OSHA Chemical and Refinery National Emphasis Program

Purpose Prevention or minimization of the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals OSHA initiated the Refinery NEP in 2007 to address catastrophic releases of highly hazardous chemicals at refineries

Application A process which involves a chemical at or above the specified threshold quantities listed in Appendix A. A process which involves a flammable liquid or gas (defined in 1910.1200(c)) on site in one location, in a quantity of 10,000 pounds (4535.9 kg) or more (with some exceptions).

PSM Standard 1910.119 Process Safety Information (PSI) Process Hazard Analysis (PHA) Operating Procedures Training Pre-startup Safety Review Mechanical Integrity The compilation of written process safety information used by the employer/employees to identify and understand the hazards posed by those processes involving HHCs. PSI shall include information pertaining to the hazards of the process, the technology and equipment in the process. The PHA hazard analysis (hazard evaluation) shall identify, evaluate, and control the hazards involved in the process.

PSM Standard 1910.119 Contractor Evaluation Management of Change Incident Investigation Emergency Planning and Response Compliance Audit The compilation of written process safety information used by the employer/employees to identify and understand the hazards posed by those processes involving HHCs. PSI shall include information pertaining to the hazards of the process, the technology and equipment in the process. The PHA hazard analysis (hazard evaluation) shall identify, evaluate, and control the hazards involved in the process.

PSM Standard 1910.119 Contractor Evaluation Management of Change Incident Investigation Emergency Planning and Response Compliance Audit The compilation of written process safety information used by the employer/employees to identify and understand the hazards posed by those processes involving HHCs. PSI shall include information pertaining to the hazards of the process, the technology and equipment in the process. The PHA hazard analysis (hazard evaluation) shall identify, evaluate, and control the hazards involved in the process.

Ammonia Refrigeration PSM Standard 1910.119 Ammonia Refrigeration RAGAGEP International Institute of Ammonia Refrigeration (IIAR) American society of Heating, Refrigerating and Air- Conditioning Engineers (ASHRAE) American Society Mechanical Engineers (ASME) Manufacturer’s Recommendations The compilation of written process safety information used by the employer/employees to identify and understand the hazards posed by those processes involving HHCs. PSI shall include information pertaining to the hazards of the process, the technology and equipment in the process. The PHA hazard analysis (hazard evaluation) shall identify, evaluate, and control the hazards involved in the process.

PSM Standard 1910.119 Chemicals RAGAGEP American Petroleum Institute Chlorine Institute National Fire Protection Association (NFPA) https://www.osha.gov/laws-regs/ Standard Interpretations/2016-05-11-0 The compilation of written process safety information used by the employer/employees to identify and understand the hazards posed by those processes involving HHCs. PSI shall include information pertaining to the hazards of the process, the technology and equipment in the process. The PHA hazard analysis (hazard evaluation) shall identify, evaluate, and control the hazards involved in the process.

Tanker Cleaning Confined Space Entry Fatality Employer is in the business of cleaning tanker trailers previously containing hazardous chemicals. Tanker trailers typically contain hazardous chemical residue (no more 2” present at the bottom). Employer used cleaning agents containing sulfuric and phosphoric acid and sodium hydroxide to clean the tankers. Over 200 tankers had been cleaned over a four month period.

Tanker Cleaning Confined Space Entry Fatality Employees open the top hatch of a tanker to looks inside to determine how they will clean the inside of the tanker. They wear no respirator and no fall protection. Employee falls inside the tanker containing hazardous chemical residue (no more 2” at the bottom) Employees father goes inside the tanker (holds his breath) to rescue his son, is also overcome and falls down inside the tanker. Fire Department is called to the site. They rescue the father but the son is found dead at the bottom of the tanker truck.

Tanker Cleaning Confined Space Entry Fatality Employees were not provided any chemical information regarding the chemical content of the tankers. Employees were not provided and required to wear a lifeline attached to a safety harness, or air-line respirators when entering the confined space. Employees complained of burning eyes when entering the tankers and requested full-face respirators. Employer only provided half- face respirators Testing of the atmosphere inside the tanker was not performed prior to employees entering confined spaces and a blower unit was not used to ventilate the confined space.

Tanker Cleaning Confined Space Entry Fatality Employer falsified confined space permit by indicating that air monitoring of the confined space was provided even though 4- gas meter had not been calibrated and had not been operational for months. PPE, boots and gloves had holes in them and were only purchased once/month. Employer did not have an emergency eye wash or shower. Replacement cartridges for the half-face masks were replaced every two months.

Tank Cleaning Confined Space Entry Fatality Employees received no training on the chemical hazards of the job in general and the specific hazards regarding the chemical they were exposed to. Prior to this incident the father’s other son was also overcome by the chemical vapors and was rescued just prior to passing out.