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  • http://www.bp.com/genericarticle.do?categoryId=2012968&contentId=7012963
  • http://www.publicintegrity.org/articles/entry/2085/
  • MEMORANDUM FOR: Regional Administrators FROM: John B. Miles, Jr. Director Directorate of Compliance Programs Subject: Coverage of Stored Flammables Under the Process Safety Management Standard In a recent decision, 1 the judge ruled that coverage under OSHA's Process Safety Management Standard (1910.119) does not extend to stored flammables in "atmospheric tanks," even if they were connected to a "process" within the definition of the standard. This is contrary to consistent OSHA interpretations of the standard. However, the decision will not be appealed because it is based on problems in the text of the standard itself, which support the judge's decision. We have asked the Directorate of Safety Standards Programs to consider developing amendments to the standard which would clearly state our intention to cover flammables stored in atmospheric tanks when they are connected to a covered process, or when they are located such that there is a reasonable probability that they could be involved in the release of a covered highly hazardous chemical. Until the standard is revised, however, OSHA will abide by the Meer decision, and will not cite 1910.119 under circumstances when coverage of the process would be based partly or solely on the quantity of flammable liquid in connected atmospheric storage tanks, that would otherwise qualify for the 1910.119(a)(1)(ii)(B) exemption. Citations under 1910.119 will continue to be issued when the quantity of flammables in the process, not counting atmospheric storage, exceeds 10,000 pounds, or where the quantities in storage do not fall within the exception for other reasons (i.e. storage not atmospheric, storage relies on refrigeration, quantities not actually in storage). Citations for 1910.106 may apply to situations where flammable liquids are stored. In other cases where stored flammable liquids subject to the exemption are connected to a process, and a documentable hazard exists which involves a serious risk to workers, 5(a)(1) citations may be issued. Since such citations will in all likelihood be litigated, early involvement of the Solicitor in such cases is mandatory, to ensure that the basis for citation has legal clearance. Employers inquiring about coverage of stored flammables under PSM should be informed that OSHA is following the decision in Meer , pending possible revisions to the standard to resolve the ambiguity, but that citations may be issued under 5(a)(1) if circumstances warrant. For further information, contact the Office of General Industry Compliance Assistance (Ray Donnelly or Alcmene Haloftis on 202-219-8041 or Mike Marshall on 202-219-8118, x112). This memorandum should be filed with CPL 2-2.45 . Process Safety Management. 1 Secretary of Labor v. Meer Corporation, OSHRC Docket No. 95-0341
  • During the night a valve had to be changed on a unit which handled a mixture of acids. The fitter could not find a suitable valve in the workshop but on looking around he found one on another unit. He tested it with a magnet and finding it to be nonmagnetic he assumed it was similar to the stainless steel valves normally used. He therefore installed it. Four days later the valve was badly corroded and there was a spillage of acids. The valve was made of Hastalloy, an alloy suitable for use on the unit where it was found, but not suitable for use with the mixture of acids of the unit on which it had been installed.

Transcript

  • 1. PSM, VPP and 2010 (moment in time) June 3, 2010 John Newquist, MS, CSP, CFI Assistant Regional Administrator
  • 2. Moment in Time
    • These are a snapshot of issues in the last months.
    • The next 12 months could be different.
  • 3. New Leadership
    • Secretary of Labor – Hilda L. Solis
      • Assistant Secretary (OSHA)
        • Dr. David Michaels
      • Deputy Assistant Secretary (OSHA)
      • Jordan Barab
      • Deputy Assistant Secretary (OSHA)
      • Richard Fairfax
      • Chief of Staff (OSHA)
        • Deborah Berkowitz
  • 4. Process Safety Management
    • Bhopal (’84): focused OSHA’s attention
    • Institute, WV(’85): shows disasters can happen here = CHEMSEP
    • 1988-91: concern of public & Congress increases w each event = PETROSEP
    • Feb. 24, 1992: standard in Federal Register
  • 5. Ghost of PSM past
            • Deaths Injuries
    • 1984 Mexico City 650 --
    • 1984 Bhopal, India 2500 --
    • 1984 Union Oil, IL 17
    • 1988 Norco, LA 7 42
    • 1989 Morris, IL 2 18
    • 1989 Pasadena, TX 23 130
    • 1990 Houston, TX 17 --
    • 1990 Cincinnati, OH 2 72
    • 1991 Lake Charles, LA 5 --
    • 1991 Sterlington, LA 8 120
    • 2005 Texas 15 170
    • 2010 WA 7 ?
  • 6. State Plans
    • Over a dozen refineries not received comprehensive PSM inspection
    • Are States going to inspect under the CHEMSEP?
    • Dr. Michael letter to States in May 2010
  • 7. Incentives
    • Some companies have only one criteria for safety incentive bonus….
    • The OSHA Lost time rates
    • Disincentives exist in some facilities that discourage proper recording of accidents
  • 8. Mea Culpa
    • “ Over the years, the working environment had eroded to one characterized by resistance to change, and lacking of trust, motivation, and a sense of purpose. Coupled with unclear expectations around supervisory and management behaviors this meant that rules were not consistently followed, rigor was lacking and individuals felt disempowered from suggesting or initiating improvements.”
  • 9. May 17 2010
    • The only thing you can conclude is that BP has a serious, systemic safety problem in their company,” Barab said.
    • The head of OSHA, David Michaels, said the safety problems aren’t limited to BP. “We are very concerned about the commitment of the refining industry to worker health and safety,” he said.
  • 10. Significant Enforcement
    • BP Texas – Oct 2009 $87M
    • BP Ohio – 42, Willful, 20 Serious, $3M
    • NDK – 500K, 7 Willful 5a1
    • Repeat OSHA Findings across corporations
    • If not PSM, then OSHA stds, 5a1 – ASHRAE, NFPA, CCPS etc…
  • 11. VPP Issue #1
    • What! I am covered?
    • Flammables
    • Ammonia
    • Explosives
    • “ I meet the MEER decision” (Then what is your work on the tanks and pipe? Hot works? Line Breaking? Leaks? )
  • 12. 1996 Court Case - MEER Decision
    • Flammable liquid storage tank exemption
    Judge ruled - flammable liquids stored or transferred from atmospheric tanks are exempted regardless of quantity 1910.106 and the “General Duty Clause” is used to regulate stored flammables In a 1996 court decision, the judge ruled that coverage under OSHA's Process Safety Management Standard does not extend to stored flammables in "atmospheric tanks," even if they were connected to a "process" within the definition of the standard.
  • 13. MEER Decision Process * Exemption if atmospheric tanks is used solely for storage * Process is covered if it involves 10,000 pounds or more of flammable liquid Flammable Storage Tank Flammable Liquid Storage Tank & Unit Operation Flammable Liquid Atmosphere Storage Tank with Flammable Gas Blanket * No exemption as the atmosphere tanks are used for purposes beyond storage
  • 14. Contractors #2
    • What? The host facility is responsible for all that PSM!
    • The contract employer shall…
    • assure that each contract employee is trained in the work practices
    • assure that each contract employee is instructed in the known potential fire, explosion, or toxic release hazards related to his/her job and the process, and the applicable provisions of the emergency action plan.
    • document that each contract employee has received and understood the training required by this paragraph.
    • prepare a record which contains the identity of the contract employee, the date of training, and the means used to verify that the employee understood the training.
    • advise the employer of any unique hazards presented by the contract employer's work , or of any hazards found by the contract employer's work.
    • Facility siting for trailers, Classified locations and ignition sources.
  • 15. Static and Dynamic Questions
    • 51 questions + 15 changing ones.
