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The Safety Case Regulatory Regime 21st Century Major Accident Prevention The CSB Chevron Investigation Rafael Moure-Eraso, Ph.D., Chairperson. CAER-CCC Richmond, CA DEcember 16, 2013.
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“The U.S. refining sector has more than three times the rate of property losses of refineries overseas.”Swiss Rae, 2011
The CSB has investigated many refinery incidents:
The CSB has investigated many refinery incidents
The safety case regime is a more effective approach for preventing major accidents at U.S. refineries than current U.S. regulatory systems.
California State Legislature to California refineries to:
The CSB committed to investigate additional issues:
Staff Draft Report for
Chevron internal recommendations not implemented
PHA Safeguards not evaluated
No requirement to reduce risks to as low as reasonably practicable, or ALARP.
No requirement to implement inherent safety
Regulators lack the technical staff with the necessary
These are essential to provide sufficient direct oversight of petroleum refineries in California.
The CSB has made a number of process safety-related recommendations to OSHA and the EPA.
Available data from Norway and the United Kingdom (UK) shows a reduction in hydrocarbon releases offshore under the safety case regulatory regime.
The existing regulatory regimes for onshore petroleum refineries in the US and California:
The existing U.S. and California Process Safety Regimes:
Tweaking current OSHA-PSM and EPA-RMP regulations only incorporates learnings from most recent accidents. This is performed at a very slow rate, if at all.
The safety case regime proposed in the report requires continuous risk reduction and is a more effective approach to prevent major incidents in petroleum refineries.
“A verifiable case which the operator of a hazardous facility makes to a regulator, setting how safety is to be managed. Includes:
OSHA recordable injury and illness rates (lagging indicators) are not sufficient.
The Safety Case allows regulators to
Regulators review and accept safety case reports
Great emphasis is placed on inherent safety
The regulator may reject the safety case report and require additional measures to further reduce risks
Preventative inspections and audits are conducted to intervene before high-risk activities commence.
The role of the safety regulator:
The safety case regulatory approach is not foreign to the US:
The US already has the safety case approach: