Good engineering practice of updating standards
The responses summarize lessons learned from CSB accident investigations over the course of CSB's history.
In response to OSHA's RFI on PSM, the CSB recommended that OSHA: For more information, read the full CSB response to OSHA's Request for Information on revisions to the PSM Standard.
My passion is for testing, as I believe that good testing practices can both ensure a minimum quality standard (sadly lacking in many software products), and can guide and shape development itself.
It is also criticized that Annex 15 has a "tutorial tone".
This is the result of the adoption of contents from the PIC/S document PR 1/99-1.
In response to EPA's RFI for RMP, in addition to PSM program related enhancements mentioned above, the CSB recommended that EPA: For more information, read the full CSB response to EPA's Request for Information on revisions to the RMP Regulation.
In the Spring 2015 regulatory agenda released in May 2015, EPA projected that a Notice of Proposed Rulemaking (NPRM) for revisions to RMP would be published in September 2015, however, EPA has yet to publish a Proposed Rule, though it has initiated a Small Business Advocacy Review (SBAR).