IUOE Local 381

United we bargain, divided we beg!

Welcome to IUOE Local 381's web site

Local 381 consists of the hourly maintenance, operations and lab employees employed by the Lion Oil Refinery located in El Dorado AR.

Why PSM?

Process Safety Management (PSM) is a part of the day to day operations at refineries and chemical plants because ….. well, for a lot of reasons. This would be an even longer article if I listed every reason, but the two most important reasons are: #1, It’s the right thing for folks in our line of business to do, and #2, There is a legal requirement in the form of rules and regulations.

The final PSM rule entitled Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents, was published in the United States Federal Register on February 24, 1992 and became part of OSHA’s regulations as 29 CFR Part 1910.119. Like most major regulatory initiatives, the need for PSM became apparent after several major catastrophes. During the 1980’s and early-1990’s there were several major accidents at refineries and chemicals plants including: Union Carbide 1984 Bhopal, India incident resulting in over 3,000 deaths; the October 1989 Phillips66 Chemical Plant explosion that killed 24 and injured 132; the July 1990 Arco Chemical incident that killed 17; the July 1990 BASF incident resulting in 2 deaths and 41 injuries; and the May 1991 IMC explosion that killed 8 workers and injured 128. Similar incidents occurred in Europe as well (Occidental Petroleum’s Piper Alpha North Sea Platform destroyed on July 6, 1988 killing 167). OSHA’s background documentation of the PSM final rule states “The continuing occurrence of incidents has provided impetus, internationally and nationally, for authorities to develop or consider the development of legislature and regulations directed toward eliminating or minimizing the potential for such events.”

The 1984 Bhopal incident triggered a worldwide concern for the safety of workers and the public that lived near chemical plants and refineries. Less than a year after Bhopal, there was another serious chemical release in West Virginia at a Union Carbide plant (owners of the Bhopal plant). There were no deaths as a result of the release but 135 people were injured. OSHA and EPA evaluated the existing regulations and programs that they had in place at that time in congressional hearings. OSHA concluded that the regulations they had in place did a good job of addressing the day-to-day safety of workers and the general hazards of chemicals, but they did not address the precautions necessary to prevent large accidental releases that could result in catastrophes. OSHA believed that available evidence supported a need for standards aimed at the processing and handling of specific highly hazardous chemicals.

Government agencies as well as, trade and labor organizations worldwide became active in the search for a solution to the problem of accidents with highly hazardous chemicals. The American Institute of Chemical Engineers formed a separate branch, the Center for Chemical Process Safety (www.aiche.org/CCPS). The American Petroleum Institute developed recommended practices to address the protection of employees and the public (Recommended Practice 750). The Organization Resources Counselors (ORC) and the World Bank developed and published a Code of Practices in the Prevention of Major Accidents.

OSHA published the first proposed PSM rule in the Federal Register on July 17, 1990 (55 FR 29150). Within four months of this initial publication, the Clean Air Act Amendments (CAAA) was enacted into law and included in section 304 that OSHA in coordination with EPA would develop a process safety standard to prevent accidental releases of chemicals which could pose a threat to employees, the public and environment. The CAAA required that the standard include a list of highly hazardous chemicals that include toxic, flammable, highly reactive and explosive substances.

The final PSM rule includes this list of highly hazardous chemicals (29 CFR Part 1910.119 Appendix A) along with fourteen elements to the standards. The fourteen elements of PSM are: Employee Participation; Process Safety Information; Process Hazards Analysis (PHA’s); Operating Procedures; Training; Contractor Safety; Pre-Startup Safety Review (PSSR’s); Mechanical Integrity; Hot Work Permits; Management of Change (MOC’s); Incident Investigations; Emergency Planning and Response; Compliance Safety Audits and Trade Secrets. This is the PSM Program that all refineries in the US must operate under. It is a program required by both OSHA and EPA.

In March of 2005, an explosion and fire at BP’s Texas City Refinery killed 15 and injured 180 workers. The Chemical Safety Board (CSB) investigated the incident for almost two years, reviewing BP’s safety culture from the highest levels of management to the hourly workers and contractors. The BP Texas City Explosion is the most thoroughly investigated industrial accidents in history and has produced some of the most comprehensive and provocative reports and studies. BP, the refinery industry and government agencies (OSHA and EPA) received blame for this accident. In response to the BP accident, OSHA is conducting PSM audits at all refineries in the US. Trade organizations and unions are working together on new industrial standards and the overall attention to PSM is at its highest level since the regulation was enacted.

Jesse C. Ducommun stated in the Baker Report on the BP accident: “It should not be necessary for each generation to rediscover principles of process safety which the generation before discovered. We must learn from the experience of others rather than learn the hard way. We must pass on to the next generation a record of what we have learned.”

Hopefully this little background summary will help clear why we are always hearing terms like; MOC (Management of Change), PSSR (Pre-Startup Safety Review) and PHA (Process Hazard Analysis). The PSM regulations have more common sense and practical application in them than other regulations I have worked with in the past. Everyone in the refinery and chemical processing business should be feeling a new awareness and importance placed on PSM. This is a benefit that can increase the safety for employees, the public, the environment, our jobs and communities.

Here are some links to information on the subjects discussed:

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