CSB Provides Guidance on Release Reporting
In August, the US Chemical Safety and Hazard Investigation Board (CSB) released a 29-page guidance document for facilities that are subject to the accidental release reporting rule that took effect in March 2020.
The newly available guidance outlines the legal history of the release reporting rule and a summary of the requirements. CSB employs a Questions & Answer format to address many common points of uncertainty about the rule.
CSB’s release reporting rule requires owners/operators of stationary sources to make a report to CSB within 8 hours of an accidental release to the air of a regulated substance or extremely hazardous substance that results in death, serious injury, or substantial property damage (40 CFR 1604.3(a)).
From CSB’s Guidance Document
The guidance notes that making a complete report to CSB should take less than ten minutes. For releases that were already reported to the National Response Center (NRC), the facility is required to provide the NRC report number only, which will shorten the reporting time even more.
If the owner/operator is unsure whether a report is required for an accidental release, CSB states that the owner/operator “should report, rather than risk violating the rule by failing to report.”
On the accuracy of initial release reports, CSB says:
“Complete information is the goal, but absolute perfection is not a requirement. Hence, the rule allows for “safe harbor” reporting within 30 days following the incident so that owners/operators can update their submissions with more accurate information…newly developed information…or information that was not otherwise available…”
The full guidance document also clarifies the overall applicability of the rule and the definition of terms like "extremely hazardous substance" and "substantial property damage."
Data on Reported IncidentsRecently, CSB released chemical incident data submitted since the reporting rule took effect.
As of July 11, 2022, facilities had reported accidental releases from more than thirty different US states, as well as the US Virgin Islands. About one-third of the reported incidents occurred in Texas or Louisiana.
The 162 total incidents reported resulted in 25 fatalities, 92 serious injuries, and 68 instances of substantial property damage.
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