In June 2007, the Occupational Safety and Health Administration (OSHA) initiated the Petroleum Refinery Process Safety Management National Emphasis Program (NEP). The purpose of the NEP was to confirm employers' compliance with Process Safety Management (PSM). This initiative stemmed from the multiple fatal or catastrophic incidents related to the release of highly hazardous chemicals (HHC) in the petroleum refining industry.
Following review of the citations issued for violations of the PSM standard under the NEP, OSHA identified a number of common non-compliance areas across the industry. The lessons learned were published by OSHA in 2017 (OSHA 3918 Publication). The most citations issued during the Petroleum Refinery Process Safety Management National Emphasis Program (NEP) are highlighted below:
- Process Safety Information (PSI)
- Employers' written PSI did not contain information about Relief Systems RAGAGEP or Relief System Design and Design Basis documentation
- Petroleum refineries did not document facility-siting RAGAGEP to control toxic and/or fire and explosion hazards in buildings and structures housing employees
- Many petroleum refineries failed to maintain accurate, complete, and up-to-date P&IDs for the equipment in the process
- Process Hazard Analysis (PHA)
- PHA deficiencies: (1) recommendation resolution, (2) facility siting, and (3) human factors analyses
- Operating Procedures
- Many operating procedures citations resulted from a complete absence of written operating procedures
- Even when operating procedures existed, they were not always accurate or implemented as written
- Emergency shutdown procedures did not identify conditions that would require an emergency shutdown and did not designate appropriate personnel for those tasks
- Petroleum refineries did not have sufficient safe work practices such as Hot Work permitting including control of motorized vehicles into process areas, lock-out and tag-out, line break and equipment opening
- Mechanical Integrity (MI)
- MI compliance issues include: (1) equipment deficiencies, (2) inspection, testing, and maintenance procedures, (3) resolving anomalous data by retesting not discarding test data, and (4) ensuring site-specific inspection and testing
- Management of Change (MOC)
- 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
If your organization requires a PSM Program health check, Trinity Consultants offers a wide range of PSM compliance services to meet your organization's needs including PSM Program Implementation, Process Hazard Analysis (PHA), Compliance Audits, Gap Assessments, and Training.
For immediate assistance with PSM Program support, please contact us at (800) 229-6655.
For more details on OSHA's Lessons Learned from the Petroleum Refinery PSM National Emphasis Program, please reference the OSHA 3918 Publication.