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…
a MOC as these plans would need to be updated, as well as training for certain personnel.
As I stated in my previous posts, this reporting rule is quite different than CERCLA/EPCRA reporting rules. For example, the CSB’s reporting rule has a 4-hour window. But did you know…
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If the owner or operator has submitted a report to the National Response Center (NRC) pursuant to 40 CFR 302.6, the CSB reporting requirement may be satisfied by submitting the NRC identification number to the CSB within 30 minutes of submitting a report to the NRC.
If the owner or operator has NOT submitted a report to the NRC and notified the CSB under paragraph (b) of this section, the owner/operator must submit a report directly to the CSB within EIGHT HOURS of the accidental release and must include the required information listed in §1604.4. A report may be made by email to: [email protected], or by telephone at 202-261-7600. |
I believe that an MOC is in order to manage the change to the facility’s reporting procedures, as there is a lot more to understand about this NEW CSB reporting rule. The plans need to contain procedures as to who:
- determine that the release needs to be reported to the CSB
- gather the data for the verbal or e-mail reporting
- will actually make the report
REMEMBER, the CSB reporting is NOT triggered by the EPA’s RQs! A report to the CSB may be necessary even when the amount released is less than the RQ but had an impact to workers or citizens.