Letters: December 2018

An Environmental Perspective on Safety Awareness

I very much appreciate “Committing to Safety Awareness” (March 2018, p. 13), a review of the March AIChE Journal Perspective article, “Safety Awareness: A Chemical Engineering Imperative” by Robert Davidson. Safety awareness is critically important for chemical engineers beginning at the undergraduate level and throughout their careers.

Although the Environmental Protection Agency (EPA) was addressed with respect to the U.S. environmental movement, I was rather disappointed that Davidson failed to acknowledge EPA’s role in catastrophic chemical accident prevention, preparedness, and response. EPA’s Risk Management Program (RMP) for the prevention of chemical accidents is complementary to OSHA’s Process Safety Management (PSM) standard. OSHA’s PSM standard works to protect workers from catastrophic chemical accidents; EPA’s RMP works to protect the public and the environment. While both regulations have PSM at their core, the RMP has two fundamental additional requirements of importance to process safety: hazards analysis (including worst-case scenarios) and development of an emergency response program. Further, the RMP prepared by a covered facility is shared with State Emergency Response Commissions (SERCs) and Local Emergency Planning Committees (LEPCs), which were established by the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986. The RMP along with chemical information provided under EPCRA are designed to be used at the local level for emergency response planning, preparedness, and response.

Not only should chemical engineers have safety awareness within the process and facility, they also must be aware of the need for strong coordination at the local level with officials and first responders for sound chemical accident prevention, preparedness, and response. All of these elements must work together to develop that “robust safety culture and a future with fewer adverse health and environmental consequences” stated at the end of the article.

R. Craig Matthiessen, P.E

Burke, VA

The Author Replies:

Mr. Matthiessen makes an important point that there are many organizations — federal, state, local, and industrial — that all need to coordinate their efforts to avoid incidents and minimize impacts. EPA and its Risk Management Program (RMP) are key elements of the overall effort and should have been highlighted. He has clearly explained the need for chemical engineers to be aware of this further role. I appreciate his addition to the conversation.

Robert Davidson

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