Joint EPA/OSHA/CISA Safety Advisory
Hazardous Chemical Storage
Today, CISA’s Office of Chemical Security published a ‘News Item’ on the Chemical Facility Anti-Terrorism Standards (CFATS) Knowledge Center pointing at a new joint EPA-OSHA-CISA safety advisory: “SAFETY ADVISORY: Risks of Improper Storage of Hazardous Chemicals at Chemical Warehouses and Chemical Distribution Facilities”.
Following the Links
The link on the Knowledge Center takes you to the CFATS Resources page. There under the “Industry-related Chemicals Fact Sheets” heading is a listing for the “Joint Safety Advisory: Risks of Improper Storage of Hazardous Chemicals at Chemical Warehouses and Chemical Distribution Facilities (PDF, 353 KB)”.
Unfortunately, clicking that link returns an ‘Access Denied’ message:
INSERT Access Denied Photo
Looking closely at the link in that message it is easy to see why that message resulted. The link starts: “https://edit.cisa.gov/”. It would not do to allow the general public to have edit permission on the web site. Remove the ‘edit.’ And the link works fine.
The same Safety Advisory can be found via the EPA’s Chemical Accident Prevention Publications page. The link there works properly without editing and goes to https://www.epa.gov/system/files/documents/2021-11/11_02_21_jointsafteyaltert_chemicalwarehouse_final.pdf
The OSHA Chemical Facility Security and Safety Working Group page does not actually link to the document. Instead the link on the OSHA page takes you to the EPA page described above.
Safety Concerns
The Safety Advisory notes:
“In the past several years, federal agencies have visited numerous chemical warehouses and chemical distribution facilities (i.e., companies that process, formulate, blend, re-package, store, transport, and market chemical products) to determine compliance with applicable regulatory requirements for chemical accident prevention, preparedness, safety, and security. Based on information gathered, agencies found that many facilities do not manage chemicals in a safe or secure manner. Complying with applicable regulations may help avoid catastrophic chemical accidents.”
It then goes on to list eleven concerns about chemical storage. The first 10 are common safety issues that anyone who has worked around chemical storage will readily recognize. That is certainly not saying that folks don’t need to be reminded about these issues, complacency is a problem in any industry and safety reminders are always in order.
There is only one security ‘concern’ noted, the last concern:
“Failure to complete a CISA CFATS Top-Screen, as well as not utilizing predictive filing to determine all reportable chemicals of interest.”
Regulatory Summary
The bulk of the five-page Safety Advisory provides a brief overview of the various regulatory programs run by these three agencies that deal with chemical safety and security issues. It lists the commonly used name for each program, the CFR reference (no active links unfortunately) and a brief summary of the program requirements. There are a number of links provided to various program web sites and fact sheets.
Commentary
The timing of the release of this advisory, just before the holidays, is not really helpful. It is likely to get overlooked in all of the hustle and bustle of the end of the year. That combined with the fact that there is no coherent action statement provided in the document means that this is probably not going to result in any changes in behavior or compliance.
Now, having said that, this is a valuable document because it puts a summary of the major chemical safety and security programs in this country into one document. It would be more valuable with links to the US Code and CFR references mentioned in the document, but those are readily available from https://www.govinfo.gov/, so that is not a major problem.