Executive Order 13650 Improving Chemical Facility Safety and Security Public Listening Session, Baton Rouge Louisiana

Date: February 19, 2014

Location: Louisiana State Police Academy , 7901 Independence Blvd., Baton Rouge, LA 70806
Introduction and Opening Remarks
Patrick White, Facilitator , introduced the proceedings and remarked:

• There are opportunities for those on the phone to comment at the Newark, New Jersey session scheduled for February 27. Written comments can also be provided to eo.chemical@hq.dhs.gov

.
• This session is being recorded for note

- taking purposes only.

• Purpose: Provide stakeholders an overview of the Executive Order 1365 0: Improving Chemical Facility Safety and Security (EO) progress to date and provide an opportunity for the public to provide comments, feedback, and suggestions.
Summary and Progress to Date

J ordan Barab , Deputy Assistant Secretary, Department of Labor/Occupational Safety and Health Administration ( OSHA ):

• Thanked those attending the session

• Referenced the additional sessions that have been held since November 2013

• It is important to be in Louisiana.

o Mentioned some of the chemical releases over the past few years (land, air, and sea)

• The w orking g roup is a ware that there are companies doing a good job and want to address outliers not cooperating with the regulations.

• The President has tasked the G overnment to take meas ures and make recommendations to improve the safety and security of chemical facilities.

o The White House is very serious about these issues and wants the hard issues addressed , including through p olicy recommendations.

• Each agency has an important r ole to play in chemical facility safety and security:

o The Department of Homeland Security ( DHS ) focuse s on security ;
o OSHA focused on worker health and safety ;
o The Environmental Protection Agency ( EPA ) focuse s on facility safety and the protection of human health and the environment.

• Two of the EO goals are to improve operational coordination and information sharing and to modernize regulations and best practices

.
• The w orking g roup d ivided the directives into manageable sections and e stablished four working groups :
o Sections 3 and 4: Coordination of Federal a gencies

 Plan to work together (all stakeholders from the G overnment to local communities)

EO 13650 Public Listening Session Page 1 February 19, 2014 Baton Rouge, LA Highlighted the EPA Region II Pilot Program that defines high risk and inspection prioritizations between agencies

o Section 5: Examining ways that data is collected and disseminated b etween agencies and to local stakeholders as needed.

 Agencies have defined sharing regimes and a common terminology

.
 The g oal is to build a flexible data

- sharing process with more accessibl e information.

o Section 6: Policy , Guidance, and Standards Modernization

 Focuses on policy issues

 Developed a list of options to improve safety and security by improving risk management practices

 There is a draft document on the OSHA EO webpage for review. Lisa Long will review the options listed in the paper later in the introduction.

 Will develop a plan based on the commented options

 Anything decided based on these options will still undergo the rulemaking process.

 The Interim Chemical Advisory was also is sued on August 30 on the safe handling, sale, and storage of a mmonium n itrate

. This document is considered an evergreen document

. o Section 7: Stakeholder Outreach and Best Practices

 Runs the listening sessions

• Comments may be submitted through the OSHA EO W ebsite or at eo.chemical@hq.dhs.gov

. • In the coming weeks and months, the w orking g roup will finalize tasks and making recommendations to the President. This will mean that the results will be public , and a work ing plan will be established going forward.

• One 90

- day status update has been made, and another is forthcoming in a few days.

• The purpose of these listening sessions came out of the tragedy in West, Texas in April 2013. Based on that, the working group is looking to establish a better method for promoting safety and security in chemical processing facilities.
Mathy Stanislaus, Assistant Administrator, Office of Solid Waste and Emergency Response Executive, EPA, Executive Order 13650 Working Group Co

- Chair :

• Underscored Mr. Barab’s comments that these listening sessions are crucial to understand ing insight from all stakeholders in establishing recommendations for the President.

• The w orking g roup has heard a lot about local preparedness and gaps in that infrastructure as well
as access of local responders to chemical facility data during emergencies . This has become a major point of focus.

• Another point that has been raised is better notification to the local comm unity in case of an emergency.

• The w orking g roup has also h eard a lot about the need for coordinated outreach to smaller and mid

size d facilities that do not have the ability to fully understand and comply with the existing regulations.

• Coordination of da ta among the F ederal programs has been a topic throughout the listening sessions . Easier and understandable data that can be consumed by stakeholders is important.

o EPA is specifically looking at two programs: R isk M anagement P lan (RMP) program and the Emer gency Planning Community Right

- to

- Know Act ( EPCRA ) program.

 Looking at additional hazards , including reactivity hazards

EO 13650 Public Listening Session Page 2 February 19, 2014 Baton Rouge, LA Looking at additional chemicals to add to the regulated list

 Using industry

- based programs for risk

- based analysis

 Safety c onsiderations and how data can be better enabled for local responders

• The w orking g roup is planning to modify the a mmonium n itrate alert based on responses from industry that some information is outdated

. • The rough end date of the EO deliverables is the end of May. A p rogress report will be available in the next few days to update stakeholders on the work done to date.
Dave Wulf, Director, Infrastructure Security Compliance Division (ISCD), DHS , Office of Infrastructure Protection :

• ISCD is responsible for administering the Chemical Facility Anti

- Terrorism Standards ( CFATS ) program as well as the pending Ammonium Nitrate Security Program.

• Amy Graydon will fill in for Mr. Wulf from time to time during this session.

• DHS brings a unique security

- centric perspective to chemical protection through voluntary and regulatory initiatives.

• The voluntary programs are meant to assist chemical facilities in navigating the regulations.

• The U.S Coast Guard leads the efforts for the Maritime Security Transportation Act.

• DHS c oordinate s with stakeholders across the industry to establish these programs and promote chemical sector resilience.

• The CFATS program identifies and regulates those programs at the highest risk for terrorist attacks and exploitations.

o More than 4 , 200 facilities are regulated. More than 70 of these are in Louisiana.
o Since 2007, ISCD has made much progress to make Americans safer through inspections and authorization of chemical facility Site Security Plans.

o Through the imp lementation of safer processes and chemicals, m ore than 3 , 000 facilities have modified their process and holdings so that they are no longer high risk.

Matt Wren, Department of Justice/Alcohol, Tobacco, Firearms, and Explosives ( ATF ) :

• ATF also regulates the explosives industry.

• This includes the storage , handl ing , manufactur ing , and distribution of a mmonium n itrate f uel o il.

