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OSHA Chemical Safety Initiatives. SOCMA Washington, DC December 5, 2007. Fatality/Catastrophe PSM Incidents. From DEP Fatality Study. What’s Up with OSHA. Refinery National Emphasis Program (NEP) Pilot “Chemical Plant” CPL “ MOTIVA” Interpretation Federal Register Notice

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osha chemical safety initiatives

OSHA Chemical Safety Initiatives


Washington, DC

December 5, 2007

fatality catastrophe psm incidents
Fatality/Catastrophe PSM Incidents

From DEP Fatality Study

what s up with osha
What’s Up with OSHA
  • Refinery National Emphasis Program (NEP)
  • Pilot “Chemical Plant” CPL
  • “MOTIVA” Interpretation
    • Federal Register Notice
  • Combustible Dust NEP
  • Guidance
motiva interpretation
‘Motiva” Interpretation
  • 2 Business Units
    • Refinery
    • Distribution Terminal
  • Interconnection of >>> TQ flammable gas
  • Fire During Loading
    • Driver burned

Refinery Complex

7 Propane Bullets >>> TQ

Interconnected to Distribution Terminal

Truck Distribution Rack

Distribution Terminal

motiva background
Motiva Background
  • Issue of interconnection of flammable materials is key to the enforcement of the PSM standard
  • Motiva appealed OSHA PSM citations
    • Motiva only argued scope/application of standard
    • OSHA won the case at the ALJ level.
  • OSHA then lost case at the OSH Review Commission - Motiva Enterprises, 21 BNA OSHC 1696 (OSHRC No. 02-2160, 2006).
  • The Review Commission questioned whether the regulatory text was meant to limit the coverage of the PSM standard to a HHC process, that was both “on-site” and “in one location” as per scope/application of 1910.119.
motiva background7
Motiva Background
  • Review Commission decided
    • Could not determine that the cited activities were "on site" and "in one location”
    • Absence of an authoritative interpretation
    • Vacated the citations.
  • The Review Commission recognized
    • OSHA is the agency responsible for policymaking under the OSH Act
    • Commission left it to OSHA to decide
      • "in the first instance . . . the meaning of these terms and offer an 'authoritative interpretation.'"
      • "[a]ny such subsequent interpretation" would be reviewed in a future case "under 'standard deference principles.'"
  • FR Notice addresses OSHA’s interpretation of the term “on site in one location” in the scope and application section of the PSM standard
  • Bottom Line
    • Interpretation and application of scope provisions of PSM stays the same
    • NOTHING has changed
    • FR Notice reiterated OSHA’s current interpretation
refinery national emphasis program
Refinery National Emphasis Program
  • OSHA national PSM enforcement program
    • Program (NEP) for inspecting petroleum refineries
    • SIC 2911 and NAICS 324110
  • Contains policies and procedures to verify employers’ compliance with OSHA’s PSM standard
  • Primary Purpose: Tool for OSHA CSHOs to determine compliance w/PSM
why refinery nep
Why Refinery NEP
  • Need for OSHA to conduct programmed inspections at high risk facilities
  • FAT/CAT data indicates refineries are good place to start
    • SIC 2911 experienced 36 FAT/CATS since 1992
    • Top 4 SICs account for 40% of all PSM FAT/CATS
    • Refineries account for 20% of Total
    • Refinery FAT/CATs > other 3 top SICs combined
  • Recent Refinery Incidents
    • BP TCR
breakdown of 152 u s refineries
Breakdown of 152 U.S. Refineries

