(30a) California’s 2017 Process Safety Regulations for Oil Refineries - the Future of U.S. PSM Regulations?

On August 12, 2012 a pipe failure in the Chevron Richmond, California oil refinery crude unit led to large fire that endangered the lives of 19 workers and caused over 15,000 area residents to seek medical attention. In the wake of the incident, the US Chemical Safety Board (CSB) and Governor Brown’s California Interagency Working Group on Refinery Safety called for substantial revisions to the state’s process safety regulations for the state’s 14 oil refineries. In response, the California Department of Industrial Relations promulgated a revised, 24-part Process Safety Management (PSM) regulation, Process Safety for Oil Refineries, GISO §5189.1, which became enforceable on October 1, 2017.

The new regulations introduce substantial changes to the 12 existing PSM elements and add 9 new elements that include damage mechanism reviews, hierarchy of controls analysis, safety culture assessment, employee participation authorities, root cause investigative analysis, use of PSM indicators, human factors, management of organizational change, and safeguard protection analysis. Cal/OSHA will enforce these regulations with significant increases in staff positions that include recruitment of personnel with chemical and mechanical engineering backgrounds. The PSM revisions draw from the recommendations of CCPS’s Guidelines for Risk Based Process Safety (2007). The California regulations will require greater attention by refinery operators on strategies to anticipate, analyze and prevent process incidents.

California’s PSM standard for oil refineries represents the latest and most sweeping regulatory reform initiated by a US government entity in response to a major process incident. These reforms are poised to reframe the national discussion on the role of public policy in preventing major chemical accidents.