Key Takeaways from the Inaugural
Process Safety Summit in Washington, DC
The Inaugural Process Safety Summit in Washington, DC on October 23, 2018 was a huge success. The event allowed the more than 160 safety and legal representatives from the petroleum refining, chemical manufacturing, paper manufacturing, and fertilizer industries to hear from and share with senior federal government officials from OSHA, EPA and the Chemical Safety Board, both through interactive panel discussions and breakout roundtable discussions. The agency panels and facilitated discussions covered topics ranging from enforcement under the Trump Administration, to the status of OSHA’s PSM and RMP Rulemakings, candid debates about major issues in dispute in recent PSM and RMP case, and practical discussions about how to prepare for the next round of inspections under OSHA’s new PSM National Emphasis Program and how to comply with RMP in the wake of the new Amendments and the imminent Rescission Rule.
- the importance of candid discussions between regulators and the regulated community; and
- the near-term risk of agencies working to upend the historical performance-oriented paradigm of the process safety regulatory framework.
Too often, OSHA and EPA representatives complain that Industry “can make up the rules as it goes along.” – Tweet from David Michaels, Former Assistant Secretary of Labor for OSHA.
Statements like that imply a haphazard approach to process safety that it is not reflected by the diligent work of refiners and manufacturers across the country. Our experience shows a much different take on process safety. We hear about all of the ways that process safety is evolving, much more often on Industry’s own initiative than in response to a regulatory action. We watch how lessons are being learned and applied from incidents and experience. We see how much time is spent trying to anticipate the kinds of issues that could cause a process safety incident. And we feel a regulatory backlash, when process safety problems are most often found in outliers or with operations not even covered by OSHA’s or EPA’s process safety regulations.
More importantly, remarks about Industry making up the rules as it goes along also reflect a flawed belief by regulators that Continue reading