Comment from Rodriguez, Katherine; United Support and Memorial for Workplace Fatalities

The protection of employees in the oil and gas industry has proven necessary given recent workplace tragedies like the April 2010 Tesoro refinery blast that killed 7, the Deep water Horizon incident that killed 11 men and the 2005 BP Texas City refinery blast that killed 15 workers right down the street. I address you as the daughter of a worker killed at the same BP refinery in September 2004, six months before the massive explosion that killed 15. I realize that you are looking for “expert” comments on regulatory models from stakeholders, but I would venture to say that every family member of a worker in this industry, as well as any member of this community is considered a stakeholder. As a family member and member of this community, I am encouraged that you are seeking comment on various regulatory models. I am disappointed that you are not proposing changes to existing regulations. I applaud your effort to centralize the agencies efforts for addressing hazards to employees and the general public. As you discuss different regulatory models and the advantages and disadvantages, I wonder why the safety case approach is not mentioned in the federal register. As you know, the safety case approach is well known in the UK and Europe and not yet well known in the United States. Risks are understood and controls exist to manage a facility to a target such as “As Low As Reasonably Practicable”. At the National Academies Committee on Science, Technology and Law, Dr. David Michaels, Assistant Secretary of Labor stated “it might be prudent to adopt an approach to chemicals management that is drawn from the experience of the Department of Energy, which aims to keep exposures to radiation “as low as reasonably achievable” in an approach to safety goal setting. I hope some discussion on the safety case approach is considered to ensure that everyone in the workforce is able to come home to their families at the end of the workday. Thank you for this meeting.