• All stakeholders are here to promote more safety and security. The best way to get to that point is to receive input from the public , and he is looking forward to the audience’s comments.
Lisa Long, OSHA provided a brief summary of the options document, “Executive Order 13650, Section A

– Solicitation of Public Input on Options for Policy Regulation and Standards Modernization,” locat ed at: https://www.osha.gov/chemicalexecutiveorder/Section_6ai_Options_List.html

.
Mr. White established some session ground rules :

• The p urpose is to hear a diverse set of opinions from a broad spectrum of people.

• The w orking g roup is not looking for consensus on any topics.

• Comments should be related to the Executive o rder.

• Please respect the opinion of others.

EO 13650 Public Listening Session Page 3 February 19, 2014 Baton Rouge, LA• State your name, organization , and/or stakeholder group when presenting.

• Five minutes are provided to each person when speaking.
Registered Speakers : Steve Taylor, Missouri Agribusiness Association (MAA) , remarked:

• He and his organization have much experience with fertilizer

- grade ammonium nitrate ( AN )

.
• Organization j oined with Fe d eral representatives to sponsor a mmonium n itrate regulatory training throughout Missouri.

o EPA, OSHA, DHS, and Missouri State regulators conducted the t raining

. o During the training, the OSHA official stated that 29 CFR 1910.109(i) would be enforced.

• Current provisions for 1910.109(i) are only related to equipment

- grade AN in blasting agents and other related components.

• Institute of Makers of Explosives ( IME ) gui delines address the safe handling of technical

- grade ammonium nitrate and advocate for rulemaking to update 109i.

o Missouri Agribusiness d isagree s on IME ’s position to prohibit wooden bins.

 If proper safety guidelines are followed, wooden bins are safe.

 A close review of past accidents shows that confi nement, compression, and contamination are the causes.

• In regards to coordination and information sharing, more attention should be put on emergency response planning.

o MAA has a history of working with Local Emergency Planning Committees ( LEPCs ) . In July 2013, he participated in the Region 7 LEPC/T ribal E mergency R esponse Commission Emergency Planning & Response Conference

. o MAA d eveloped its own guidelines and looks forward to an opportunity to discuss those at a later time.

o More attention shoul d be placed on emergency response planning.

o P articipated in many sessions and panel discussion related to AN handling

• Quoted K arl Brooks : “ The worst time to know your emergency responders is when you roll up on an incident. ”

• Overall g eneral recommendations :
o He w ould like to see CFATS long

- term implementation and authorization

. o PSM retail facility exemption should be retained

. o They are skeptical of including AN in RMP

. Andy Zellinger, Louisiana Bucket Brigade (LBB) on behalf of Anna Hrybyk , commented:

• Louisiana Bucket Brigade s upports grassroots action s to hold industry and G overnment accountable for the true costs of chemical pollution.

• Louisiana is particularly vulnerable due to the amount of pipelines and oil wells in the S tate.

o Produces the most oil and has the second largest refining capacity in the United States

EO 13650 Public Listening Session Page 4 February 19, 2014 Baton Rouge, LA• A ccording to the National Response Center , 10 petrochemical accidents per week occur in Louisiana.

• Coast Guard has been taking more complaints , at over 4 , 000 complaints a year.

• There are 20 ,000 people and 90 schools and day care centers within 2 miles of refineries . The se buildings shake when flares go off

. Residents can hear workers talking inside the plant on the intercom.

• Three areas need strengthening :
o EPA RMP: Improve methods of targeti ng high

- risk facilities for inspections.

 Leve rage additional programs from OSHA, the State p olice, and the Louisiana Department of E nvironmental Q uality

.

 Often, facilities ’ self

- reported measures in their Risk Management Plans do not correlate with what they actually have in their facilities or what they report to other agencies.

 In Oct 2010, the LB B review of Exxon Mobile Baton Rouge refinery’s RMP showed that the RMP does not comply with the Clean Air Act Part 68: Accidental Release Prevention.

• Accidents from this facility were not reported to EPA’s RMP based on this review.

• On April 14, 2010 , a flash fire sent people to the local hospital’s burn unit , but no information wa s given regarding its root cause.

 Need additional RMP inspectors i n Region VI

.

 Improve enforcement of viol ations found during inspections to ensure that facilities take concrete meaningful action when fault is discovered.

o LEPC i mprovement :

 LEPCs are great in theory, but in practice they are n ot legally enforceable

.

 There are many EPCRA violations within LEPC plans , specifically in sections 301 and 303.

 Specific dates do not exist for training plans. Also , there is no mention of environmental monitoring or protection.

 They need better funding and enforcement capabilities.

o Improving information for first responders:

 Fenceline monitoring should be increased , and the data collected should be available to the public in real time.

 Currently the Clean Air Act does not require this and should be updated to do so.
Darryl Wiley, Environmental Justice program, Sierra Club , remarked:

• Welcome to Cancer Alley. This is the heart of the beast where chemical accidents occur on a regular basis.

• Emergency r e sponse time is poor

— including hours and days after an accident.

• There is not an environmental justice (EJ) reality in the United States.

o The EO working group needs to give this greater consideration.

EO 13650 Public Listening Session Page 5 February 19, 2014 Baton Rouge, LAo There is no EJ analysis required in any F ederal reviews. This should occur.

• P ost

- Hurricane Katrina Louisiana has seen changes to public access to emergency planning.

o The Local Emergency Planning Commissions no longer allow public input since the h urricane. Mr. Wiley said that he has not been invited to any meetings or asked to en gage in any planning efforts.

o He is not aware if the S tate commissions are operating but said that a nnouncements are not made and that the community is not engaged.

• In regards to a risk map, when the law first occurred, he had to work through his Congressm an to get to the LEPC to look at risk map data

• Enforceable r egulation needs to be established , as oppose to establish ing limits for voluntary compliance.

o Voluntary compliance does not work ; for example , every time I drive over 70 miles per hour on the fre eway, I do not write myself a speeding ticket.

• E nforcement is important.

• We often talk all over the place about chemical safety after accidents , but we need to actually get a handle on it.

• Including the transportation of these materials , including tar san ds by rail, makes this a difficult situation. Cleanup from preventable accidents is important.

