In this edition of the Weekly Compliance Digest, we cover OSHA’s Process Safety Management standard for oil refineries and highlight common areas of non-compliance.
OSHA Process Safety Management for Petroleum Refineries
According to OSHA, since the promulgation of the Process Safety Management (PSM) standard in 1992, the petroleum refining industry has had more fatal or catastrophic incidents related to the release of highly hazardous chemicals (HHC) than any other sector. In June 2007, OSHA initiated the Petroleum Refinery Process Safety Management National Emphasis Program (NEP) to verify the compliance of refinery employers with PSM.
A few months ago, OSHA released the report “Process Safety Management for Petroleum Refineries”, which includes lessons learned and highlights areas of PSM where OSHA issued the most citations during the Petroleum Refinery PSM NEP.
After reviewing the citations issued for violations of the PSM standard, OSHA identified many common instances of non-compliance in the petroleum refinery industry. In this post, we highlight these common instances of non-compliance. Refineries should pay close attention to them to reduce risks of non-compliance with the PSM standard. Non-compliance instances and deficiencies are grouped by the five areas of the PSM standard where OSHA issued the most citations during the NEP.
Process Safety Information (PSI)
Employers must compile written process safety information (PSI), which must include information on the hazards of highly hazardous chemicals (HHC) used or produced by the process, information on the technology of the process, and information on the equipment in the process. In addition, all equipment in PSM-covered processes must comply with recognized and generally accepted good engineering practices (RAGAGEP). The PSM standard allows employers to select the RAGAGEP they apply in their covered processes.
Pay close attention to these elements that can lead to non-compliance:
- RAGAGEP:
- Lack of information about relief systems.
- Lack of documentation about facility siting RAGAGEP to control toxic and/or fire and explosion hazards in buildings and structures housing employees.
- Piping and Instrumentation Diagrams:
- Failure to maintain accurate, complete, and up-to-date P&IDs for the equipment in the process.
- Lack of documentation of relief system design and design basis.
Process Hazard Analysis (PHA)
A Process Hazard Analysis (PHA) helps to identify and analyze the significance of potential hazards associated with HHC. It must identify, evaluate, and control the hazards involved in the process. The PHA must be in writing and include:
- Any previous incident that had a likely potential for catastrophic consequences in the workplace.
- Engineering and administrative controls applicable to the hazards.
- Consequences of failure of engineering and administrative controls.
- Facility siting.
- Human factors.
- A qualitative evaluation of a range of the possible safety and health effects of failure of controls on employees in the workplace.
The PHA team may make recommendations for additional safeguards to adequately control hazards or to mitigate their effects.
Pay close attention to these potential deficiencies:
- Recommendation Resolution:
- Employers must “establish a system” to ensure that PHA team recommendations are promptly resolved. Failure to establish such a system was a leading cause of PHA citations.
- Systematic problems with multiple instances of failure to resolve findings and recommendations.
- Facility Siting:
- Lack of a facility siting analysis completely by the PHA team.
- No adequate evaluation whether temporary structures were properly sited.
- The most common facility siting citations involved permanent structures.
- Specific human factors issues that led to the following failures:
- Inadequate or unsafe accessibility to process controls during an emergency.
- A lack of clear emergency exit routes.
- Inadequate or confusing labeling on equipment, procedures, and/or P&IDs.
Operating Procedures
PSM-covered petroleum refineries must 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 on steps for normal operations, upset conditions, temporary operations, safe work practices, and emergency shutdown.
Pay close attention to these potential deficiencies, and elements that can lead to non-compliance:
- Emergency Shutdown Procedures:
- Failure to identify conditions that required emergency shutdown.
- Failure to designate appropriate personnel responsible for emergency shutdown procedures.
- Safe Work Practices – areas of deficiency:
- Controlling entry of motorized equipment into ignition source controlled areas.
- Controlling personnel access to process units.
- Line breaking and equipment opening practices.
- Hot work permitting.
- Lockout and tagout (LOTO) practices.
- Vehicle collision control.
- Housekeeping
Mechanical Integrity (MI)
Employers must 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. MI programs must address pressure vessels, storage tanks, piping systems, pumps, relief and vent systems and devices, emergency shutdown systems, and controls.
Pay close attention to these elements that can lead to non-compliance:
- Equipment Deficiencies:
- Failure to correct equipment deficiencies that are outside acceptable limits.
- Equipment most commonly cited for deficiencies were relief devices, followed by piping circuits, pressure vessels, and alarm systems.
- Inspection, Testing, and Maintenance Procedures:
- Complete lack of inspection and testing procedures.
- Inadequate or complete lack of inspection of covered process equipment.
- Inadequate written procedures.
- Most commonly cited types of equipment for non-compliant inspection or testing procedures were: piping circuits, pressure vessels, relief devices, and monitoring alarms.
- Resolving Anomalous Data:
- Failure to address inconsistencies in testing measurements.
- Ensure Proper “Site-Specific” Inspections and Tests:
- Inadequate site-specific inspection or test procedures leading to a failure to inspect or test equipment, or to inspect or test equipment inadequately.
Management of Change (MOC)
Employers must 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. The MOC procedure requires descriptions of the technical basis for the change, impact on safety and health, modifications to operating procedures, necessary time period for change, and appropriate authorizations. Employees impacted by the changes must be informed and trained appropriately.
Pay close attention to these elements that can lead to non-compliance:
- Failure to use an MOC when there was a change in equipment design.
- Failure to use an MOC when there was a change in operating procedures.
- Failure to use an MOC when there was a change in inspection and test and maintenance procedures.
- Facilities:
- Failure to initiate an MOC if an existing structure is being modified.
- Failure to create an MOC for newly installed facilities within or near a PSM-covered process.
- Excessive time limits for temporary changes:
- Failure to initiate MOCs when there were temporary changes (e.g. when using temporary supports during installation of a new vessel or piping circuit, or using a shed or break area as a temporary control room during construction or repair of the main control room).
- MOC procedures that fail to define or fail to adhere to the time limit of the temporary change.
Check out OSHA’s full report for more details and to learn more about recommendations that will help you comply with the PSM standard.
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