Utah Petroleum Association
Utah OSHA Presentation
Paul C. Cannon, CSP
Safety and Health Compliance Officer
January 30, 2014
Achieving compliance and providing assistance with safety and health
Agenda
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Introduction
New Utah OSHA Director
Overview of Utah OSHA Priorities – Oil/Gas/Petroleum
Refineries & High Hazard Industries
◦ Silica – Date Extended for Comments
◦ High Risk Industries Emphasis
◦ Petroleum Refinery Process Safety Management
National Emphasis Program (NEP)
◦ Rulemaking to Improve Chemical Safety
Q&A
Introduction
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Paul Cannon, CSP,
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Safety and Health Compliance Officer, Utah OSHA
Work Cell Phone: 385-232-0177
Email: pcannon@utah.gov
33 plus years in safety, health, regulatory and program management
professions.
◦ (Overall experience in explosives, propellants, pyrotechnics, hazardous
materials/chemicals)
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Reynolds Metals Company, St. Louis, MO (1979-1981)
 Safety Manager
Olin Corporation, Marion, Illinois (1981-1988)
 Safety Engineer
 Senior Safety Engineer
 Plant Safety Supervisor
Thiokol/ATK, Brigham City, Utah (1988-2010)
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Senior Engineer, Aerospace Group, Corporate Auditor
Senior Engineer
Manager, Safety & Health
Safety Engineer
Program Manager
New Utah OSHA Director
Scott McKenzie
• 32 years Active Duty in the U.S. Navy
• Primary Specialties in Environmental Health,
Occupational Safety and Health and Public Health
• 801-530-6898
• smckenzie@utah.gov
Overview of Utah OSHA Priorities –
Oil/Gas/Petroleum Industries
• Silica – Date Extended for Comments – February 11, 2014
• OSHA Designated High Hazard Industries – 2014
• Petroleum Refinery Process Safety Management
National Emphasis Program (NEP) – Complete in 2014
• Rulemaking to Improve Chemical Safety – March 10,
2014
Silica
• OSHA has published in the Federal Register a “Notice of Proposed Rule
Making for Respirable Silica” on September 12, 2013.
• Current permissible exposure limit (PEL) for crystalline silica is based
on a formula and in which industry you work in.
• The PEL’s for the Construction and Shipyard industries allow
exposures twice as high as for workers in General Industry.
• The proposed PEL is 50 micrograms per cubic meter (µg/m3),
averaged over an 8-hour day. The new PEL would be the same for all
industries covered by the rule.
• Public comments on the proposed rule has been extended to February
11, 2014
OSHA Designated High Hazard Industries
Utah OSHA will be inspecting more High Hazard Industries in
the State of Utah.
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• Utah OSHA uses OSHA’s FY 14 High Hazard Health and
Safety List
• High Hazard Health
• High Hazard Safety
• High Hazard Non-Manufacturing Industries
Petroleum Refinery Process Safety Management
National Emphasis Program (NEP)
• Utah OSHA adopted NEP CPL 03-00-010 on September 26
2009
• Five Oil Refineries in the State of Utah
• Big West Oil LLC
• Chevron Products Company
• Holly Refining & Marketing Company
• Silver Eagle Refining Inc
• Tesoro Refining & Marketing Company
• NEP to be completed in 2014
Petroleum Refinery Process Safety Management
National Emphasis Program (NEP) Cont’d
Nationally, these four categories account for
70% of all violations
MECHANICAL INTEGRITY: Failure to perform inspections and tests, and failure to correct
deficiencies in a timely manner. This is a particular concern given the aging of refineries in
the United States.
PROCESS SAFETY INFORMATION: Failure to document compliance with Recognized and
Generally Accepted Good Engineering Practices to keep process safety information up to
date, and to document the design of emergency pressure relief systems.
OPERATING PROCEDURES: Failure to establish and follow procedures for key operating
phases, such as emergency shutdowns, and using inaccurate or out-of-date procedures.
PROCESS HAZARDS ANALYSIS: Lack of attention to human factors and facility siting, and
failing to address PHA findings and recommendations in a timely manner-- or, all too
often, failing to address them at all.
