ILTA, Industry Coalition Comment on CSB Reporting Rule

January 14, 2020

ILTA 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.

The 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.

CSB% Reporting Industry Coalition Comments-Docket.pdf