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OSHA Releases New PSM Guidance for Oil Refineries

By Jeremiah Wooten at Inspectioneering, LLC.. September 13, 2017

The U.S. Occupational Safety and Health Administration (OSHA) recently released a new guide to help petroleum refiners comply with its Process Safety Management (PSM) standard (1910.119). "Since the PSM standard was promulgated by OSHA in 1992, no other industry sector has had as many fatal or catastrophic incidents related to the release of highly hazardous chemicals (HHC) as the petroleum refining industry," the document states.

In an effort to reduce these incidents, OSHA introduced the National Emphasis Program (NEP) in 2007, which was designed to verify whether refinery operators were maintaining PSM compliance. After reviewing the citations issued for violations of the PSM standard under the NEP, OSHA has discovered several common instances of non-compliance in the petroleum refinery industry, including many related to the following 5 areas:

Process Safety Information

Under the PSM standard, employers are required to compile written process safety information (PSI). The compilation of written process safety information enables the employer and the employees involved in operating the process to identify and understand the hazards posed. During inspections under the NEP, OSHA issued many citations for violations of the PSM standard related to the (1) RAGAGEP, (2) piping & instrumentation diagrams (P&IDs), and (3) relief system design basis.

Process Hazard Analysis

A process hazard analysis (PHA) is an organized and systematic effort to identify and analyze the significance of potential hazards associated with the processing and handling of HHC. The PHA must be appropriate to the complexity of the process and must identify, evaluate, and control the hazards involved in the process. During NEP inspections, OSHA frequently found PHA deficiencies in (1) recommendation resolution, (2) facility siting, and (3) human factors analyses.

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