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| Documents/CSB/3: Implementation of Recommendations |
3: Implementation of Recommendations Reduce the likelihood of similar accidents in the future by securing implementation of CSB safety recommendations. Other Information: Key Results: - CSB safety recommendations are closed based upon acceptable actions by recipients Key Strategies: Resources, Skills, and Technology Needed - Maintain an efficient system for rapidly communicating with recommendations recipients, tracking the status of all open safety recommendations, and evaluating the adequacy of recipient actions - Publicize up-to-date status information on all safety recommendations through the CSB website and other public communication channels, with an emphasis on most-wanted safety actions - Conduct focused advocacy programs for significant, challenging safety recommendations through ongoing dialogue with relevant government and other stakeholders, testimony, and other public communications - Publicly recognize recommendations recipients that implement significant safety actions based on CSB safety recommendations Metrics: - Number and percentage of safety recommendations closed successfully Discussion: Specific, measurable recommendations are a primary tool of the Board for encouraging safety improvements that help protect workers, the public, and the environment. Most CSB reports, bulletins, case studies, and hazard investigations include a number of safety recommendations directed to specific named organizations. Recommendations recipients include government agencies at all levels, standard-setting organizations, trade associations, labor unions, and private corporations such as oil and chemical firms, engineering companies, and insurers. By statute, the EPA and OSHA must respond to any CSB safety recommendation within 180 days. The CSB’s recommendations staff works with recipients and other interested parties to help ensure the successful acceptance of recommendations. As soon as a recommendation is issued, the Board communicates with the recipient in writing, providing the text of the recommendation and citing its rationale in a specific CSB investigation. Recipients are requested to provide extensive documentation of the actions they take in response to the CSB’s recommendations. In some cases, CSB staff and board members may visit sites to assess the safety changes made in response to a recommendation. If a recipient’s actions meet or exceed the intent of the CSB’s recommendation, the staff develops a formal, written evaluation urging closure of the recommendation by a vote of the full board. Significant recommendations may require extensive, time-consuming advocacy efforts to achieve successful closure. For example, in 2003 the Board determined that improvements in New York City’s 85-year-old fire code were required to help prevent future accidents similar to a 2002 building explosion in downtown Manhattan that injured 36 people. The recommendation to modernize the fire code at first encountered skepticism and resistance. Board members conducted two public meetings in New York City, testified twice before the New York City Council, met with key stakeholders, and made a number of media appearances to discuss the importance of the requested safety changes. Within one year, the New York City government changed course and began working on a complete overhaul of the code. In 2005, the Board developed a real-time tracking system for the status of all of its issued recommendations; up-to-date status information on hundreds of recommendations appears on the agency’s popular website, CSB.gov. The Board recognizes that public, stakeholder, and media interest in the responses of recipients to CSB recommendations is a key ingredient in gaining acceptance and closure of these recommendations. Some recipients opt to go above and beyond the actions contemplated in CSB recommendations. For example, the American Institute of Chemical Engineers’ Center for Chemical Process Safety — responding to a CSB recommendation for better guidance on preventing accidents involving reactive chemicals — developed and issued an entire book on the subject and through the funding of government agencies made it freely available to the entire industry. The state of Kentucky exceeded the Board’s safety recommendation for controlling industrial dust explosions by establishing a comprehensive identification, inspection, and outreach program for facilities statewide that handle combustible powders. In such instances, the Board provides special recognition to recipients through public announcements, speeches, or certificates. Baseline Statistics: As of July 2006, the CSB had issued 383 safety recommendations, including more than 200 in the preceding three years. To date, 145 safety recommendations have been successfully closed based on actions that meet or exceed the Board’s intentions. Many of the remainder are in varying stages of implementation, and fewer than 20 recommendations have been designated as “unacceptable” or “no longer applicable.” From a low of 10 recommendations closed per year in 2003 and 2004, the CSB successfully closed 54 recommendations in 2005 and has closed 66 more as of July 2006. Objective(s):
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