The decision by the OSHRC settles several KEY PSM application debates. The accident involved a boiler that provided steam to a covered process and the boiler also used fuel from the refinery process(s) so OSHA took the position the boiler was part of the “covered process” because it was both interconnected and co-located such that the boiler could impact the covered process. The company attempted to use grammar and punctuation in OSHA’s definition of a “process” to argue that interconnected nor co-location were proper means to define a “process”. The four main topics discussed in this case are:
- “Interconnected” Vessels and Proof of Risk of Catastrophic Release
- Interconnection of Vessels
- Location of Wickes Boiler
- Workplace Fuel Consumption Exemption
This is a MUST read for all process safety professionals as these same arguments and rationale will apply to ALL “covered processes”.