• California Oil Refinery Safety Regulations

Weekly Compliance Digest – California Oil Refinery Safety Regulations

July 29, 2016 By
In this edition of the Weekly Compliance Digest, we cover new proposed regulations in the state of California to improve the safety of workers at oil refineries.

Process Safety Management for Petroleum Refineries

What is it?

Following a chemical release and fire at the Chevron refinery in Richmond, California, on August 6, 2012, a report was produced raising concerns and recommendations about the safety of California oil refineries. The report recommended the establishment of an Interagency Refinery Task Force to: 1) coordinate revisions to the state’s PSM regulations and California Accidental Release Program (CalARP) regulations,  2) strengthen regulatory enforcement, and 3) improve emergency preparedness and response procedures.

In accordance with the recommendations of the report, Cal/OSHA announced on July 15, 2016 a new Process Safety Management (PSM) regulatory proposal for oil refineries. The proposal implements the recommendations of the report and other PSM elements. These elements include: applying a hierarchy of controls to implement first- and second-order inherent safety measures; conducting damage mechanism reviews; applying rigorous safeguard protection analyses; integrating human factors and safety culture assessments into safety planning; involving front-line employees in decision-making; conducting root-cause analysis following significant incidents; and performing comprehensive process hazard analyses.

The regulatory proposal sets safety performance standards for refinery employers and ensures that those standards are met through improvements in transparency, accountability, worker participation and enforcement.

Who is affected?

The proposed regulation would apply to processes within petroleum refineries in California.

What are the requirements?

Changes in the Process Safety Management (PSM) standard would require petroleum refineries to:

  • Implement inherently safer systems to the greatest extent feasible.
  • Perform periodic safety culture assessments.
  • Incorporate damage mechanism hazard reviews into process hazard analyses.
  • Conduct root-cause analyses after significant accidents or releases.
  • Account for human factors and organizational changes.
  • Use structured methods, such as layer of protection analysis, to ensure adequate safeguards in process hazard analyses.

More information about the requirements is available in the document on the proposed regulation.

What is next?

The proposed regulation was promulgated on July 15, 2016. A comment period will be held until September 15, 2016, which is also the date when a public hearing will take place on the proposed PSM regulation. The proposed regulation will be adopted in its current version or revised version sometime after the public hearing.
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California Accidental Release Prevention Program

What is it?

​The California Accidental Release Prevention (CalARP) program was implemented on January 1, 1997. Its purposes are to prevent accidental releases of substances that can cause serious harm to the public and the environment, minimize the damage if releases occur, and satisfy community right-to-know (RTK) laws. This is accomplished by requiring businesses that handle more than a threshold quantity of a regulated substance listed in the regulations to develop a Risk Management Plan (RMP). An RMP is a detailed engineering analysis of the potential accident factors present at a business and the mitigation measures that can be implemented to reduce this accident potential.

Following the chemical release and fire at the Chevron refinery in Richmond, California, a report was produced raising concerns and recommendations about the safety of California oil refineries. The report recommended revisions to the state’s PSM regulations and CalARP Program regulations. In accordance with the recommendations of the report, the California Governor’s Office of Emergency Services (Cal OES) proposed on July 15, 2016 to promulgate new CalARP Program regulations for petroleum refineries. The proposal implements the recommendations of the report and other CalARP Program elements.

Cal OES says that the proposed regulations may improve safety at California refineries, which will in turn result in fewer major process incidents and fewer releases of hazardous materials from refineries.

Who is affected?

The proposed regulation would apply to petroleum refineries in California.

What are the requirements?

According to a Safety+Health article, the main changes to the CalARP program would do the following:

  • Increase transparency by providing more information to the public.
  • Make annual reporting of process safety performance indicators a requirement.
  • Make investigation reports available to the public after major incidents.

What is next?

The proposed regulation was promulgated on July 15, 2016. A comment period will be held until August 29, 2016. A public hearing is not scheduled at this time.

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Categories: EHS

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