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DIR & Cal/OSHA: Refinery Sector Update Mike Wilson and Clyde Trombettas CAER, Martinez

DIR & Cal/OSHA: Refinery Sector Update Mike Wilson and Clyde Trombettas CAER, Martinez March 27, 2014. Application of Hierarchy of Controls in Process Safety. Cal/OSHA Statewide PSM Unit Past, Present, and Future. Boots to the Ground…. Past Enforcement.

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DIR & Cal/OSHA: Refinery Sector Update Mike Wilson and Clyde Trombettas CAER, Martinez

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  1. DIR & Cal/OSHA: Refinery Sector Update Mike Wilson and Clyde Trombettas CAER, Martinez March 27, 2014

  2. Application of Hierarchy of Controls in Process Safety

  3. Cal/OSHA Statewide PSM UnitPast, Present, and Future Boots to the Ground….

  4. Past Enforcement • 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.

  5. Past Enforcement Numbers From 2001 thru October 2012

  6. Current Enforcement Activities of the PSM Unit • 2013 Total PSM Inspections = 63 Inspections • 2013 Total Refinery Inspections = 33 Inspections

  7. Current Enforcement Activities of the PSM Unit • 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.

  8. Current and Future Enforcement of PSM Unit • 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

  9. Current and Future Enforcement of PSM Unit continued… • 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…

  10. Current and Future Enforcement of PSM Unit continued… • 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…

  11. Current and Future Enforcement of PSM Unit continued… • 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.

  12. Current and Future Enforcement of PSM Unit continued… • 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…

  13. Questions???

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