Eliminate the CSB, and move the CSB incident investigations functions to OSHA and EPA.
In the spirit of the government eliminating waste and duplication, it is necessary to increase the efficiency of agencies. Having three agencies, the Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), and the Chemical Safety Board (CSB), all looking at investigations of industrial incidents is a triple redundancy.
The redundancy needs to be removed to better spend our tax dollars. The CSB does not have regulatory power and can only make “suggestions” to the industry it is investigating. It must rely on the other two agencies to make fines, change regulations, or do further analysis of the industry. This is not the most efficient process. Each regulatory agency needs to have its own investigative power to look into events that happen in the industry. The CSB has no real power to influence industry, make changes to regulations, or punish those who have intentionally violated rules, regulations, and laws and it needs to be eliminated.
There are things the CSB does well that need to be preserved. The dissolution process should keep the finer parts of the CSB such as the videos, the publicly accessible reports that are easy to read, and the reporting of all incidents occurring in United States. However, these need to be moved to within OSHA and EPA. These results are fantastic for the process safety management professionals as it gives them a place to look at events that have occurred in a language that is easy to understand. It also allows them to give the same reports to management and operations so they can also comprehend the risks.
The videos and reports are produced on a level that allows their use for safety meetings and safety instructions. These activities need to be kept and moved to agencies that have control over defining the regulations to deliver a better product to the industry. This would also help OSHA and EPA move away from being the “punishers” as they walk into the door to being an agency looking to help facilities understand the events that have occurred.
OSHA and EPA already have investigative functions that are dispatched to industrial accident sites. This redundancy with the CSB needs to be eliminated. It is not necessary to have three organizations show up to a facility. Allow OSHA and EPA to work together to determine the responding agency and let that agency take the lead on the investigation, and remove the CSB from the equation. Increase the strength of investigations at OSHA and EPA and there is no need for a third agency.