Heightened Scrutiny of U.S. Petroleum Refineries and Chemical Facilities

In the last two decades, the petroleum refining industry has had more fatal or catastrophic incidents related to the release of highly hazardous chemicals (HHCs) than any other industry sector covered by the PSM standard. Because of this, in 2007 OSHA initiated its refinery National Emphasis Program (NEP) to greatly reduce or eliminate the workplace hazards associated with the catastrophic release of HHCs at petroleum refineries. The program's inspection process includes asking detailed questions designed to gather facts related to PSM requirements and verifying that employers' written and implemented PSM programs are consistent.

Impact

The NEP includes inspections of all refineries for compliance with the Process Safety Management Regulations and a random selection of facilities likely to have highly hazardous chemicals in quantities covered by the standard. In the first year of the NEP, OSHA inspection teams completed inspections and issued citations at 14 refineries in six of OSHA's 10 regions. A total of 348 PSM citations, including proposed penalties, were issued. These citations reflected the serious PSM compliance issues that were found at many refineries. Twenty percent of the citations were issued on only four sub-elements of the PSM standard.  These are:

• j(5) Equipment Deficiencies     
• d(3)(ii) Equipment RAGAGEP
• e(5) PHAs not promptly addressed
• l(1) Management of change procedure

Challenge

An effective process safety management program requires a systematic approach to evaluating the whole process, not just checking off each element as complete.  If you can’t find information when you need it – then it doesn’t exist for practical purposes. Many organizations still have PSI, PHAs, manufacturer’s data, MSDS etc in crumbling books on dusty old shelves. Missing and/or inconsistent information between disparate documents and systems can account for a large portion of NEP citations.

The Dyadem Solution

One of the best and most productive means of streamlining compliance is to deploy a central framework that can act as a PSM compliance platform for the company.  A compliance platform can give one click access to documents, data assurance maps & workflows, integrated EH&S systems, real-time data, internal reporting, dashboards, contractor information, access to regulatory organizations and citations, KPI metrics, and much more.  Having a central location to access PSM information systems demonstrates organization, responsibility, planning, and good leadership. Many systems exist to handle portions of your Process Safety Management program but few are able to support all 14 elements and organize your information to streamline an NEP audit. Stature is an Operational Risk Management platform that can help you not only identify, analyze, mitigate and monitor risks throughout your operations but also allow you to organize data, individual files, videos and photos, in any format, in one central repository.  This provides visibility and transparency into your PSM programs and ensures an audit trail during NEP inspections.

The Stature enterprise risk management platform is built on the principles of continuous improvement, providing seamless communication from the operator up to the executives and customized dashboards and reporting for every level of the company.  Its Risk Assessment, Management of Change, Incident Management and Action Tracking modules support multiple workflows that can be configured to any corporate standards and provide a global risk register of all hazards across the organization.  Its central repository serves as a way to integrate all 14 elements of OSHA’s PSM directive and provides transparency for NEP inspections.