complete comments are available at: http://nacd.com/docs/regulatory/2014/NACD%20PSM%20Comments%203-31-14.pdf
NACD and its over 420 member companies are vital to the chemical supply chain providing products to over 750,000 end users. They make a delivery every eight seconds while maintaining a safety record that is more than twice as good as all manufacturing combined. NACD members are leaders in health, safety, security, and environmental performance through implementation of Responsible Distribution, established in 1991 as a condition of membership and a third-party verified management practice. For additional information on our members, their safety record or NACD, visit NACD at www.NACD.com.
Contact: Matthew McKinney
SOURCE National Association of Chemical Distributors (NACD)