DIR & Cal/OSHA: Refinery Sector Update

Mike Wilson and Clyde TrombettasCAER, MartinezMarch 27, 2014

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.

From 2001 thru October 2012

Classification of PSM Inspections Total Number of Inspections Total Hours Average Hours Per InspectionAccidents 231 20743 90 hours per inspection

Complaints 206 14346 70 hours per inspectionProgrammed Related 46 1896 42 hours per inspection

Unprogrammed Related 177 8147 46 hours per inspectionReferral 63 5166 82 hours per inspection

Follow Up 102 3513 35 hours per inspectionPlanned Inspections 831 58441 70 hours per inspection

Planned Inspections - Refineries ONLY 56 4022 72 hours per inspectionTOTAL 1712 116274 68 Hours Per Inspection

2013 Total PSM Inspections = 63 Inspections 2013 Total Refinery Inspections = 33

InspectionsClassification Total Number of Inspections Total Hours Average Hours Per Inspection

Refinery inspections 24 573 24 hours per inspectionRefinery "Leak Seal" Inspections 9 1444 160 hours per inspectionNon-Refinery Inspections 30 766 26 hours per inspectionTOTAL 63 2783 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???