California Oil Refinery Safety Regulations - Weekly Compliance Digest

August 18, 2017
By Jean-Grégoire Manoukian

In this edition of the Weekly Compliance Digest, we cover new California regulations on workplace and environmental safety at oil refineries.

Process Safety Management for Petroleum Refineries

What is it?

On August 4, 2017, the California Department of Industrial Relations and the California Environmental Protection Agency announced final approval of new regulations to strengthen workplace and environmental safety at oil refineries across the state.

The new regulations overhaul Cal/OSHA worker safety regulations as they apply to refineries and the California Accidental Release Prevention program (CalARP), which is designed to prevent the accidental release of hazardous substances that could harm public health and the environment.

Who is affected?

The new regulations affect the 15 oil refineries in California. Most of them are located in the Los Angeles area and the eastern San Francisco Bay Area.

What are the requirements?

We described the requirements in a previous Weekly Compliance Digest when California’s Department of Industrial Relations’ Occupational Safety and Health Standards Board had . We provide them again below along with a few updates. Refinery employers will be required to:

  • Conduct Damage Mechanism Reviews for processes that result in equipment or material degradation. Physical degradation, such as corrosion and mechanical wear, are common technical causes of serious process failures.
  • Conduct a Hierarchy of Hazard Controls Analysis to encourage refinery management to implement the most effective safety measures when considering competing demands and costs when correcting hazards.
  • Implement a Human Factors Program, which requires analysis of human factors such as staffing levels, training and competency, fatigue and other effects of shift work, and the human-machine interface.
  • Develop, implement and maintain written procedures for the Management of Organizational Change to ensure that plant safety remains consistent during personnel changes.
  • Utilize Root Cause Analysis when investigating any incident that results in, or could have reasonably resulted in, a major incident.
  • Perform and document a Process Hazard Analysis of the effectiveness of safeguards that apply to particular processes and identify, evaluate and control hazards associated with each process.
  • Understand the attitudes, beliefs, perceptions and values that employees share in relation to safety and evaluate responses to reports of hazards by implementing and maintaining an effective Process Safety Culture Assessment program.
  • Report annually on refinery safety metrics under the California Accidental Release Prevention program (CalARP).

The regulations also give authority to refinery personnel to shut down a unit, if needed, in the event of an unsafe condition or emergency, and include provisions for anonymous reporting of safety hazards.

What is next?

The new regulations will take effect on October 1, 2017. Here are links to more articles on the regulations:

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