OSHA to Increase Refinery PSM Inspections
In a recent article in its Up To Date Newsletter, OSHA has committed to performing enforcement inspections at all 81 refineries under its jurisdiction. This is all part of its National Emphasis Program, which will target process safety management and compliance. This is in response to the Chemical Safety Board’s report of the Texas City refinery explosion in 2005.
A major emphasis will undoubtably be equipment maintenance, operability, and integrity. The BP refinery disaster highlighted a list of failed equipment problems, including:
- Failed tower level transmitter
- Failed remotely operated vent valve
- Unreadable Tower level sight glass
- Failed tower high level alarm
- Failed blowdown drum high level alarm
- Failed automatic level control system
All of these were known, (poorly) documented problems that were allowed to exist even before the unit start-up.
How many problems are we living with in our day-to-day operations? How many recurring problems do we continue to fix as they occur? Often, a simple root cause analysis of a particular failure will quickly uncover the underlying problems that are allowing these failures to exist in the first place, and continue to exist on a long-term basis.
Equifactor is great supplement to a process hazard analysis. By understanding how your critical equipment can fail, you can factor undiscovered failure modes into your analysis. This additional layer of protection may allow you to pinpoint and correct these types of problems from within your already-established PSM program.