Understanding NJ TCPA for Effective Reactivity Management

Based on previous incident investigations, the U.S. Chemical Safety and Hazard Investigation Board (CSB) has concluded that reactive hazards pose a serious challenge to the Chemical Process Industry (CPI). Of the 167 uncontrolled chemical reactivity incidents reported between January 1980 and June 2001, CSB findings indicate that over 50% of chemicals involved in the incidents were not covered by existing OSHA Process Safety Management (PSM) or EPA Risk Management Program (RMP) requirements. Based on their analysis, the CSB has recommended regulating reactive chemicals, which continues to be a focus of debate in the manufacturing industry.

The New Jersey Department of Environmental Protection (DEP) has taken the first step towards regulating reactive chemicals by extending its Toxic Catastrophe Prevention Act (TCPA) to include reactive chemicals. Approximately forty companies would likely be required to comply with the amended TCPA regulations, which will cover thirty reactive
hazardous substances and forty-three chemical groups. Another amendment to the TCPA standard requires covered facilities to assess technologies every five years that can help alleviate potential risks and if feasible, implement such technologies.

Industry officials have warned that regulations pertaining to reactive chemicals, such as the new TCPA requirements, will be highly taxing on the industry, specifically for smaller manufacturers. This paper provides a simplified description of the Reactive Chemicals section of TCPA and associated compliance issues.

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