• Have to force petrochemical plants to implement safe r chemicals and safer processes and not the same old 18 th

- and 19 th

- century procedures they know they can profit from

• Question from Mr. Barab : At each session t he working group has been dealing with handling questions about balancing security and public awareness. How should it be done?

o Mr. Wiley responded: He has been harassed by rent

- a
- cops when taking pict ures of facilities

. There is a water treatment plant l ess than 10 blocks from his house

. There has been no effort to reduce risk through implementing inherently safer technology ( IST )

.
• Question from Mr. Stanislaus : What is the meeting that you mentioned th at no longer occurs?

o Mr. Wiley responded: The LEPC meeting in New Orleans and the State Emergency Response Commission. He does not know if they are still meeting and, if so, where. He u sed to attend both on a regular basis but cannot anymore for some reaso n

. Everything has shifted since Katrina, and information is missing.

• Question from Mr. Stanislaus : Does he h ave a proposal for applying an environmental justice analysis to F ederal review?

o Mr. Wiley responded: He and the Sierra Club have been considering h ow to put environmental justice analysis in the safety tools. He is s hooting for March 31for the publication of those comments.

Wilma Subra ; C E RC representative , former LEPC Chair , Technical Adviser to the Louisiana Environmental Action Network, and Presid ent of the Subra Company ; commented:

• The industrial facilities in the East Baton Rouge Parish break the EPA’s Risk Management plans anywhere from one unknown chemical to 40 unknown chemicals.

EO 13650 Public Listening Session Page 6 February 19, 2014 Baton Rouge, LAo The worst

- case scenarios extend from the two worst facilities out to 19 and 25 miles.

o Population risk in these areas is 420,000 and 470,000 individual s , respectively.

• While we conduct this EO listening session , we are in the worst

- case vulnerable zone in the P arish.

• 18 chemicals exceed the threshold levels in this ar ea. In addition, 29 other chemicals exceed the threshold level in adjacent areas.

• This pattern of risk is associated with other p arishes along the Mississippi river.

• Adding additional chemicals and substances to the RMP rule will reduce risk in these indus trialized

areas.
o However, due to security issues, the populations are not aware. They rely on EPA to protect them, but they need to be provided with better awareness so they can reduce their own risk.

o More data needs to be made available to the public.

• The oil and gas industry is booming in the United States through the development of shale deposits.

o This has caused a wide array of environmental issues.

o There is a desperate n eed for EPA and OSHA to develop and implement regulatory programs for shale , oil, a nd gas workers and communities

. o OSHA needs to remove the exemption and implement rules to cover the drilling and fracturing of shale oil.

o OSHA must r esume enforcing Process Safety Management ( PSM ) standards in regards to this work.

o EPA must include upstrea m oil and gas facilities under RMP and EPCRA. They release large quantities of toxic chemicals into the air, water, and land , and their production byproducts are dangerous while being located close to each other , resulting in dense development.

 One central ized facility in the Eagle Ford area of Texas reported a release of 42 pounds of benzene , as well as other releases.

• Question from Mr. Stanislaus : Are there recommendations coming from the Stronger G roup ’s deliberations that could inform the EO in terms of best practices and deliberations ?

o M s . Subra responded: Stronger developed guidelines that the working group should review, and it has reviewed a number of S tates. Texas has been extremely reluctant to participate.

Anne Rolfes , Louisiana Bucket Brigade (LBB) and the Green Army , remarked:

• Shared a story about how President Johnson was told that he should not address c ivil r ights issues

. In response, President Johnson said, “What the hell is the Presidency for?”

• It is ti me for all of us to get some guts.

• The audience ’s statements are the same things that have been said for the past 20 years.

• When Exxon and other chemical producers are telling you to slow down, a child can tell that the situation is out of hand.

• If the Fed eral Government cannot be tough and stand up to companies, what is the job of the President for?

EO 13650 Public Listening Session Page 7 February 19, 2014 Baton Rouge, LA• Has submitted written comments, but this will not be changed through written comments. These issues will be changed through will.

• The President is aware that h e needs to make hard changes through the Executive o rder.

• Four recommendations:

o Increase b u ffer zones

. o Chemical Safety Board needs teeth (also other emergency planning laws)

.

 The Emergency Planning Commissions in local parishes are in clear violation of the law based on their meeting minutes ( specifically, St. Bernard P arish and East Baton Rouge P arish )

.

 EPA’s Regional Enforcement R epresentative sa ys that he cannot do anything

.

 When they attempt to file lawsuits, the laws are so weak that there is nothing they can do.

o Criminal Prosecution of p lant m anagers and p ublic r elations p ersonnel :

 Public r elations/ a ffairs representative at Exxon Mobil said that none of their chemicals came close to leaving their facility. There is no impact on the community.

 Hold co mpanies responsible for lying during public statements.

o Federal a gencies should take over the S tate of Louisiana

.

 Louisiana has a culture that protects industry

.
• Funding should be pulled from large corporations (Exxon) to fund the regulation push.

• She move d back to Louisiana when she was 30 years old. She is now 45, and Mossville continues to have issues.

Willie Mae Weese, Vice President of L ouisiana E nvironmental J ustice Community Organizing Coalition (LEJOC), commented:

• LEJCOC is a statewide group formed to support the needs of the environmental justice communities in Louisiana. They also address racism and other social issues.

• St. James P arish is a fenceline community between New Orleans and Baton Rouge surrounded by 17 industries known as Cancer Alley.

• It truly is Cancer Alley because she knows many people in her community who have cancer or have recently died from c ancer.

• Toxic chemicals emitted by the companies include :
o Sulfuric Acid

o Nickel and Nickel Compounds

o Chlorine

o Hydrochloric Acid

• There is no ev acuation route established for this community

.
Diane Honor , LEJCOC , stated:

EO 13650 Public Listening Session Page 8 February 19, 2014 Baton Rouge, LA• She recently had a heart attack

.
• Is a sking for proper transportation of the sick

• She is asking for community n otification of plant issues and transportation away when an accident

occurs.

• Notification does not occur until after a few days after an accident.

• Question from Mr. Barab: What type of evacuation plans currently exist?

o Ms. Honor responded: The current plan is you can get out if you have a vehicle , and evacuation plans are word

- of

- mouth.

• Question from Mr. Barab : Has there been an evacuation recently?

o Ms. Honor responded: She says no, but there have been accidents recently with limited communication and no push to evacuate.
Agnes Francisco, Communit y Advocate , commented:

• Moved to Alexandria in 1959 where they were surrounded by treating plants for railroad ties and telephone poles

• Many deaths have occurred , from babies to college students to the elderly.