    • http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=3589#APPA
    • Example: Has the throughput changed from its original design rate for the Selected Unit(s)? If the throughput has changed, has the employer conducted a management of change (MOC) procedure for each throughput change(s) since May 26, 1992? If no, possible violations include: 119(l)(1) – the employer did not conduct an MOC when the throughput in the Selected Unit(s) changed.
  • 16. Others
    • Pumps – can employees bring issues to maintenance? Breakdown maintenance?
    • Pressure vessels toxic, highest pressure, most repairs, corrosive, oldest
    • Management of Change (more)
    • H2S
    • Hot Works (more)
    • Line Breaking
    • Confined space – Who goes in? Who rescues?
  • 17. Management of Change
    • 1910.119(l)(1) The employer shall establish and implement written procedures to manage changes (except for "replacements in kind") to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.
    • A carbon steel valve painted with aluminum paint was used instead of a stainless steel valve. It corroded rapidly.
    • More Pressure Added.
    • Higher Temperatures in the Process
  • 18. Hot Works
    • Is there a program?
    • Do they know how to calibrate equipment?
    • What distance from sparks is safe?
    • Testing/clear area before work?
    • Hoses and openings to flammables?
  • 19. Our Training
    • VPP PSM review require 3300 &3400 classes
    • PSM is having us send out advance person
    • Region has
    • 3300 – 46 People
    • 3400 – 32 People
    • 3430 - reactives
  • 20. National Emphasis Programs
    • Chemical Plants / PSM
    • Amputations
    • Trenching
    • Crystalline Silica
    • Lead
    • Combustible Dust
    • Federal Agency
    • Air Traffic Control Towers
    • Flavorings
    • Recordkeeping
  • 21. Significant Cases
  • 22. Willfuls = Most Cited
    • 1910.119(d)(3)(i) Process Safety Information
    • No U-1 for Isobutane Recycler Coalescer
  • 23. Willful
    • 1910.119(d)(3)(ii) Equipment not meet good engineering practice
    • PSV providing pressure relief protection to the reflux drum had an inlet pressure drop exceeding 3%
    • PSV had back pressure less than 10% of its set pressure
    • NO PSV for pump around cooler
    • Furnaces have no combustion safeguards
    • API RP 520
    • ASME BPV
  • 24. Willful
    • 1910.119(d)(3)(iii) Equipment not operated in a safe manner
    • Cross connections in piping systems
    • Cross-connections are the links through which it is possible for contaminating materials to enter a piping system
  • 25. Willful
    • 1910.119(e)(5) PHA findings not resolved
    • Building over pressure scenario
  • 26. Willful
    • 1910.119(j)(4)(ii) Inspections on process equipment
    • No thickness readings on PV
    • No thickness reading on piping with a history of leaks
    • Thickness readings not at half remaining life
  • 27. Willful
    • 1910.119(j)(5) Equipment had deficiencies outside acceptable range
    • PSV was undersize and adequate to have adequate relieving rate during relief scenarios
  • 28. Overlooked?
    • Facility siting
    • Incident Investigation
    • Furnaces/Heaters
    • Fatique
    • Change in ownership of facility – loss of institutional memory, best people, breakdown maintenance
    • PPE – flames, and arc flash
  • 29. Where to Start
    • Risk management – top risks/high severity
    • Process Safety Information - Walk it down
    • Process Hazard Analysis
    • Operating Procedures
    • Emergency Procedures
    • Training
    • Incident Investigations
    • Audits
  • 30. The Future
    • Need to add citation language to IMIS/OIS
    • OSHA VPP resources are limited
    • Third Party and VPP?
    • Comprehensive vs. Partials?
    • Incentives
    • Injury and Illness recording
    • Employee Involvement
    • Drug Testing
  • 31. Resources
    • Trevor Kletz – What Went Wrong
    • Csb.gov
    • OSHA Public database for 5a1
    • Rolf Eckhoff – Explosion Hazards in the Processing industry
    • William Leffler – Petroleum Refining in Nontechnical Language
    • Social Media
  • 32. [email_address]