The Strange Case of The Missing Safety Case Recommendation

The safety case is one of the keys to North Sea and Australian offshore oil and gas safety.  The approach is very much like a legal argument in which an offshore company must argue before government regulators and present evidence that it has identified hazards and addressed them.  Supporters say it helps ensure that industry has anticipated and controlled hazards.   (I am not so sure that it is an improvement over the U.S. approach and suspect that it is just as prone to becoming a routine check-the-box approach, but that is another story).

Recently  President Obama asked government agencies to come up with new, more effective ways to address safety and environmental concerns over hazardous chemicals (see blog posting here).   Proponents of the approach must have rejoiced when the National Institute for Occupational Safety and Health (NIOSH) recommended that the U.S. adopt a safety case approach in a March 6 record:

safety case letter


However, on June 6, after the chemical safety proposals had already been presented to the White House and had been released to the public, NIOSH sent a letter withdrawing the original letter and submitting a new letter that removed any reference to safety case.   They said they based it on a “reevaluation of the scientific evidenciary foundation” for its first letter.    Huh!   Is that bureaucratic speak for ” we just realized we were out of sync with the recommendations of every other agency?”

Thanks to the Charleston, West Virginia Gazette for noticing the reversal.  Here is their article.


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