From Chemical Incident Recommendations to Actionable Safety Practices: A Pilot Coding Framework Applied to Three U.S. Chemical Safety Board Investigations

Abstract Chemical incident investigations offer lessons for prevention, but case-specific narratives can hinder cross-case retrieval and application. This methodological pilot develops a traceable coding framework for translating U.S. Chemical Safety and Hazard Investigation Board (CSB) recommendations into actionable safety practices while recording the obligation status separately. The framework was applied to 21 recommendations from three purposely selected investigations: Aghorn Operating, Bio-Lab Lake Charles, and Cuisine Solutions. Each recommendation was linked to its event scenario, control deficit, safety functions, safety issue categories, hierarchy or institutional action level, derived practice, and proposed verification evidence. Fifteen recommendations were company-directed, and six addressed regulators or standards organizations. Derived outputs comprised ten CSB-recommended voluntary practices, four voluntary practices with regulatory components, three institutional communication or policy actions, two proposed consensus-standard revisions, one proposed regulatory requirement, and one binding requirement with an explicit applicability condition. Original wording, recipient, recommendation status, and accepted alternative actions remain traceable, making the interpretation from the source evidence to derived practice explicit. Proposed verification evidence identifies what could be examined to assess implementation; it does not establish that a practice has been implemented. The framework supports cross-case retrieval and context-specific review without treating CSB recommendations as being automatically mandatory.