New California Refinery Safety Order - Weekly Compliance Digest

June 02, 2017
By Jean-Grégoire Manoukian

In this edition of the Weekly Compliance Digest, we cover a workplace safety and health regulation that aims to reduce risks of incidents at oil refineries in California.

Process Safety Management for Petroleum Refineries

What is it?

On May 18, 2017, the Department of Industrial Relations’ Occupational Safety and Health Standards Board of the state of California approved a new regulation that aims to strengthen workplace safety and health at oil refineries across the state. The new regulation provides a framework for anticipating, preventing and responding to hazards at refineries. The approved regulation introduces a new refinery safety order enforced by Cal/OSHA’s Process Safety Management (PSM) Unit, which is responsible for inspecting refineries and chemical plants that handle large quantities of toxic and flammable materials

What are the requirements?

Under the new regulation, refinery employers in California 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.

The new rules are part of a package of complementary regulations intended to make California refineries safer for workers and communities. The companion regulation strengthens the California Accidental Release Prevention (CalARP) program, designed to prevent the accidental release of hazardous chemicals that could harm public health and the environment. The revised CalARP regulation will also be submitted to the Office of Administrative Law for approval.

What is next?

The Standards Board has approved the regulation, which means that California’s Office of Administrative Law has 30 working days, as of May 18, 2017, to review and approve the regulation.

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