From EPA RMP Submittals

nep focus areas
NEP Focus Areas
  • Prioritize on Implementation versus the existence of documentation
    • Ensure that employers do what they have committed to do
    • 119(d)(3)(ii) – “…shall comply with RAGAGEP”
    • Mostly Equipment
      • Vessels, Piping, Relief Systems, Blowdown Systems
  • PHA
    • 119(e)(1) - “…shall identify, evaluate, and control hazards of process”
  • Equipment Deficiencies
    • 119(j)(5) – fix deficient equipment before further use or take necessary means to assure safe operation until deficiency can be fixed at next opportunity
  • Others
new inspection strategy
New Inspection Strategy
  • Evaluate PSM compliance using Inspection Priority Items (IPI)
    • Gap Analysis (Yes, No, N/A Questions)
    • Questions developed in-house
      • will work in questions provided by anybody
  • List Based IPI
    • Static List
      • 95 Questions
      • Like all OSHA CPLs, posted on public website
    • Dynamic List
      • 8 to 15 questions/list
      • Changes every 2 to 6 weeks
      • “Secret List” for inspection integrity
        • Not posted on OSHA’s public website
so far
So Far….
  • NEP launched June 7, 2007
  • 16 NEP inspections started/on-going
    • No inspections have been completed
    • Therefore, no citations issued to-date
  • Early inspections finding many deficiencies
    • CSHOs going “off-script”
      • Many deficiencies found that are not related to IPI
      • Resulting in longer inspections than originally planned
some findings
Some Findings…
  • Findings are varied
  • Some specific deficiencies found
    • PHA recommendations not resolved
    • No car seals for isolation valves on relief discharge lines
      • Low hanging fruit
    • Piping well below retirement thickness
    • Facility siting – control room
    • Facility siting – emergency isolation valves
    • Relief study recommendations as part of PHA not resolved
    • Factors contributing to the incident not listed in report
    • Contractors not included in investigation team when required
    • MOC documentation not complete for vessel rerate
    • Design basis for relief system does not exist
    • LOTO failure to verify deenerization
    • Contractors hot work practices
chemical plant compliance directive
“Chemical Plant” ComplianceDirective
  • Need for programmed inspections at high risk chemical facilities
  • PSM inspection resources fully deployed conducting NEP
  • Pilot Program for Chemical Facilities
    • Regions with few NEP inspections
    • 1 year in duration
      • Decision near end of NEP to fully deploy Chem CPL
pilot chem cpl
Pilot Chem CPL
  • Details TBD
  • Thoughts
    • Targeting Sites to be Inspected
      • Use RMP Program 3 facilities as main target for selecting sites for inspection
      • Add SICs typically covered by PSM which are not covered by RMP
    • Inspection Strategy
      • Many inspections, shorter duration
      • Use Dynamic List IPI concept
combustible dust nep
Combustible Dust NEP
  • 280 dust fires and explosions in U.S. industrial facilities
    • past 25 years
    • 119 fatalities and over 700 injuries
    • Per CSB
  • National Emphasis Program
  • Policies and procedures for inspecting

workplaces that create or handle combustible dusts.

combustible dust cpl
Combustible Dust CPL
  • CPL 03-00-006
  • Issued October 18, 2007
hazard communication
Hazard Communication
  • Considering adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)
  • Published an advance notice of proposed rulemaking (ANPR) 9/12/2006
  • Accepted comments until 11/13/2006
hazard communication21
Hazard Communication
  • Other OSHA standards may be affected
  • Will likely need to change hazard communication provisions in OSHA’s substance-specific standards to be consistent.
  • May also need to address parts of other standards that have criteria for hazard definitions, such as flammable liquids.
completed guidance projects
Completed Guidance Projects
  • Motor vehicle safety
  • Combustible dust (SHIB)
  • Indoor air (mold)
  • Pandemic flu preparedness
  • Glutaraldehyde
  • Perchloroethylene
completed guidance projects23
Completed Guidance Projects
  • Guidance for Hazard Determination (HazCom)
  • Motor vehicle safety at marine terminals
  • Slings
  • Marine terminal crane radio communication
guidance projects in development
Guidance Projects in Development
  • Hazard communication/GHS
  • PPE for emergency response
  • Reactive chemicals
  • Combustible dust poster
  • Lockout/tagout checklist

Mike Marshall