Christine Baker, Director of the Department of Industrial Relations (DIR), has submitted a legislatively-mandated status report on DIR and Cal/OSHA’s Process Safety Management (PSM) Regulatory Oversight. The report is required pursuant to the Budget Act of 2014 (Provisions 1 and 2 of item 7350-001-3121, Chapter 25, Statutes of 2014). A new assessment on the state’s oil refineries, implemented by DIR in 2013, requires refineries to provide funding support to DIR for Cal/OSHA’s PSM refinery program. The funds, which are independent of the state’s General Fund, have allowed DIR to expand the PSM staff from 10 positions in 2012 to 26 positions and supported eleven weeks of advanced technical training for the refinery inspectors. Cal/OSHA’s PSM Unit is responsible for inspecting refineries and chemical plants that handle large quantities of toxic and flammable materials. Health and safety standards enforced by the PSM Unit, including adequate employee training, are intended to prevent catastrophic explosions, fires, and releases of dangerous chemicals.
DIR has transformed the recommendations of the Governor’s report into the following seven new elements of the revised PSM standard (General Industrial Safety Order 5189.
1) Damage Mechanism Reviews:
Physical degradation, such as corrosion and mechanical wear, is often identified as the technical cause of serious process failures in the U.S. refinery sector; many of these incidents have resulted in fires, fatalities, and releases of hazardous substances. The refinery industry identifies physical degradation and other damage mechanisms through Damage Mechanism Reviews, which also include recommended corrective actions.
2) Hierarchy of Hazard Controls Analysis:
In the face of competing demands and costs, refineries do not always choose the safest, most enduring technologies or materials when correcting hazards. For example, it is currently permissible for a refinery to provide splash suits and goggles to protect employees who work with acids, rather than installing a properly engineered, closed system that eliminates the risk of an acid splash. The Hierarchy discourages reliance by refineries on such procedural safeguards, which are implemented by management and considered to be the weakest approach to solving process safety problems.
3) Human Factors:
Human factors include staffing levels, training and competency levels, fatigue and other effects of shift work, communication systems, the human-machine interface, and the general physical challenges of the work environment.
4) Management of Organizational Change:
Refineries are continually implementing changes to operations, maintenance procedures, and personnel. This recommendation calls for procedures to ensure that plant safety is considered during personnel changes. Such changes can undermine plant safety, if for example, employees are placed in positions for which they are not sufficiently trained, or if staffing is reduced to levels that do not allow for an adequate response to an emergency.
5) Root Cause Analysis:
This type of analysis focuses on identifying the underlying causes of an incident and then recommending corrective actions to prevent a reoccurrence. For example, an incident that appears to be the result of worker inattention might, following a root cause analysis, reveal underlying pressures in the organization of the work environment that motivate workers to cut corners. The recommendations from the investigation would focus on these aspects of the work environment, rather than solely on strategies to improve worker vigilance.
6) Safeguard Protection Analysis:
This is a structured analysis to assess the effectiveness of safeguards that are applied to a particular process. The goal of the analysis is to ensure that the safeguards will prevent an initiating event from cascading into a major catastrophe. For example, if a loss of electrical power could lead to a failure of important safety instruments, such as temperature indicators, the safeguard analysis would identify the instruments that should be supported with backup power systems, and it would require that those systems be brought on-line automatically in the event of a power failure.
7) Safety Culture Assessments:
A group’s culture reflects the attitudes, beliefs, perceptions, and values that employees share in relation to safety. If the group places a high value on safety, the group is said to have a “strong safety culture.” Safety culture assessments are used to determine whether and to what extent management encourages a culture that values safety.
Currently, refineries in California are complying, to varying degrees, with six of the seven elements listed above. Hierarchy of Hazard Controls Analysis is a relatively new concept, with which only refineries in Contra Costa County who are subject to the County’s Industrial Safety Ordinance are fully familiar.
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