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PLEASE NOTE that this citation is SIGNIFICANT in that OSHA took issue with how Operating Procedures were controlled/revised/managed!  OSHA found operators using three (3) different revisions for the same task that caused the release.  Document control records had odd dates as well.  A "document control" system is NOT a PSM (or RMP) requirement, BUT we MUST ensure that personnel are using the most recent APPROVED SOP!!!

A Washington state refinery is facing $77,000 in fines from the state Department of Labor & Industries (L&I) for workplace health violations after an investigation into an uncontrolled toxic release last February. L&I began the investigation at the refinery after learning of an incident during which the refinery's main flare released contaminants into the environment. The release prompted numerous odor complaints from the community nearby.  The investigation found that the company had skipped critical decontamination steps while shutting down the main flare for routine maintenance. Failing to implement safe work practices caused an uncontrolled release that exposed workers to toxic substances including mercaptans, hydrogen sulfide, hydrocarbons and pyrophoric iron. The company was also cited in 2013 for skipping critical steps when shutting down the flare. In that case, there was an explosion that nearly injured several contractors and Shell employees. For the recent incident, the refinery was cited for one willful violation and fined the maximum of $70,000 for knowingly and intentionally not following safe work practices for the control of hazards when shutting down the flare. The company was also cited for one serious violation with a penalty of $7,000 for giving workers the incorrect procedure for shutting down the flare.  Here is a breakdown of the two (2) citations and a copy of the citations:

This is another example of a change to our process that may not require a wrench to complete, but it is my opinion, as well as now the National Board's, that changing the service of a pressure vessel is indeed a change that should undergo a MOC.  The National Board Inspection Code (NBIC) Part 2, SUPPLEMENT 9, REQUIREMENTS FOR CHANGE OF SERVICE offers a very much needed insight into all that should be considered when changing the service of a pressure vessel.  AND for those who purchase USED pressure vessels with a KNOWN HISTORY and your usage would be a "change in service", you too should consider these items/requirements for your change in service.

I have written about this topic several times, but in reading the newest edition (2015) of NATIONAL BOARD INSPECTION CODE I came across some actual language that must be considered when establishing our Safe Upper Design Limits for our pressure vessels.  I feel like I must state the obivious once again - a relief valve is NOT a pressure control valve!  It should ONLY lift as a LAST RESORT to protect the vessel from being over pressurized.  Any time we have an event where a RV has lifted, it MUST BE investigated as a serious incident!  I have highlighted the language that is most critical...

California is looking to REVISE their CalARP regulation with an additional "Program Level" specific to petroleum refineries.  This is coming from Interagency Working Group on Refinery Safety and they are proposing to form a new Article 6.5 Program 4.   Program 4 eligibility requirements are...

These proposed CalARP emergency response program amendments are intended to apply ONLY to petroleum refineries, and incorporate recommendations from the Report of the Interagency Working Group on Refinery Safety.

The Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) (EPA/OSHA) issue this Chemical Safety Alert as part of an ongoing federal effort to improve chemical risk management, advance safety and protect human health and the environment.1 Recent catastrophic chemical facility incidents in the United States prompted the President to issue Executive Order (EO) 13650 - Improving Chemical Facility Safety and Security on August 1, 2013. Feedback from industry, workers, community members and environmental organizations emphasized the benefits of implementing safer technologies, including those, where possible, that are inherently safer, as part of an integrated approach to reducing risks associated with hazardous chemicals.

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