The U.S. Occupational Safety and Health Administration (OSHA) recently released a new guide to help petroleum refiners comply with its Process Safety Management (PSM) standard (1910.119). “Since the PSM standard was promulgated by OSHA in 1992, no other industry sector has had as many fatal or catastrophic incidents related to the release of highly hazardous chemicals (HHC) as the petroleum refining industry,” the document states.
In an effort to reduce these incidents, OSHA introduced the National Emphasis Program (NEP) in 2007, which was designed to verify whether refinery operators were maintaining PSM compliance. After reviewing the citations issued for violations of the PSM standard under the NEP, OSHA has discovered several common instances of non-compliance in the petroleum refinery industry, including many related to the following 5 areas:
Process Safety Information
Under the PSM standard, employers are required to compile written process safety information (PSI). The compilation of written process safety information enables the employer and the employees involved in operating the process to identify and understand the hazards posed. During inspections under the NEP, OSHA issued many citations for violations of the PSM standard related to the (1) RAGAGEP, (2) piping & instrumentation diagrams (P&IDs), and (3) relief system design basis.
Process Hazard Analysis
A process hazard analysis (PHA) is an organized and systematic effort to identify and analyze the significance of potential hazards associated with the processing and handling of HHC. The PHA must be appropriate to the complexity of the process and must identify, evaluate, and control the hazards involved in the process. During NEP inspections, OSHA frequently found PHA deficiencies in (1) recommendation resolution, (2) facility siting, and (3) human factors analyses.
PSM-covered petroleum refineries are required to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information. Operating procedures must provide clear instructions not only to specify the steps for normal operations, but also for upset conditions, temporary operations, safe work practices, and emergency shutdown. During NEP inspections, many operating procedures citations resulted from a complete absence of written operating procedures. Even when operating procedures existed, OSHA found that they were not always accurate or implemented as written.
The Mechanical Integrity (MI) element of the PSM standard requires employers to create written procedures to maintain the ongoing integrity of process equipment, train for process maintenance activities, inspect and test process equipment, correct equipment deficiencies, and perform quality assurance. During NEP inspections, OSHA frequently found MI compliance issues, including (1) equipment deficiencies, (2) inspection, testing, and maintenance procedures, (3) resolving anomalous data, and (4) ensuring site-specific inspection and testing.
Management of Change
The Management of Change (MOC) section of the PSM standard requires the employer to implement written procedures to manage changes (except for “replacements in kind”) to process chemicals, technology, equipment, procedures, and changes to facilities that affect a covered process. During NEP inspections, OSHA commonly found MOC non-compliance for changes in (1) equipment design, (2) operating procedure, (3) regular maintenance/repair, (4) facilities, and (5) excessive time limits for temporary changes.
OSHA recommends all petroleum refineries review these common instances of non-compliance to ensure that they do not exist within their own PSM programs.
Source: blog by Jeremiah Wooten at Inspectioneering, LLC.. September 13, 2017