Back in February, I broke down the Chemical Safety Board’s new Chemical Incident Reporting Rule (40 CFR Part 1604) and since then we have conducted quite a few safety reviews, emergency response training sessions, and PSM/RMP audits and so far we have not found a single facility that has updated their Emergency Response and/or Emergency Action plans by adding the CSB to their “reporting procedures” as they have for reporting releases that exceed the Reportable Quantities. This new reporting requirement should have actually triggered…