• From January 1, 2013 to September 2013, 113 pe ople died.

• The EPA in Dallas knows about it. They have asked the treating company to do soil sampling.

o EPA was told that the company did the sampling before they arrived and that there was nothing wrong

. EPA did do their own sampling , and t he company resul ts do not match t he City of Alexandria results.

o Why is the sampling different?

• Knows that s ome one in each house on a particular street who has died of cancer.

• She wants to know what her area can do for clean air against a company that has been polluting si nce 1923 and has the money to continue to do so.
Molly Brackin, LBB , Monitoring and Evaluation Associate , commented:

• The Executive o rder acknowledges the importance of information exchange

• Has seen communication breakdowns

o She has had n umerous conversation s with people who have no information about accidents and who are left in the dark.

• There is a major difference between what can be released and what has been released by an accident.

• Communities and first responders should not have to search for informati on on chemicals and pollutants . It should be provided to them.

• There is a chronic accident problem in Louisiana regarding chemical accidents.

o In January 2014 , there have been 62 N ational R esponse C enter reports

.
• LBB has an open

- source tool to track these accidents.

o Pol lution map that has a W ebsite available to the public :

EO 13650 Public Listening Session Page 9 February 19, 2014 Baton Rouge, LA iWitness Pollution Map: http://map.labucketbrigade.org/

o Sourced to the population for social network reporting and response

o Geolocates citizen complaints

o Provides a visual of the offsite impacts of chemical accidents

o LBB uses the tool to contest the claim that accidents do not affect those communities.

• More needs to be done to protect communities from dangerous polluting neighbors.

Marci a Our sler , Louisiana Bucket Brigade ( LBB ) commented:

• Toxic Release Inventory (TRI) is only updated to 2012 instead of 2014.

• One month ago, community members in Shreveport, Louisiana started to complain about air quality issues. The TRI said there were no p otential; however, a n analysis by LBB disagreed.

o Air contained benzene, hydrogen sulfide, methyl ethyl ketone, chlorobenzene, n

- hexane, propene, and toluene.

o All of these create health problems.

• LBB analysis tends to inform the communities better than any other reports or data shares.

• Communities have a right to know about the chemicals that fill their air.

• Urges OSHA to improve some issues and take some steps:

o Enhance information sharing.

o Identify additional ways to work with stakeholders to identify best practices

. o Adopt EPA’s policy for Risk Management Plan ’s List of Regulated Substances

.
• The Federal Government should institute the precautionary principle:

o Various chemicals should only be used if proven safe for human health

. o RMP should be adjusted to include a more thorough list of chemicals that benefit the welfare of both industry and surrounding communities.

• In a world where synergistic relationships are not unheard of for varying substances, it is increasingly important for d isclosure to be in the public knowledge.

• Mr. Barab asked a question: What is a LBB “ bucket analysis ?”

o Ms. Oursler responded: The LBB uses a “bucket” to pull a sample of the air for analysis

. It is a lined bucket connected to a vacuum cleaner that will su ck in and contain an air sample in about 3 minutes

. It then u ses a GCE Mass Spec trometry to analyze the information.
Steve Arendt, ABS Group, Process Safety Expert , commented:

• Addressing the pa nel for the third time

• There are four kinds of companies:

o Companies that know what to do and do it

o Companies that know what to do and fail

o Companies that know what to do and intenti on ally do not do it (criminals)

o Companies that don’t know what to do.

• Efforts should be targeted different ly based on different class es of companies.

EO 13650 Public Listening Session Page 10 February 19, 2014 Baton Rouge, LA• He endorses a number of suggestions in improving enforce ment and information collection.

• Root causes are important.

• Information for proper targeting should be demanded from industry for flexible regulations.

o If companies want flexible regu lations, then they should be willing to deal with providing more information to do so.

• The Chemical S afety B oard should be leveraged for improvement. They should write accident reporting requirements which should lead to better performance metrics.

• Any rul e changes should be used to solve the problems and fix the root causes. Solutions that do not fix root causes are a waste of time and money.

• Extend the stakeholder involvement process to assess written comments.

• Create a Federal Advisory Committee Act ( FACA )

- type committee in a multi

- stakeholder environment for rulemaking feedback instead of vacuum

- type rulemaking.

• Open up economic impact analys is to the light of day , especially ones done by OMB.

• Question from Mr. Barab: It takes OSHA 7

– 10 years to issue a regulation from an RFI. Are there any suggestions to speed up that process? The reason it takes so long is due to robust public input

. o Mr. Arendt responded: Unfortunately , the only way to speed up regulation implementat ion is more accidents, and he woul d rather that not happen

. Stakeholder involvement could speed it up.

• Mr. Barab asked : What information should they get from companies to improve targeted enforcement?

o Mr. Arendt responded: Solicitation of ideas should be pulled from companies covered by t he regulations to find those that are avoiding the regulations. This will help alleviate any misunderstanding of data

. If we want performance

- based requirements, then information should be provided to make it easier for the G overnment to create those requi rements as well as making it fairer for industry.

• Question from Mr. Stanislaus : What is your view of disclosure of inf ormation on root cause analysis?

o Mr. Arendt responded: The PSM standard does not use root cause ; it uses performance standard. RMP does u se root cause

. The standard is to now go after root causes

. All PSM information is available at facilities to OSHA personnel

. The tragedy is that 20 years of data is in plants but is not referenced in a suitable way

. Improving activities that get better an d higher quality information and making it available to everyone (including root causes) can be helpful in the future.
Marylee Orr , Louisiana Environmental Action Network , remarked:

• This has been and is still called Cancer Alley

.
• The g oal of the RMP is to prevent accidental releases that can cause serious harm and to mitigate damages that do occur.

• In Louisiana, 51.6 million pounds are allowed to be released into the air under permit exemptions , and 12.6 million pounds are allowed to be released into the water.

• Accidental releases are very frequent.

EO 13650 Public Listening Session Page 11 February 19, 2014 Baton Rouge, LAo These releases add to the overburden of approved exposure.

• A n umber of accidents were collected along the Mississippi River. During the month of January, there were 33 reports. In December, there were 29, and s o on during previous months . The average release is nearly one per day. Each month there are hundreds of releases related to different types of oils and other pollutants that are not considered “chemical” releases. For the January releases:

o There were 38 toxic chemicals from 18 facilities.

o Exxon Mobil refinery had the most releases.

o 7 events released Benzene

o 4 events released HCl.

• Hundreds of accidental release events had detrimental health events in communities , specifically, from the Exxon facility.

• A co rrosion specialist from a British Commonwealth company visited Louisiana . He was appalled at the conditions , noting that an environment like this would not be allowed in his country.

• Facilities need to be upgraded to the most up

- to

- date processes, procedur es, and equipment.
Edward Flynn, Vice President, Health Safety and Security for Louisiana Chemical Association (LCA), commented :

• LCA r epresent s 63 chemical companies in the S tate of Louisiana

.
• The c ore value of every company is an unwavering commitment to community, safety, and security.

• They try to o perate safely with the goal of zero accidents, but he understands that they do not have a perfect record.

• When accidents happen, the collective responsibility is to determine why.

• Understand ing the root cause o f the accident is most important to preventing a future accident.

• LCA agrees with many elements outlined in the EO , specifically in s ections 3, 5, and 7.

• As responsible operators , we have an obligation to drive a culture of safety. This is the right thing to do, and it is the smart thing for business to do as well.

o This means engaging with other stakeholders in the chemical community.

• LCA has committees of company representatives that meet monthly.

o Safety and security are not propri etary , and these meetings are used to share information that is important to the EO.

o One main goal is continuing performance improvement

. o Committees also provide an innovative way to teach a culture of safety to undergraduate engineers in school who will be members of the chemical industry. They partner with Louisiana State University and plan to expand to other schools.

• Efforts at the plant level are also important , including:

o OSHA’s Voluntary Protection Program (V PP ) Program

o American Chemist Council’s ( A CC ) ResponsibleCare ® Program

o Serious About Fostering Excellence (SAFE) Program is LCA’s voluntary program created in the mid

- 1990s to evaluate and improve performance and process safety.

• Process safety takes many forms.

EO 13650 Public Listening Session Page 12 February 19, 2014 Baton Rouge, LAo They share the American Chemistry C ouncil’s views on inherently safer technology (IST)

.
• Question from Mr. Barab: Why do you not agree with Section 6?

o Mr. Flynn responded: This is a discussion that continues to take place within the organization. There will be comments submitted regarding S ection 6 that cannot be referenced yet at this listening session.

• Question from Mr. Stanislaus : In terms of root cause analysis and information sharing, there is a tension between proprietary information and public awareness. What information should we dis close? What is the right balance?

o Mr. Flynn responded: There is a long history of a right

- to

- know culture in this State . There was a big effort in the late ‘ 90s when RMP was created

. 9/11 has added a security consideration in how can we thread the needle t o provide enough information for right to know while balancing security concern s. An I nternet

- ready information share is not feasible due to this

. This is why the reading rooms were set up. A controlled fashion needs to be continued.

• Follow

- up from Mr. Sta nislaus : How can local information sharing be better done?

o Mr. Flynn responded: There is a rekindling of desire among the company to re

- energize community advisory panels. It is not a one

- size

- fits

- all approach, but it can be an effective way for plants to share information with the community directly

. These panels take a lot of maintenance work and community support, but it is a good mechanism.

• Mr. Stanislaus asked : In terms of the o utlier problem, how should the G overnment address it?

o Mr. Flynn responded: He was looking to the G overnment with the same question. Looking at S tate

- based and trade

- based organization are solid starts

. There are probably chemical manufacturers in Louisiana that do not belong to his trade group. There is always a need for outreac h to small facilities (mom and pop operations) to find outliers that may exist simply because they are not knowledgeable of all of the existing regulations

. Additionally, LEPCs need to be made aware of where outlier facilities exist.
William Fontenot, priv ate citizen , commented :

• If Mr. Flynn’s comments were correct, then there is no need for a hearing or listening session.

• In December 1984, the U nion C arbide accident in India occurred. 23,000 people died due to that, and 150,000 people were seriously injure d or still have health problems.

o Union Carbide concluded that it was a disgruntled employee who created the incident. What it did not mention is that 2 years earlier in Taft, Louisiana , a similar configuration of tanks existed and water entered the tank , c reating a similar reaction . The major difference was that there was control equipment that brought everything under control.

• Almost all industrial accidents and injuries are preventable. There is no excuse for the kinds of accidents that occur.

• Workers at facilities need to know more of what they are working with and what they are standing next to. Very little information is adequately provided to workers (particularly contract workers) about potential accidents.

EO 13650 Public Listening Session Page 13 February 19, 2014 Baton Rouge, LA• More information needs to be made available about products used in these industries to make sure it is being handled correctly and safely.

• Question from Mr. Barab: In terms of IST, how can we properly define and balance IST regulations?

o Mr. Fontenot responded: Part of the problem for the chemical s pill in West Virginia was that emergency responders did not have access to spill information

. It is very critical that the EO recommends to the President that information is made available to workers and security people who respond to accidents

. We need to put in place less dangerous materials.
Terry Newton , Director Safety and Compliance for Nelson Brothers , remarked:

• Comments will center on a mmonium n itrate (AN) s olids

• AN is the key component in blasting agents

.
• Nelson Brothers has never had an injury or illness to employ ees or public due to AN release or detonation.

o They have b een in business since 1956.

o This is attributed to best practices and regulatory compliance.

• They are a m ember of Institute of Makers of Explosives ( IME ).

• Supports all of the IME re commendations made to the EO, specifically:

o S upport updating and strengthening 29 CFR 1910

. 109 ( i )

 Eliminate the storage of AN in combustible structures

 Advise outside emergency responders to not fight fires involving AN but should instead evacuate personnel and locals to a safe distance

 They b elieve that this is a proven bedrock of AN safety

.

 This standard was violated at West, Texas

.

 This recommendation is based on their focus on employees and safety , as opposed to material s and equipment.

o Oppose a dding a mmonium n itrate or other explosives to RMP

.

 Division 1.1 explosives are the most sensitive ; these are not regulated by RMP and were delisted in 1998.

 An accident of 1.1 explosive would not create a release event, and the ATF current regulations hand le surrounding communities in such an event.

 There are no gaps in the regulation of explosives for RMP to fill.

 If 1.1 explosives are not covered, then less sensitive explosives like AN should also not be covered.

• Question from Mr. Stanislaus : If there are gaps, should they be filled through other programs and not RMP?

o Mr. Newton responded: Correct

.
• Question from Mr. Barab : Should AN also not be added to PSM?

o Mr. Newton responded: Correct

.
• Question from Mr. Barab : Aren’t there different ammonium nitrate regulations for explosive versus agricultural use?

