“Defunding the CSB is just plain stupid.”  -Mark Rosenzweig, Editor-in-Chief, Chemical Processing

It has been a month since the administration announced a list of 19 independent federal agencies that it wants to completely defund in the 2018 budget.  Tucked in among the regional economic development agencies and the agencies that support the arts and humanities was the Chemical Safety Board.

Each of these agencies has a dedicated constituency, citizens who are convinced that the agency does immeasurable good and is worth every penny spent on it.  Many of these agencies, however, are opposed by people who sincerely believe the world would be better off without them.  The Corporation for Public Broadcasting, the National Endowment for the Arts, and the National Endowment for the Humanities especially attract a kind of venom that makes me blush.

How did the Chemical Safety Board get on this list?

The CSB is a Bargain

Here’s a gross generalization:  engineers, by and large, are a conservative bunch that like standards and specifications, but dislike regulations and other forms of government interference with how they do their jobs.

The CSB, however, does not make regulations and it does not enforce regulations.  It simply investigates chemical catastrophes in an effort to understand why they happened, makes whatever recommendations are necessary to make reduce the likelihood of reoccurrence, and works diligently to educate all parties about making the chemical industry safer.

Every engineer with an opinion (and what engineer doesn’t have an opinion) that I have talked to is convinced that the Chemical Safety Board is essential to improving the safety of chemical operations in the United States, and by virtue of example, the rest of the world.  Moreover, when they learn what the CSB’s budget is, they are astonished.  “Wow!  What a bargain!”

It’s All Up There On the Screen

The annual budget for the CSB is $12 million.  As one wag put it, that’s less than four presidential trips to the southern White House at Mar-a-Lago.  If the work the CSB does each year prevents only one additional catastrophic event in the future, one quickly concludes that the CSB gives an incredible return on investment.

The annual budget for the National Transportation Safety Board, the agency on which the CSB is modeled, is a little over $100 million.

Many years ago, I read the review of a summer blockbuster movie that had just come out.  The critic commented on how expensive the movie had been to make and then added, “But it’s all up there on the screen.”  That struck me as very high praise.  The annual budget for the CSB doesn’t even approach that of a blockbuster movie, but I can say, “It’s all up there on the screen.”  The videos that the CSB produces about the disasters they have investigated alone are worth the price of admission.

Who Thought This Was a Good Idea?

The question that haunts me is this:  Who thought that getting rid of the federal agency responsible for investigating catastrophes in the chemical industry was a good idea?  I’ve checked.  It’s certainly not process safety professionals, neither those that work in or those that work for the chemical industry. It’s not chemical industry workers.  It’s not the chemical industry itself.  It’s not public interest groups or the public in general (at least once they understand what the CSB does.)

Then who?

I’ve searched.  Conservative outlets, while enthusiastic at ridding the country of government-sponsored arts groups, are silent on the subject of the CSB.  Their commentaries never address the specific point of defunding the CSB.  Understanding the causes of chemical catastrophes and preventing the reoccurrence of similar disasters is apparently a non-partisan issue.

I Could Tell You But Then I’d Have to Kill You

There are some who have argued that while there is clearly a need for investigations into chemical catastrophes, these investigations don’t need to be done by a federal agency.  They suggest that an industry group should do this, something like the Center for Chemical Process Safety.

There are some problems with this.  First, the obvious.  Industry groups are sponsored.  When the economy softens and sponsors are looking to cut costs, sponsorships are one of the first to go.  The sponsored organizations know this, and cater to their sponsors even when the economy is strong and sponsorships easy to pick up.

Secondly, sponsored organizations have a generally bad record of investigating their sponsors.  The CCPS predated the CSB by 13 years and yet it didn’t conduct investigations.  Partly, that is because the CCPS, like all privately funded organizations, depends on its donors and their goodwill.  The sponsors of CCPS had a specific agenda: tell us how to do process safety, but tell us without pointing fingers.  It’s not an evil agenda, but it’s not the agenda of the CSB.

Thirdly, sponsors do not want their dirty laundry aired in public.  Practices, policies, and procedures can be sanitized, the findings can be generalized.  Every person who has ever volunteered on a committee has heard, “This can’t leave the room.  Our lawyers don’t want us to talk about this and require that this information only be revealed confidentially.”  A chemical catastrophe, on the other hand, is completely identifiable.  There is no hiding from an investigation.  Witness cannot say, “I could tell you, but then I’d have to kill you.”

Finally, the constituency for investigations of chemical catastrophes does not consist exclusively of the industry itself.  Workers, researchers, academics, regulators, and the public all have a legitimate interest in the findings. For investigations to do any good, they have to be good investigations.  Just as importantly, everyone with an interest has to believe that they are good investigations.  Right or wrong, any investigation, no matter how well done, will be tainted if it is not conducted by a truly independent party.

We Need the CSB

Like independent layers of protection, chemical catastrophe investigations need to be effective, independent, and auditable.  The CSB provides that.  To scrap the CSB would not eliminate the need—it would just shift the burden to a new entity.  In the mean time, disasters would go uninvestigated, or if investigated, investigations would be undisclosed or disbelieved.  We need the CSB.

Make Your Voice Heard

The proposed budget is not the final budget.  Congress has to pass a budget and there is a lot of movement between where it starts and where it ends up.  This means that there is a lot of opportunity for individual citizens to influence individual line items in the budget.  It does no good for you to complain to your co-workers.  It is your representatives in Congress that need to hear from you, your Congressman and your Senators.

I’ve said this before, but it bears repeating:  Contact your legislators.  They need to see this as more than a flash in the pan, a passing fancy.  Send a well-reasoned explanation of what you would like to see them do, and why.  Don’t send a rant. Don’t send a form letter; form letters are typically dismissed or lumped together as a single comment. Also, don’t stray to other topics.  It makes it hard for staffers to keep a tally.  It doesn’t take very many letters, calls, or e-mails with “unique content” to represent a flood of interest in the eyes of a legislator.  Make yours understand how important the CSB is to your safety and the safety of our entire industry.