Recommendations

Open: 0% | Closed: 100%

Final Report Released On: January 20, 2011

2008-08-I-WV-2

Review and revise, as necessary, all Bayer production unit standard operating procedures to ensure they address all operating modes (startup, normal operation, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup following a turnaround or emergency shutdown), are accurate, and approved.

Status: Closed - Acceptable ActionThis link opens a new window

2008-08-I-WV-3

Ensure that all facility fire brigade members are trained in the National Incident Management System, consistent with municipal and state emergency response agencies.

Status: Closed - Acceptable ActionThis link opens a new window

2008-08-I-WV-4

Evaluate the fenceline air monitor program against federal, state, and local regulations, and Bayer corporate policies, and upgrade and install air monitoring devices as necessary to ensure effective monitoring of potential releases of high-hazard chemicals at the perimeter of the facility.

Status: Closed - Acceptable ActionThis link opens a new window
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2008-08-I-WV-5

Commission an independent human factors and ergonomics study of all Institute site PSM/RMP covered process control rooms to evaluate the human-control system interface, operator fatigue, and control system familiarity and training. Develop and implement a plan to resolve all recommendations identified in the study that includes assigned responsibilities, required corrective actions, and completion dates.

Status: Closed - Acceptable ActionThis link opens a new window
DownloadThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: January 20, 2011

2008-08-I-WV-1

Revise the corporate PHA policies and procedures to require:
a. Validation of all PHA assumptions to ensure that risk analysis of each PHA scenario specifically examines the risk(s) of intentional bypassing or other nullifications of safeguards,
b. Addressing all phases of operation and special topics including those cited in chapter 9 of "Guidelines for Hazard Evaluation Procedures" (CCPS, 2008), and
c. Training all PHA facilitators on the revised policies and procedures prior to assigning the facilitator to a PHA team.
Ensure all PHAs are updated to conform to the revised procedures.

Status: Closed - Acceptable ActionThis link opens a new window
Recommendations Status Change SummaryThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: January 20, 2011

2008-08-I-WV-12

In light of the findings of this report and the serious potential hazards to workers and the public from chemicals used and stored at the Bayer Institute site (such as phosgene, MIC, and methomyl), conduct a comprehensive Risk Management Program (RMP) inspection of the complex. Coordinate with the Occupational Safety and Health Administration, as appropriate.

Status: Closed - No Longer ApplicableThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: January 20, 2011

2008-08-I-WV-6

Establish a Hazardous Chemical Release Prevention Program to enhance the prevention of accidental releases of highly hazardous chemicals, and optimize responses in the event of their occurrence. In establishing the program, study and evaluate the possible applicability of the experience of similar programs in the country, such as those summarized in Section 5.3 of this report. As a minimum:

a. Ensure that the new program:
1. Implements an effective system of independent oversight and other services to enhance the prevention of accidental releases of highly hazardous chemicals
2. Facilitates the collaboration of multiple stakeholders in achieving common goals of chemical safety; and,
3. Increases the confidence of the community, the workforce, and the local authorities in the ability of the facility owners to prevent and respond to accidental releases of highly hazardous chemicals.

b. Define the characteristics of chemical facilities that would be covered by the new Program, such as the hazards and potential risks of their chemicals and processes, their quantities, and similar relevant factors;

c. Ensure that covered facilities develop, implement, and submit for review and approval:
1. Applicable hazard and process information and evaluations.
2. Written safety plans with appropriate descriptions of hazard controls, safety culture and human factors programs with employee participation, and consideration of the adoption of inherently safer systems to reduce risks
3. Emergency response plans; and,
4. Performance indicators addressing the prevention of incidents and chemical incidents.

d. Ensure that the program has the right to evaluate the documents submitted by the covered facilities, and to require modifications, as necessary

e. Ensure that the program has right-of-entry to covered facilities, and access to requisite information to conduct periodic audits of safety systems and investigations of chemical releases;

f. Establish a system of fees assessed on covered facilities sufficient to cover the oversight and related services to be provided to the facilities including necessary technical and administrative personnel; and,

g. Consistent with applicable law, ensure that the program provides reasonable public participation with the program staff in review of facility programs and access to:
1. The materials submitted by covered facilities (e.g., hazard evaluations, safety plans, emergency response plans);
2. The reviews conducted by program staff and the modifications triggered by those reviews;
3. Records of audits and incident investigations conducted by the program;
4. Performance indicator reports and data submitted by the facilities, and;
5. Other relevant information concerning the hazards and the control methods overseen by the program.