EO 13650 Public Listening Session Page 14 February 19, 2014 Baton Rouge, LAo Mr. Newton responded: There are ATF

- specific regulations, and they apply to explosives.

• Comment from Mr. Rice: ATF regulates AN storage when it is stored near a blasting agent that can be recognized as an explosives. AN, by itself, is not regulated by ATF.

• Question from Mr. Wulf : Could you talk a little bit about security measures in place for AN?

o Mr. Newton responded: AN and blasting agents have the same security measures

. Under ATF regulations, they also have the same locking standards.

• Question from Mr. Stanislaus : Is his recommendation only related to explosives or to AN in general?

o Mr. Newton responded: He is referencing AN in general

. There are differences from those of the Missouri Ag ribusiness grou p

.
• Question from Mr. Wulf : Is the locking an industry standard?

o Mr. Newton responded: It is an indust ry standard and an ATF standard as relate d to blasting agents.

• Question from Mr. Rice: Should the locking standard be across the board?

o Mr. Newton responded: Certainly, for security purposes, yes.
Rick Vance, Nelson Brothers , remarked:

• Nelson Brothers is not a manufacturer of AN, but they are an end user in the mining industry.

• Explosives operations use a large amount of AN. It can be manned safely and properly.

• He will focus on security recommendations:

o Along with IME, they support the push of a supplemental proposal of rulemaking p rior to final rulemaking on the Ammonium Nitrate Security Program

.

 Nothing in the current proposal relates to the good housekeeping sta ndards OSHA promotes and are related to current best practices.

 The DHS proposal for registration and vetting will not work for the explosives industry due to bulk shipping.

 A transportation interface is essential. The chain of custody pro cedures oversteps TSA authority to determine the security risk of those engaged in AN transportation.

 We should not overlay redundant registration and vetting systems over the existing ATF standards and s ystems that already vet and determine who is appropr iate to possess such explosives.

 Urge DHS to address the unique operating conditions

• Use ATF , CFATS, or explosives vetting as sufficient under the proposed AN Security Program.

 It is inappropriate to finalize the proposal in the midst of the EO process.

o AT F should have access to criminal backgrou nd checks and other vetting and registration systems.

o Encourage the ATF to close the so
- called terror gap

.

 Federal law does not require ATF to allow people with “ positive hits ” access to explosives materials

— it only penalizes after these individuals receive access to explosives materials.

EO 13650 Public Listening Session Page 15 February 19, 2014 Baton Rouge, LA IME thinks this is an inadvertent oversight when the S afe E xplosives A ct was enacted.

 Presidents Bush and Obama have asked for the gap to be c losed.

• Question from Mr. Wulf: He appreciates the comments on AN rulemaking. Transporters are a major issue, and DHS wants to align with ATF. Given that there is a gap in the ATF authorities relating to AN, how should we address the gap as we continue to w ait for other gaps that still exist?

o Mr. Vance responded: He is not sure how to close the gap in the interim period due to the fact that it takes regulations through the system

. He would need help on answering that question.
Christine Bennett, Mossville , Louisiana resident, Mossville Environmental Action Now (MEAN) , commented:

• She is wearing a mask because her white blood cell count has dropped.

• Her doctors only know antibiotics and not chemical releases.

• Revelation 11:18 is her answer to the President

.
• Th ey are living in a kill

- zone among all of the chemical plants.

• She a sked if the facilitator or the panel is being paid by industry.

• Sasol is now coming to Mossville as well, and they are not regulated yet. The Mossville community is hoping that Sasol will not receive the permits.

• Wants Mossvi lle to be relocated before Sasol is permitted to establish themselves in the community

.
• Why isn’t there a toxicologist available to communities where fenceline issues are prevalent?

• Why are records only kept for a few years locally after a release instead of as permanent records that are electronically based and available to the public?

• There needs to be a better way to record accidents and releases and have access to them 24/7.

• Reque st s that Sasol is not allowed to co me to Mossville before permits are granted to the company
Delmar Bennett, Mossville resident, MEAN , remarked:

• He has some new ideas that he was not able to present previously.

• In terms of security, terrorists are a proble m.

• However , he feels that residents are actually being attacked by the plants themselves because the air they breathe is toxic.

• During shelter

- in

- place, why has it not been established that communities cannot be issued something like mask s until shelter

- in

- place is called off?

• In terms of a water system, can filtration be provided after accidents or release issues?

• The companies are the ones that report to the EPA and other agencies about plant issues. Should there be a regulation that plants are be require d to stay ahead of their potential issues?

• Mr. Barab commented that there is a mechanical integrity requirement that does require plants to stay ahead of potential issues.

EO 13650 Public Listening Session Page 16 February 19, 2014 Baton Rouge, LA• Question from Mr. Stanislaus : How is the community currently notified when shelter

- i n
- place is called and how many people follow those instructions?

o Mr. Bennett responded: There is a horn that blows. It is tested once per week (Tuesday at 12 PM)

. T he numbers are impossible to track. Additionally, many people don’t know exactly what the h orn means. Education is only done by word

- of

- mouth.
Lt. Gen, Russel Honore, Ret., Green Army , remarked:

• Moved to Louisiana 4 years ago and got involved with the Green Army

• There is an early 19 th

- century governance in Louisiana creating a 21 st

- century threa t.

• Facilities are abusing our human rights by hurting the environment.

• Fines are negotiable , and that is a problem. This system needs to be strengthened when it is found that facilities are negligent.

• Self

- regulation needs to be fixed. The State allows thi s, and it is unacceptable.

• T his is a high flood

- prone area, and no known flood protection exists with more than 100 chemical plants.

• Plants are so close that there could be chain reaction s, creating a weapon of mass destruction issue.

• These facilities do not have environmental impact statemen t s.
o He s tated that during his time with the Army, he needed an e nvironmental i mpact

s tatement for everything he did. Why does this same concept not exist for these plants?

• There should be a Federal EPA Command and Control Center in the S tate of Louisiana due to the large amount of plants and volume of chemical products between Baton Rouge and New Orleans. The Federal EPA o ffice should be a Command and Control Center.

• There needs to be a better alert system.

o Horns are not appropriate. What about a reverse 911 concept?

o There is no requirement for community training.

• What happened to an au tomated system alerting that releases have occurred and notify ing community members immediately?

