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This decision covers several interesting items and sets a HUGE precedent for RESPONSIBILITY of PHA and Audit items from the PREVIOUS owners PHAs and Audits.  The decision CONFIRMED that "utilities" within the process, in this case a "positive pressure unit" on a control room ventilation system, is a piece of COVERED EQUIPMENT.  It also establishes minimums for when an employer uses "alternatives" to labeling each container of hazardous chemicals, being that the said containers were process vessels.  The commission vacated two citations, which the machine guarding item involving an unguarded horizontal merely because OSHA could not show "exposure to the hazard" and an MOC citation since the use of steam lances was a "common occurrence at the refinery".  The item regarding the PHA and Audit items from a previous employer/owner could be a HUGE precedent for future sales of facilities that have covered processes.  Here is the case...

tank and bollardsMost everyone has seen a bollard; they may have not realized what they were seeing at the time, but most have seen one.  But this group of people who have seen one grows much smaller when we begin to ask “what makes a bollard a safety device?”  A couple of years ago I shared an engineering standard for bollards and vehicle protection.  That page has been viewed more than 200,000 times since 2012, so there must be some level of interest in these safety devices.  I lost count of the number of e-mails I received asking if the post was a “joke”, as who in their right mind would have an engineering design for a post?!?!  Well a well designed, constructed, chemical process that utilizes mobile equipment within their process battery limits… that's who!  Just last year we issued several audit findings for either the lack of or improper design of bollards protecting bulk tanks and other "critical" process equipment.  These were PSM audits… so what RAGAGEP did we reference?

This is not the first time I have "beat up" on excess flow valves and the reliance on them as a "safeguard" in a PHA or process design.  Both EPA and OSHA are on record stating their displeasure of claiming these valves as a safe guard.  Now don't get me wrong, these devices WORK and WORK WELL when they are DESIGNED, INSTALLED, TESTED, and MAINTAINED per the manufacturer's requirements... and here lies the problem.  These valves MUST be included in the PSI - Safety Systems with the engineering (i.e. sizing) documentation, as well as reside in the MI program for inspection and testing.  Here is some language from one of the top manufacturer of these safety valves and we can see that these valves require a LOT of attention, which many facilities are lacking...

Christine Baker, Director of the Department of Industrial Relations (DIR), has submitted a legislatively-mandated status report on DIR and Cal/OSHA's Process Safety Management (PSM) Regulatory Oversight. The report is required pursuant to the Budget Act of 2014 (Provisions 1 and 2 of item 7350-001-3121, Chapter 25, Statutes of 2014). A new assessment on the state's oil refineries, implemented by DIR in 2013, requires refineries to provide funding support to DIR for Cal/OSHA's PSM refinery program. The funds, which are independent of the state's General Fund, have allowed DIR to expand the PSM staff from 10 positions in 2012 to 26 positions and supported eleven weeks of advanced technical training for the refinery inspectors. Cal/OSHA's PSM Unit is responsible for inspecting refineries and chemical plants that handle large quantities of toxic and flammable materials. Health and safety standards enforced by the PSM Unit, including adequate employee training, are intended to prevent catastrophic explosions, fires, and releases of dangerous chemicals. 

I am working on getting all of these RMP NOVs posted but found this one especially interesting...

XXXXXXXXXX did not address the impact of the lock-out of the factory workers in August 2011 and hiring all new replacement workers.  Such extensive staffing changes could impact the safety and health of the XXXXX workers and should be included in the MOC review process. Center for Chemical Process Safety (CCPS) Guidelines for Management of Change for Process Safety section 3.4.2 Types of Changes to Be Managed include organizational and staffing changes.

So you have been "warned", now both OSHA and EPA are on record for issuing citations against staffing changes without the aid of an MOC.

CLICK HERE to see all the citations

 
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