Rulemaking to Improve Chemical Safety
President Obama’s Executive Order 13650, dated August
1, 2013, “Improving Chemical Facility Safety and Security”
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• “Process Safety Management and Prevention of Major
Chemical Accidents”, Federal Register 12/9/13. Response
due March 10, 2014
• Proposed changes to 29 CFR 1910.106 (Flammable
Liquids), 29 CFR 1910.107 (Spray Finishing F.L./C.L.),
29 CFR 1010.109 (Explosive & Blasting Agents), and
29 CFR 1910.119 (PSM) Standards.
Rulemaking to Improve Chemical Safety Cont’d
17 Proposed Changes
• PSM Standard to cover the following:
1. Include flammable liquids in atmospheric storage
tanks within or connected to a PSM covered process.
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(29 CFR 1910.119(a)(1)(ii)(B))
2. Retain or remove exemption for oil-and gas-well
drilling and servicing operations. (29 CFR 1910.119(a)(2)(ii))
3. Define the “production” phase after the well has
been drilled, completed and placed into operation or
has been returned to operation. (29 CFR 1910.119(a)(2)(ii))
4. Expand PSM coverage for “Reactive Hazards”.
5. Update the List of Highly Hazardous Chemicals in
Appendix A of the PSM Standard. (29 CFR 1910.119, Appendix A)
Rulemaking to Improve Chemical Safety Cont’d
6. Require additional Management-System elements.
• Center of Chemical Process Safety (CCPS)-Risk Based
Process Safety (RBPS) + Other (New)
7. Require employers to evaluate updates to Recognized
and Generally Accepted Good Engineering Practices
(RAGAGEP). (New)
8. Add Definition of RAGAGEP. (New)
9. Expand PSM Standard to cover the Mechanical Integrity
of any Safety-Critical Equipment. (29 CFR 1910.119(j)(1))
10. Clarify that Employers must follow Management-of
Change (MOC) for Organizational changes, such as
management structure, budget cuts, personnel changes,
etc. (29 CFR 1910.119(l))
Rulemaking to Improve Chemical Safety Cont’d
11. Require Coordination of Emergency Planning with Local
Emergency Response Authorities. (29 CFR 1910.119(n))
12. Add required Third-Party Compliance Audits. (29 CFR
1910.119(o))
13. Expand Requirements to cover Dismantling and
Disposal of Explosives, Blasting Agents, and
Pyrotechnics. (29 CFR 1910.109(k)(1))
14. Update the Flammable Liquids and Spray Finishing
Standards to current consensus standards. (29 CFR 1910.106 & .107)
15. Update regulations addressing the Storage, Handling
and Management of Ammonium Nitrate. (29 CFR 1910.109)
Rulemaking to Improve Chemical Safety Cont’d
16. Change PSM Standard to include Retail Facilities in
NAICS Codes 44-45. (29 CFR 1910.119(a)(2)(i))
17. Adopt EPA’s policy for Risk Management Plan (RMP)listed chemicals that do not have listed concentrations.
• Change Enforcement Policy for Highly Hazardous
Chemicals Listed in Appendix A of the PSM Standard
without specific concentrations.
• 11 Chemicals has listed concentrations
• 126 Chemicals are silent on concentrations
What Utah OSHA Is Seeing
• Assumptions are made without validation
• Don’t Assume
• Verify 2 + 2 = 4
• If 2 + 2 ≠ 4, you don’t have the answer
• Higher incidence of serious injuries and fatalities
with Oil & Gas Service Companies
• Companies are organized and designed to increase
profit and reduce risks. This creates unique
challenges.
What Utah OSHA Is Seeing
• The interface and verification when jobs are
“handed off” to another individual or company needs
to be strengthened.
• Lack of or inadequate hazard recognition by
employees and supervision
• Non-routine, maintenance, and “we have always
done it that way before” allows complacency to creep
in.
What Utah OSHA Is Seeing
• Inadequate or lack of communication with
employees
• Multiple Languages, Cultures
Questions