• There should be a black box conc ept established during releases and response s

.
• Health monitoring should be provided.

• EPA should have a monitoring number where public can report.

• “Smell something, say something” should be the new moniker.

• They need a Justice Department revi e w

. Release issues are criminal and should be treated as such.

• A Federal i nspector should exist per plant 24 hours per day.

• By and large these are good companies. They just do bad things.
Open Comment Period
Ronald Carriger , Mossville resident and member of MEAN , remarked:

EO 13650 Public Listening Session Page 17 February 19, 2014 Baton Rouge, LA• In terms of s helter

- in

- p lace, it is a pointless measure because most houses are not going to be able to seal out the chemical during a release

.
• In response to being told to move away, it is not always that easy.
Wilma Subra, Subra Company and Louisiana Environmental Action Network , commented:

• Her open comment statements are a continuation of her earlier comments.

• Upstream oil and gas production facilities store many chemicals and harm the environment

. Excess threshold quantities ar e exceeded; however, they are not regulated in that fashion. These facilities also store and process flammable mixtures and have explosions and/or fires on a fairly frequent basis , particularly production well sites and injection well sites.

• Unit trains t r ansport shale oil and tar sand from North Dakota and Canada , respectively , to the G ulf C oast facilities and refineries . These trains ’ rail l ines are in desperate need of repair

. They

a re located near residential communities and two

- lane streets

.
• Flowback w ater and waste from shale development are being transported to Louisiana for d isposal by barge now as well, and they are going to have to deal with it.

• The EPA and Department of Transportation should monitor and address risk s associated with the transporta tion and storage of fracturing waste stream.

• The EPA RMP should address these waste streams . EPA needs to monitor the industrial facilities and enforce rules and regulations.

• Sufficient resources need to be provided to these F ederal organizations t o actual ly address these issues and to protect associated workers and communities.

• If the risk to communities cannot be reduced, then adequate buffer zones need to be created and communities relocated to compensate.

• Question from Mr. Stanislaus : I n terms of adequate buffer zones, how would they be implemented?

o Ms. Subra responded: State agencies have a small distance established based on injection well or landfill. The vulnerable zone is much larger than the current standard

. Any buffer zone should be based on the vulnerable zone and not based on current regulations.
Marylee Orr, Louisiana Environmental Action Network (LEAN), remarked:

• Address ed issue of citizen monitoring

o Regulatory and enforcement arms currently have limited resources.

o Citizen monitoring is an excellent way to fill the ability and resource gap that is left after Federal regulatory budget cuts.

• It is unacceptable that facilities intimidat e citizens attempting to monitor facilities under homeland security considerations.

• I ndustry in Louisiana uses security as an excuse to not document environmental disruption s.

EO 13650 Public Listening Session Page 18 February 19, 2014 Baton Rouge, LA• Many who document environmental issues are threatened and harassed under homeland security issues

.
• LEAN encourages F ederal agencies to take appropriate action to pro tect the health and well

being of chemical facility workers and communities.

• Communication is the key to everything. There is not enough communication.

• The issue of b uff er zone s is something they feel very strongly about.

• Relocation need s to be done rightl y and justly when needed.

• Shelter

- in

- p lace is not dealt with properly, and she would like to create more dialogue with that in the future.

• Question from Mr. Barab: S everal speakers have mentioned worker hazards. Why have many workers not testified?

o Ms. Orr responded: W orkers feel very intimidated by c ompanies in filing OSHA reports

. Their NGO has created an environment where people can approach them, but that is not the norm in the corporate environment

. Someone said to her once , “I sell my body for so muc h an hour to feed my family , ” and that is not right.

Delmar Bennett , Mossville resident, MEAN, remarked:

• He has been a plant worker and knows many plant workers.

• P lant worker s truly feel that they have arrived in life and have reached a goal in life that puts them above other people. As a result, they are willing to die to remain in that status.

• Most plant workers get to a point in life where they are actually able to adapt to the chemical inhalation until they are about 65 years old. Upon retirement, their body takes a shock , and they go through many changes.
Lt. Gen, Russel Honore, Ret., Green Army, remarked:

• It should be against the law to state that jobs would be lost if reg ulations are increased.

• We need to look at the F ederal level to determine what lean management and production truly

means.
o As a result, most workers are subcontractors , and institutional knowledge is lost at plants. This can cause major structural and proc ess issues at older plants.

• There needs to be a minimal safety zone surrounding a plant.

• We need rules similar to those of the Federal Aviation Administration ( FAA ) for plant operation , including no

- notice inspections.

o There is no requirement in Louisiana for bonding to run a chemical plant.

 If you are going to build a plant, then you can cover a loss created by an accident at the plant.
Terry Newton , Nelson Brothers , commented:

• He wanted to expand on the PSM statement.

EO 13650 Public Listening Session Page 19 February 19, 2014 Baton Rouge, LA• OSHA excluded blasting agents from PSM because it is highly unlikely that a mass explosion will

occur.

• AN does pose a threat that the PSM is intended to address.

• If AN blasting agents are managed properly under current OSHA regulations, workers, first resp onders, and the public are adequately protected.

• Additional regulations will not prevent future tragedies; rather, existing regulations coupled with best practices need to be better implemented and communicated.

• Outlier topic:

o The c ompany feel s that this c an be address by working with the local emergency response community.

o The question is how to identify these so

- called outliers. This can be best done through emergency responders as the eyes and ears.

o DHS can leverage FEMA resources to better train emergen cy responders as a conduit to provide outreach identification.

• It is Nelson Brothers ’ practice to invite local emergency responders to trainings on their facility to better understand their business and risks.

• Most emergency responders want to know these t hings. An invitation and engagement is the most important.

• Statement from Mr. Barab: He is surprised to hear that AN does not provide a risk that should be regulated under PSM standards based on the results of West, Texas

. o Mr. Newton responded: The produc t that exploded was not just AN, and the studies claim that it was AN in addition to other components.

• Mr. Barab asked: What is the logic that contamination s should not be covered by PSM?

o Mr. Newton responded: 100% pure AN chemical on its own should not be covered by PSM, but contaminants should be considered

. In their industry, contamination does not occur. Contaminants creates bad product.

• Question from Mr. Stanislaus : H ow should we look at LEPCs as a vehicle for outliers when they are staffed by volunteers?

o Mr. Newton responded : There are obvious limited resources, but local emergency responders (fire, police, etc. ) know that community better than anybody and should be leveraged to understand what may fly under the radar for larger regulatory organizations

. He does not know how to exactly fund that.

