ILTA, Industry Coalition Comment on CSB Reporting Rule
ILTA worked with an industry coalition to provide comments to the Chemical Safety Board (CSB) on its recent reporting rule. The CSB Reporting Industry Coalition asked that the CSB consider an alternative approach to what it proposed. The industry’s newest proposal, which was initially discussed in the agency’s 2009 Advance Notice of Proposed Rulemaking, would allow CSB to continue to review media and NRC reports to identify accidents it wants to investigate and then request that facility operators report in greater detail on the incidents of interest. Such a change would avoid the CSB collecting nearly 2,000 reports annually and allow investigators to look in depth at a much smaller number of incidents each year.
The comments specifically oppose the proposed definitions of both a serious injury and substantial property damage as well as the provision to double-report to both the National Response Center and the CSB when reporting. The 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. A link to the comments is available here.