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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.
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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.
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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.