• Follow

- up from Mr. Stanislaus : E ach of the major trade groups has codes and different third

party auditing standards . H ow much of that capacity can be brought to the LEPC level for their effective distribution to outliers?

o Mr. Newton responded: As a member of IME, they are in support of working with local emergency response groups. They are not able to fund anything but are more than happy to work with them.
Steven Taylor, M iss ouri Agr ib usiness Association (MAA) remarked:

EO 13650 Public Listening Session Page 20 February 19, 2014 Baton Rouge, LA• Regarding the outlier discussion , MAA have been tackling that by attempting to leverage other databases.

o Missouri sales tax database

o Missouri registration database

• He encourages his membership to engage other c ompetitors that are not members and to communicate that information to the LEPCs.

• In regards to PSM, they approach it according to how chemicals are cooked. They focus on storage only.

o C ontamination is an issue. How is that handled?

o They focus their energy in their industry on storage guidelines and not necessarily PSM.

• In regards to wooden bins, there is not a one

- size

- fits

- all concept. He has members who have huge quantities of AN, but someone on the edge of town has a smaller amount of AN.

o Engaging LEPCs with an emergency response plan and communicating how that facility can be tackled in case of an emergency is necessary.

• In terms of AN fires, they will engage a fire, but if the fire is close to AN, then it will not be engaged.

• Question from Mr. Stanisl aus : O perationally, if a local responder has knowledge that AN is there, why would they ever fight that fire?

o Mr. Taylor responded: If the facility is spread out over a quarter mile, and a small building fire is several hundred yards from the AN storage, then it should be fought. If the fire is closer to AN, then it should be avoided

. This is why a layout of the facility should be shared with the LEPC so they can coordinate emergency response for containment, evacuation, etc.

• Follow

- up from Mr. Stanislaus : T he challenge is making sure that emergency responders actually have that information.

o Mr. Taylor responded: He recognizes that LEPCs have limited resources, and he thinks that regional meetings and bringing groups together to identify needed capabiliti es is a good first step, especially in rural areas.

• Question from Mr. Barab: O ne
- size

- fits

- all is always a problem with regulatory standards, but in terms of OSHA, they are more concerned about the facility and not necessarily the surrounding community. Th ey do treat each facility as a single unit.

o Mr. Taylor added: It is worker safety as well identifying when to properly attack an AN fire.

Mr. White adjourned the afternoon session to reconvene at 6 PM for the 2 hour evening session.
Evening Session Regist ered Speakers

• There were no pre

- registered speakers for the evening session.
Evening Session Open Comment Period

EO 13650 Public Listening Session Page 21 February 19, 2014 Baton Rouge, LA• There were no speakers for the open comment period during the evening session.
Closing Comments

• Jordan Barab addressed the audience :
o The intent behind the sections is to get public input and build them into a report for the President.

o The working group is still taking comments on the option paper , the Request for Information ( RFI ) revision, and the OSHA’s PSM standards modernization

. o Everything c an be reviewed at https://www.osha.gov/chemicalexecutiveorder/index.html on the Chemical Security Executive Order page.

o Reiterated that written comments are appreciated The last session in Newark is scheduled for n ext Thursday, February 27.

EO 13650 Public Listening Session Page 22 February 19, 2014 Baton Rouge, LAParticipant Analysis

Stakeholder Group 2/19 /2014 Baton Rouge, LA

Chemical Producer 2 Ag Supply 0 Chemical Storage 2 State/Local Regulator 0 First Responder 0 Media 2 Owner/Operator 1 Industry Association 3 Labor Organization 0 Federal Representative 5 Environment/Community 17 Consensus Organization 0 Other: 1 Citizen 2 Education 0

Security 1 Vendor 0 State/Local 1 Tribal 0 Health/Research 0 

## TOTAL (Attended In

- Person) 

## 37
Conference Call 55


## Attended (In

Person & Conf Call) 92

EO 13650 Public Listening Session Page 23 February 19, 2014 Baton Rouge, LA

## Executive Order 13650 Improving Chemical Facility Safety and Security **February 19**  **, 2014 Listening Session** Hosted by the Department of Homeland Security (DHS), the Environmental Protection Agency (EPA), and the Department of Labor (DoL) Location: Louisiana State Police Training Academy , 7901 Independence Blvd, Baton Rouge, LA 70806 

### Agenda 12:00 p.m.

– 1:00 p.m. Registration
1:00 p.m.

– 1:35 p.m. Welcome, Introductions, and Overview Patrick White, Facilitator Jordan Barab , OSHA, Executive Order 13650 Working Group Co

- Chair Deputy Assistant Secretary, Occupational Safety and Health Administration Mathy Stanislaus, EPA, Executive Order 13650 Working Group Co

- Chair Assistant Administrator, Office of Solid Waste and Emergency Response Dave Wulf , Department of H omeland Security (DHS), Office of Infrastructure Protection Matt Wren , Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) Overview Section 6a Lisa Long , OSHA
1:35 p.m.

– 1:50 p.m. Listening Session Format Patrick White, Facilitator
1:50 p.m.

– 5:00 p.m. Comments from Listening Session Participants
5:00 p.m.

– 6:00 p.m. BREAK
6:00 p.m.

– 6:20 p.m. EO Overview Jordan Barab , OSHA, Executive Order 13650 Working Group Co

- Chair Deputy Assistant Secretary, Occupational Safety and Healt h Administration Overview Section 6a Lisa Long , OSHA
6:20 p.m.

– 6:25 p.m. Listening Session Format Patrick White, Facilitator
6:25 p.m.

– 7:50 p.m. Comments from Listening Session Participants
7:50 p.m.

– 8:00 p.m. Closing Remarks Jordan Barab , OSHA, Executive Order 13650 Working Group Co

- Chair Deputy Assistant Secretary, Occupational Safety and Health Administration
8:00 p.m. Adjournment
Persons also may submit written comments to NPPD/ISCD/Mailstop 0610, Department of Homeland Security, 245 Murray Lane, SW, Arlington, VA 20598

- 0610. Comments will also be accepted by email at: EO.Chemical@hq.dhs.gov or through the Federal eRulemaking Portal at http://www .regulations.gov

. For more information on EO 13650, please visit https://www.osha.gov/chemicalexecutiveorder/index.html and https://www.dhs.gov/topic/chemical

- security

.