I’m writing right now to emphasize how important it is to you, your staff, and your company that your facility complies with all relevant Occupational Security and Well being Administration (OSHA) requirements, particularly with 29 Code of Federal Regulations (CFR) 1910.119 聳 Process Security Administration of Extremely Hazardous Chemicals (PSM). Outcomes from OSHA’s ongoing Petroleum Refinery Course of Security Management Nationwide Emphasis Program (NEP), described beneath, combined with the industry’s historical past of severe accidents, underscore the need for you to ensure that the PSM packages at your facility are totally compliant with the requirements of 搂1910.119.
In the last fifteen years, the petroleum refining industry (Commonplace Industrial Code (SIC) 2911, North American Industry Classification System (NAICS) 32411) has had more fatal or catastrophic incidents related to the discharge of highly hazardous chemicals (HHCs) than any other business sector coated by the PSM normal. Due to this, in 2007 OSHA initiated its refinery NEP to tremendously scale back or eliminate the office hazards related to the catastrophic release of HHCs at petroleum refineries. In the primary 12 months of the NEP, OSHA inspection groups completed inspections and issued citations at 14 refineries in 6 of OSHA’s 10 regions. A complete of 348 PSM citations, together with proposed penalties, have been issued. These citations reflect the serious PSM compliance points now we have discovered at many refineries. We are significantly concerned that our inspection groups are seeing many of the same problems repeatedly, and that these embrace violations of provisions such as 1910.119(e)(5), (j)(2), and (j)(5), that are designed to ensure that deficiencies in important process tools are recognized and corrected promptly.
These are the varieties of problems that have led to earlier fatality / catastrophe incidents involving HHCs in refineries. Latest incidents include a large explosion and fireplace in Texas Metropolis, TX, on March 23, 2005, that killed 15 workers and injured 170, in addition to a large LPG launch and subsequent explosion and hearth in Big Spring, TX, on February 18, 2008, and a release and fireplace near Dumas, TX, on February sixteen, 2007. Beforehand, a January 19, 2005, refinery incident killed one employee and injured others in Bakersfield, CA, when a pump ruptured, causing a severe hearth. One other incident at a refinery near Gallup, NM, on April eight, 2004, injured six workers when a release occurred throughout pump maintenance in the refinery’s HF Alkylation unit.
These serious incidents reinforce the necessity for vigilant compliance with OSHA requirements, notably the PSM commonplace, which requires employers to develop comprehensive, site specific, built-in safety administration methods to scale back the dangers of incidents involving HHCs. Paragraphs c through p of the PSM normal describe the required components of those applications. The table below lists these parts by their paragraph designations in the usual (excluding paragraphs (a), Application, and (b), Definitions).
Paragraph PSM Program Factor Paragraph PSM Program Factor
c Employee Participation j Mechanical Integrity
d Process Security Information ok Sizzling Work Permit
e Course of Hazard Analysis l Management of Change
f Operating Procedures m Incident Investigation
g Training n Emergency Planning & Response
h Contractors o Compliance Audits
i Pre-startup Overview p Commerce Secrets
Conscientious compliance with the PSM customary will scale back the chance of an incident involving HHCs. To help you in your compliance efforts, we recommend that you simply evaluation the refinery NEP, which is posted at: http://www.osha.gov/OshDoc/Directive_pdf/CPL_03-00-010.pdf.
We additionally refer you to attachment A, which summarizes the results of the primary 14 NEP inspections. Considerably, as proven in Determine 1 of the attachment, nearly 80% of the violations found associated to paragraphs (f) Operating Procedures, (j) Mechanical Integrity, (e) Course of Hazard Analysis, (d) Process Safety Data, and (l) Administration of Change, of the usual. And, as proven in Determine 2, greater than 50% of all violations were of simply 18 specific necessities, that are listed underneath that figure.
As well as, attachment B to this letter comprises abstracts of a representative pattern of the citations proposed within the 14 inspections. You need to consider these when reviewing the currentstatus of the process safety management program at your facility.
OSHA is out there to offer help to companies dealing with all varieties of safety and well being hazards. Additionally, companies participating in OSHA’s Voluntary Protection Program (VPP) have entry to a variety of compliance assistance tools.
Finally, as you might know, OSHA intends to examine all U.S. refineries topic to Federal OSHA jurisdiction and never within the VPP below this NEP. Moreover, OSHA has strongly encouraged State Plan states with refineries to adopt this NEP, and the overwhelming majority of them have achieved so. Because of this, your refinery may have already been inspected, may at present be undergoing inspection, or can anticipate being inspected in the close to future below this NEP.
If you have any additional questions, please call OSHA’s Office of Normal Industry Enforcement at 202-693-1850, or your State Plan or state session program. Data on each is available at www.osha.gov.
