ARLINGTON, Va., April 1, 2014 /PRNewswire-USNewswire/ -- Yesterday, the National Association of Chemical Distributors (NACD) filed comments to the Chemical Facility Safety and Security Working Group in response to Executive Order 13650, Improving Chemical Facility Safety and Security, Section 6(a) – Solicitation of Public Input on Options for Policy, Regulation, and Standards Modernization. Section 6(a) tasks the working group with considering options to improve and modernize key policies, regulations, and standards to enhance the safety and security of chemical facilities.
In its comments, the association stressed that effective chemical safety and security regulations must be clear and consistent, and that government agencies must engage in both compliance assistance and regulatory enforcement.
Stated NACD Vice President of Regulatory Affairs Jennifer Gibson, "In order for facilities to achieve compliance, they must be able to clearly understand what steps they need to take to meet the requirements and what the agencies' expectations are. This is best achieved when the regulatory language is clear and the agencies develop helpful guidance documents. This facilitates implementation, promotes effective training of current and new employees, and leads to safer facilities."
The association also provided thorough comments on the various options proposed in the Section 6(a) document regarding OSHA's Process Safety Management, EPA's Risk Management Program, and DHS's Chemical Facility Anti-Terrorism Standards regulations; leveraging industry programs such as NACD's Responsible Distribution; and ways to identify facilities covered under existing process safety and security regulations. In the comments, NACD also expressed serious concerns about potential inherently safer technology mandates and the prospect of shifting to a "safety case" regulatory regime as recently proposed by the U.S. Chemical Safety Board.
NACD urged relevant regulatory agencies to conduct full rulemaking processes on any potential regulatory changes, including Advanced Notices of Proposed Rulemaking for each of these initiatives, to provide opportunity for careful consideration of hazard and cost-benefit analysis and adequate data and comment submission from interested parties.
To read NACD complete comments, visit: http://nacd.com/docs/regulatory/2014/NACD%20EO%20Section%206a%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)