Understanding NJ TCPA for Effective Reactivity Management

The New Jersey Toxic Catastrophe Prevention Act (TCPA) has recently been amended to cover reactive chemicals and is the only regulation that requires as assessment of reactivity hazards and mitigation of associated risks. The Reactive Chemicals section of this regulation lists specific chemicals and functional groups along with corresponding threshold values that serve as trigger points for conducting reactive hazard assessments. This paper provides a simplified description of the Reactive Chemicals section of TCPA and associated compliance issues.

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 observe that over 50% involved chemicals not covered by existing OSHA Process Safety Management (PSM) or EPA Risk Management Program (RMP) requirements. As such, the CSB has recommended regulating reactive chemicals, which continues to be a controversial topic in the industry.