Transcript CHRISTOPHER LEE

DIR & Cal/OSHA: Refinery Sector Update
Mike Wilson and Clyde Trombettas
CAER, Martinez
March 27, 2014
Emergency
Response
Prevention:
PSM & RMP
regs
Task Force
(IRTF)
Interagency
Working
Group
Improve
Enforcement
Capacity
Community
Outreach
Further
Study
Emergency
Response
Prevention:
PSM & RMP
regs
Task Force
(IRTF)
Interagency
Working
Group
Improve
Enforcement
Capacity
Community
Outreach
Further
Study
Annual
emergency
response training
exercises
Unified command
with Joint
Information
Center controlled
by a public
agency
Conduct planning
with major public
assets (e.g. BART,
schools, health
care, transit
Emergency
Response
Upgrade
monitoring and
communication
capacity on air
toxics (Daily and
upset)
Improve Area
Plans to include
focus on
refineries
Align radio
frequencies
between onsite
fire depts and
public fire depts.
Emeraency
Response
Prevention:
PSM & RMP
regs
Task Force
(IRTF)
Interagency
Working
Group
Improve
Enforcement
Capacity
Community
Outreach
Further
Study
Require inherent
safety as the
primary objective
in the hierarchy
of controls
Require
accounting for
human factors in
plant operations
and processes
Require root
cause analysis
following
incidents, with
reports made
public
Prevention:
PSM & RMP
Regs
Require safety
culture
assessments,
with worker
involvement
Require damage
mechanism
hazard reviews,
with results
provided to
agencies
Emergency
Response
Prevention:
PSM & RMP
regs
Task Force
(IRTF)
Interagency
Working
Group
Improve
Enforcement
Capacity
Community
Outreach
Further
Study
Boots to the Ground….


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.
Classification of PSM Inspections
Total Number of Inspections
Accidents
231
Complaints
206
Programmed Related
46
Unprogrammed Related
177
Referral
63
Follow Up
102
Planned Inspections
831
Planned Inspections - Refineries ONLY
56
TOTAL
1712
Total Hours
20743
14346
1896
8147
5166
3513
58441
4022
116274
From 2001 thru October 2012
Average Hours Per Inspection
90 hours per inspection
70 hours per inspection
42 hours per inspection
46 hours per inspection
82 hours per inspection
35 hours per inspection
70 hours per inspection
72 hours per inspection
68 Hours Per Inspection


2013 Total PSM Inspections =
63 Inspections
2013 Total Refinery Inspections = 33 Inspections
Classification
Refinery inspections
Refinery "Leak Seal" Inspections
Non-Refinery Inspections
TOTAL
Total Number of Inspections
24
9
30
63
Total Hours
573
1444
766
2783
Average Hours Per Inspection
24 hours per inspection
160 hours per inspection
26 hours per inspection
70 hours per inspection


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.



9 New Compliance Officers Hired as of April
1, 2014
From April 1 thru October 3rd 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

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…

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…

SB 1300, If passed by the Legislature and
signed by the Governor will require refineries
to;
◦ Submit to Cal/OSHA every September 15th 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.




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…
Questions???