CSB Commends CGA for Developing New Process Safety Standard, CGA P-86

On April 2, 2021, the U.S. Chemical Safety and Hazard Investigation Board – referred to as the CSB – held an open public meeting to discuss operations and agency activities. During this meeting, the CSB commended the Compressed Gas Association (CGA) for developing the new safety publication, CGA P-86, Guideline for Process Safety Management, in response to CSB’s recommendations.

We share the details of CSB’s positive comments in the article below.

Overview

The CSB is an independent, non-regulatory federal agency that investigates major chemical incidents at fixed facilities. These investigations examine and evaluate a wide range of aspects, including:

• Equipment and system design
• Regulations, industry standards, and guidance
• Training, operations, and procedures
• Human and organizational factors

In 2016, the CSB conducted an investigation and issued recommendations related to a fatal nitrous oxide incident. Three of those recommendations were addressed to CGA; all of those recommendations have now been closed.

Specifically, as a part of its investigation in 2016, the CSB “reviewed relevant industry standards by the Compressed Gas Association and determined that safety in the nitrous oxide manufacturing industry would greatly benefit from the risk reduction provided by a process safety management system.”

During the meeting on April 2, 2021, the CSB provided detailed, positive comments about CGA’s response to the agency’s recommendation 2016-4-I-FL-R2, Safety Management System for Nitrous Oxide Manufacturing. We provide those comments below, verbatim.

CSB Recommendation (2016-4-I-FL-R2): Safety Management System for Nitrous Oxide Manufacturing

Develop and implement a safety management system standard for nitrous oxide manufacturing, to manage known process safety hazards, including nitrous oxide decomposition, which includes appropriate elements based on chemical industry good practice guidance, such as CCPS Guidelines for Risk Based Process Safety, Essential Practices for Managing Chemical Reactivity Hazards, and Guidelines for Implementing Process Safety Management.

In May 2020, CGA published CGA P-86, Guideline for Process Safety Management (CGA P-86) that is applicable to the nitrous oxide industry. The document has 21 elements that fully implement a process safety management system necessary to manage known process safety hazards such as nitrous oxide decomposition, as well as identify, assess, and manage other hazards.

It is also highly significant to point out that the scope of CGA P-86 extends far beyond addressing the hazards associated with nitrous oxide. In fact, the scope was expanded to address all processes within the industrial and medical gases industries. Additionally, the process safety management elements found in the CGA P-86 come from multiples sources. In addition to the Center for Chemical Process Safety (CCPS) it also includes information from the European Industrial Gases Association (EIGA) to make it a globally harmonized publication. These actions provide increased safety over several industry segments that includes the international community. This significantly exceeds what the recommendation intended and by far surpasses the objectives envisioned by the Board.

As a result, on 01 April 2021 the Board Voted: Closed – Exceeds Recommended Action. Any time a recommendation recipient receives this status, the CSB wants to recognize them for it.  Great job, Compressed Gas Association!

Q1 – What is the big-picture significance of CGA implementing…recommendation (R2), to develop and implement a safety management system standard for nitrous oxide?

A1 – As previously stated, as a part of our investigation, the CSB reviewed relevant industry standards from the Compressed Gas Association (CGA) and determined that safety in the nitrous oxide manufacturing industry would greatly benefit from the risk reduction provided by a process safety management system. In response, CGA published CGA P-86 which provided detailed guidance on 21 elements that fully implement a process safety management system necessary to manage known process safety hazards such as nitrous oxide decomposition, as well as identify, assess, and manage other hazards. But the amazing part is that they expanded the scope to cover all processes with the industrial and medical gases industries. This increases safety far beyond what the CSB intended, and we want to recognize CGA’s actions.

Q2 – Why did you choose to highlight the recommendations to the Compressed Gas Association?

A2 – Over the years, we have issued recommendations to the Compressed Gas Association in five of our investigations…The CGA has always been a very positive group to work with and have been very responsive in implementing recommendations in a short amount of time. With the closing of these recommendations, the last…of the recommendations issued to CGA [are now closed]. We want to thank CGA for their diligence and dedication and say, “Keep up the great work.”