January 14, 2020
worked with an industry coalition to provide comments to Chemical Safety Board on its recent
reporting rule. The CSB Reporting Industry Coalition asked that CSB consider an alternative approach to what
they proposed that was included in the agency’s 2009 Advance Notice of Proposed
Rulemaking. That would allow CSB to continue to review media and NRC reports to
identify accidents they want to investigate and then request the facility
operators to report in greater detail on the incidents of interest. This would
avoid CSB collecting nearly 2,000 reports annually and rather look in depth at
a much smaller number of incidents each year.
comments specifically oppose the proposed definitions of a serious injury and
substantial property damage and the provision to double-report to both the
National Response Center and CSB when reporting. CSB has investigated more
than 130 incidents since its inception in 1998, which is equal to about six or seven investigations a year. In the past decade, the average number of investigations has slipped to four to six per year.
The full comments are attached below.