Recently, we offered tips on chemical
reporting for hazardous waste facilities. Today, we will take a look at a
possible new model for process safety management at refineries.
Every time a facility
explodes, we look for ways it could have been prevented. Well, in the wake of a
refinery explosion in Richmond, California, Cal/OSHA has proposed strict
process safety measures at oil refineries. We are taking a look at Cal/OSHA’s
proposal because it has been suggested that other states follow California’s
lead.
The draft proposal,
Process Safety Management for Oil Refineries (Refinery PSM), would apply only
to refineries and would apply to “all processes, operations and substances at
petroleum refineries that have the potential to cause serious physical harm or
a major incident.” In addition to proposing changes to existing PSM language,
the draft proposed Refinery PSM introduces new requirements in a number of
areas. We’ll take a look at some of the new requirements.
Damage Mechanism
Reviews (DMRs). New requirements for
DMRs would include:
- That recommended actions addressing hazards that could cause death or serious physical harm be corrected immediately or through interim measures pending permanent measures.
- Employers would be required to document all DMR recommended actions that are delayed beyond the timelines and communicate the rationale and new timeline to employees.
Hierarchy of Hazard
Control Analysis. Employers would be
required to perform a Hierarchy of Hazard Control Analysis (HCA) for all
process hazard analyses (PHA) recommended actions. All initial PHAs would have
to be completed within 3 years. New requirements for HCAs would include:
- An initial HCA as a standalone analysis would have to be done for all existing processes within 3 years and updated every 5 years.
- An HCA would also be required in the analysis and implementation of corrective actions from PHAs and when certain changes are proposed as part of a Management of Change review.
- All recommended actions that are delayed would have to be documented and include a plan for communicating why they were delayed and the new timeline to employees.
Management of Change
(MOC). The biggest change to
MOC procedures would be the requirement that employees participate in all MOCs
from the beginning of the MOC process through the implementation of the change.
Which brings us to…
Employee
Participation. One of the most
significant changes to the PSM procedures in the proposed Refinery PSM is the
emphasis on employee participation throughout the draft. Effective employee and
employee representative participation would be required at the earliest
possible point, throughout all phases of the development, training,
implementation, and maintenance of the PSM elements. In addition, employers
would be required to develop, implement, and maintain an effective Hazard
Reporting Program that ensures, at a minimum, the right of all employees,
including employees of contractors, to anonymously report hazards.
Human Factors. Employers would be required to take a
much more proactive stance with regard to human factors in the PSM program. When
addressing a task, they would now be required to account for staffing levels
and the length of time needed to complete the task. They would also have to
account for communication systems and the understandability and clarity of
operating and maintenance procedures.
In addition,
employers would be required to implement human factors controls on process
equipment and appurtenances as determined by the PHA, safeguard protection
analysis, or HCA, including but not limited to:
- Error-proof mechanisms;
- Automatic alerts; and
- Automatic system shutdowns for critical operational errors.
Safeguard Protection
Analysis (SPA). Employers would be
required to perform a written SPA for each process within 6 months of the
relevant PHA. The SPA must be completed within 90 days and must assess the
combined effectiveness of existing safeguards and safeguards recommended in a
PHA and HCA and whether additional or alternative inherent safety measures or
independent layers of protection may be needed.
Incident
Investigations. The proposed Refinery
PSM would significantly revise procedures for incident investigations.
Employers would be required to investigate and report any incident that is
major or potentially major. The definition of what constitutes a “major
incident” would be greatly expanded to include not only releases but also
events that cause community evacuation or shelter-in-place orders; and
unplanned releases of nontoxic or nonflammable materials, such as steam or
carbon dioxide; and certain events that trigger a pressure relief device to
discharge to the atmosphere. Part of the incident investigation includes a
requirement to perform a root cause analysis, which would include employees or
their representatives as part of the investigation team.
Compliance Audits. Refineries would be required to conduct
compliance audits every 3 years and certify that the facility is in compliance
with all the provisions of the Refinery PSM.
Process Safety
Culture Assessment (PSCA). Employers
would be required to develop and implement a PSCA that encourages the reporting
of safety concerns. The program would require the development of a written
report and action plan every 3 years.
PSM Management
System. Refineries would be
required to develop a written PSM Management System and review it annually. As
part of the PSM Management System, the refinery manager would be required to
track and document all changes to the PSM Program.