EHCMA Statement on Houston Chronicle Article

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Background for Houston Chronicle

As you are aware, the East Harris County Manufacturer’s Association (EHCMA) is a voluntary organization of approximately 130 refining and chemical facilities within the Houston Ship Channel. Numerous EHCMA member companies received the request for information from the Houston Chronicle, and so as an industry association, we are providing a collective view. EHCMA’s response is focused on sharing with the Houston Chronicle what our member companies all have in common – a determination to keep our employees, plants and communities safe through a series of programs and processes to identify and reduce risks in our daily operations. Until we have a better understanding of your complete risk methodology and how it’s being used, it is difficult to respond to whether your approach is valid or whether it is potentially misleading in instances where the volume of chemicals used in your formula substantially exceed actual inventories at our member company facilities. Statement by the East Harris County Manufacturer’s Association Nothing is more important to our industry than the safety of our employees, contractors, the people who live and work around our operations and our environment. That is why our industry proactively works with local and state officials as well as federal agencies to ensure we have practices and standards in place to safeguard our operations. Additionally, our member companies regularly meet with neighbors and public officials through community advisory panels and local planning committees. Through ongoing dialogue with our community, we recognize the expectation for transparency about our manufacturing processes, the chemicals we use and the products we make. Risk management plans are an important focus of ongoing dialogue with our communities and local response authorities. We emphasize plans that include robust policies, procedures and sophisticated safety systems to manage and control chemical products used at our facilities. Additionally, these plans outline coordinated emergency response for our industry with local response agencies and industrial mutual aid associations. Rigorous government regulations along with robust industry standards help ensure the safety and security of manufacturing facilities throughout our region. There are several federal and state agencies committed to

EHCMA’s response is focused on sharing with the Houston Chronicle what our member companies all have in common – a determination to keep our employees, plants and communities safe through a series of programs and processes to identify and reduce risks in our daily operations. Until we have a better understanding of your complete risk methodology and how it’s being used, it is difficult to respond to whether your approach is valid or whether it is potentially misleading in instances where the volume of chemicals used in your formula substantially exceed actual inventories at our member company facilities.

Statement by the East Harris County Manufacturer’s Association

Nothing is more important to our industry than the safety of our employees, contractors, the people who live and work around our operations and our environment.

That is why our industry proactively works with local and state officials as well as federal agencies to ensure we have practices and standards in place to safeguard our operations. Additionally, our member companies regularly meet with neighbors and public officials through community advisory panels and local planning committees.

Through ongoing dialogue with our community, we recognize the expectation for transparency about our manufacturing processes, the chemicals we use and the products we make. Risk management plans are an important focus of ongoing dialogue with our communities and local response authorities. We emphasize plans that include robust policies, procedures and sophisticated safety systems to manage and control chemical products used at our facilities. Additionally, these plans outline coordinated emergency response for our industry with local response agencies and industrial mutual aid associations.

Rigorous government regulations along with robust industry standards help ensure the safety and security of manufacturing facilities throughout our region. There are several federal and state agencies committed to regulate the safety and security of chemical facilities through a comprehensive array of regulatory programs.1

To help safeguard their workers and communities, member companies of all sizes develop Risk Management Plans that include hazard assessments and specific prevention programs, such as safety precautions, maintenance, monitoring and employee training measures. Industry also performs disaster review analyses that assess process features, equipment design, instrumentation, safety redundancies, operating procedures and other factors to minimize risk. All of these, along with extensive modeling, are reviewed prior to receiving permits to manage higher-risk chemicals. Our member companies also ensure they have the right emergency preparedness and response capabilities in place along with procedures for informing the public and response agencies.

In addition to supporting the chemical safety laws and regulations in place, our member companies utilize comprehensive process safety management systems, procedures and operating practices that are designed to achieve, sustain and continuously improve operating safety. Member companies regularly share safety and security best practices and continually assess the hazards and risks associated with their operations, the loading and unloading of products and storage of chemicals onsite.

Working in our industry, there are thousands of employees who are dedicated to safety, security and environmental compliance. Our facilities utilize state-of-the-art technologies along with highly skilled and trained employees to operate safely without impact to our communities. We understand that the public wants to have confidence that our industry is operating responsibly, which is why we have multiple layers of safety protection in place to address potential safety risks. 2 Assessing the risks without factoring in these safeguards is similar to assessing the risks of driving a car without factoring in speed, seat belts, anti-lock brakes, safety glass and other car safety improvements. We dedicate a tremendous amount of time and resources to safely and effectively manage risk, as we deliver products that enable modern living.

1 Agencies regulating our industry include the U.S. Environmental Protection Agency (EPA), U.S. Occupational Safety and Health Administration (OSHA), Department of Homeland Security (DHS), U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA), Texas Commission on Environmental Quality (TCEQ), Texas Department of State Health Service (TDSHS) and Texas Department of Transportation (TXDOT) among others.

2 Examples of Common Preventative Measures

  • Operator and maintenance craft training
  • Vessel, piping and other safety critical equipment programs
  • Overpressure protection (Pressure Safety Valves)
  • Equipment strategies for preventative maintenance
  • Emergency isolation valves
  • Hazard and operability studies to identify potential risk associated with the operation of the equipment
  • Corporate design standards and practices
  • Emergency procedures and drills
  • Warning systems (onsite and community)
  • Gas fire, and smoke detection and alarm systems (individual and within facilities)
  • Emergency preparedness plans
  • Fire prevention systems
  • Emergency response teams and equipment (onsite and mutual aids)