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Published byAngelica Blair Modified over 9 years ago
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DIR & Cal/OSHA: Refinery Sector Update Mike Wilson and Clyde Trombettas CAER, Martinez March 27, 2014
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Interagency Working Group Emergency Response Prevention: PSM & RMP regs Community Outreach Further Study Improve Enforcement Capacity Task Force (IRTF)
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Interagency Working Group Emergency Response Prevention: PSM & RMP regs Community Outreach Further Study Improve Enforcement Capacity Task Force (IRTF)
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Emergency Response Annual emergency response training exercises Unified command with Joint Information Center controlled by a public agency Improve Area Plans to include focus on refineries Align radio frequencies between onsite fire depts and public fire depts. Upgrade monitoring and communication capacity on air toxics (Daily and upset) Conduct planning with major public assets (e.g. BART, schools, health care, transit
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Interagency Working Group Emeraency Response Prevention: PSM & RMP regs Community Outreach Further Study Improve Enforcement Capacity Task Force (IRTF)
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Prevention: PSM & RMP Regs Require inherent safety as the primary objective in the hierarchy of controls Require safety culture assessments, with worker involvement Require damage mechanism hazard reviews, with results provided to agencies Require root cause analysis following incidents, with reports made public Require accounting for human factors in plant operations and processes
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Application of Hierarchy of Controls in Process Safety
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Interagency Working Group Emergency Response Prevention: PSM & RMP regs Community Outreach Further Study Improve Enforcement Capacity Task Force (IRTF)
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Boots to the Ground….
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The primary enforcement method the district office will utilize to assess PSM compliance in covered establishments is a PSM-specific inspection, termed a Program-Quality-Verification, or PQV inspection also known as a Planned Inspection From 2001 thru 2012 the Statewide PSM Unit averaged 8 compliance officers to enforce the PSM Standard at 15 California Refineries and 1,617 Non Refinery PSM regulated facilities.
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From 2001 thru October 2012
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2013 Total PSM Inspections = 63 Inspections 2013 Total Refinery Inspections = 33 Inspections
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All Staff Completed Advanced PSM Training in October 2013. A Special Thank You to Dow Chemical and Valero Refinery for Assisting in Training of PSM Staff. ◦ Dow Chemical provided training on “Batch” Processing and MI ◦ Valero provided two days of training on “continuous process systems and MI.
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9 New Compliance Officers Hired as of April 1, 2014 From April 1 thru October 3 rd New Hires Begin Training in Cal/OSHA Enforcement Protocols and the Federally Mandated PSM Training along with Out of State Training provided by CCPS. There will be dedicated Refinery Compliance officers and Non Refinery Compliance Officers
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A Change in Enforcement… ◦ Instead of 1 Compliance Officer conducting a Planned Inspection of a refinery clocking approximately 70 hours there will be… ◦ 5 Compliance Officers conducting an inspection of 2 Refineries a year and clocking approximately 1,000 hours per refinery ◦ Same for Southern California ◦ What About that Interagency Taskforce…
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For Planned inspections at Refineries a Refinery can expect to see on a Planned Inspection… ◦ A member from the CUPA ◦ A member from the Air Board ◦ EPA (?) ◦ And What About Them Turnarounds…
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SB 1300, If passed by the Legislature and signed by the Governor will require refineries to; ◦ Submit to Cal/OSHA every September 15 th the following years T/A schedule. ◦ Cal/OSHA will pick one refinery up north and one down south to open an inspection. ◦ 60 days Prior to T/A refineries required submit to Cal/OSHA Scope of T/A and justification for any deferred maintenance.
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During T/A compliance officers to review contractors safety training and certification records. During T/A compliance officers to review significant work order changes. For those of you who remember Peter, Paul, and Mary… The Times Are A Changing…
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Questions???
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