h. Ensure that the program will require a periodic review of the designated agency activities and issue a periodic public report of its activities and recommended action items

Status: Closed - Unacceptable Action/No Response ReceivedThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: January 20, 2011

2008-08-I-WV-8

Work with the Kanawha and Putnam counties Emergency Response Directors to prepare and issue a revision to the Kanawha Putnam County Emergency Response Plan and Annexes to address facility emergency response and Incident Command when such functions are provided by the facility owner.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: January 20, 2011

2008-08-I-WV-10

In light of the findings of this report and the serious potential hazards to workers and the public from chemicals used and stored at the Bayer Institute site (such as phosgene, MIC, and methomyl), conduct a comprehensive Process Safety Management (PSM) inspection of the complex. Coordinate with the Environmental Protection Agency, as appropriate.

Status: Closed - No Longer ApplicableThis link opens a new window
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2008-08-I-WV-11

Revise the Chemical National Emphasis Program and the targeting criteria to:
a. Expand the coverage to all OSHA regions,
b. Include in the targeting criteria from which potential inspections are selected all establishments that have submitted certifications of completions of actions in response to previous PSM citations;
c. Require NEP inspections to examine the status of compliance of all previously cited PSM program items for which the company has submitted certifications of completion to OSHA.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: January 20, 2011

2008-08-I-WV-7

Work with the Director of the Kanawha-Charleston Health Department to ensure the successful planning, fee collection, and implementation of the Hazardous Chemical Release Prevention Program as described in Recommendation 2008-08-WV-R6, above, including the provision of services to all eligible facilities in the State.
 

Status: Closed - No Longer ApplicableThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: January 20, 2011

2008-08-I-WV-7

Work with the Director of the Kanawha-Charleston Health Department to ensure the successful planning, fee collection, and implementation of the Hazardous Chemical Release Prevention Program as described in Recommendation 2008-08-WV-R6, above, including the provision of services to all eligible facilities in the State.
 

Status: Closed - No Longer ApplicableThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: January 20, 2011

2008-08-I-WV-9

Revise the Fire Department Evaluation Administrative Section Matrix addressing the periodic inspection of local fire departments to include a requirement for inspectors to examine and identify the status of National Incident Management System fire department personnel training.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: December 06, 2001

2001-02-I-IN-10

Communicate findings of this report to your membership.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: December 06, 2001

2001-02-I-IN-10

Communicate findings of this report to your membership.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: December 06, 2001

2001-02-I-IN-10 URGENT!

Communicate findings of this report to your membership.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: December 06, 2001

2001-02-I-IN-7

Conduct periodic audits of work authorization, line and equipment opening, deadleg management programs, and decommissioning and demolition activities at your steelmaking facilities. Share findings with the workforce.

Status: Closed - Unacceptable Action/No Response ReceivedThis link opens a new window

2001-02-I-IN-8

Revise the Material Safety Data Sheet (MSDS) for COG condensate to highlight the potential flammability hazard. Ensure that management at your steelmaking facilities trains employees and informs contractors with regard to the potential presence of flammable liquids when working with or opening COG condensate piping and equipment.

Status: Closed - Acceptable ActionThis link opens a new window

2001-02-I-IN-9

Communicate findings of this report to the workforce and contractors at Bethlehem Steel's steelmaking facilities.

Status: Closed - Reconsidered/SupersededThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: December 06, 2001

2001-02-I-IN-1

Implement a work authorization program that requires higher levels of management review, approval, and oversight for jobs that present higher levels of risk, such as opening lines potentially containing flammable liquids where there is no low point drain.

Status: Closed - Acceptable ActionThis link opens a new window

2001-02-I-IN-2

Monitor the accumulation and flammability of COG condensate throughout the mill. Address potentially hazardous changes in condensate accumulation rates and flammability.

Status: Closed - Acceptable ActionThis link opens a new window

2001-02-I-IN-3

Survey the mill for deadlegs and implement a program for resolving the hazards. Develop guidance for plant personnel on the risks of deadlegs and their prevention. Include deadlegs in plant winterization planning.

Status: Closed - Unacceptable Action/No Response ReceivedThis link opens a new window

2001-02-I-IN-4

Provide drains at low points in piping to allow for the safe draining of potentially flammable material.

Status: Closed - Unacceptable Action/No Response ReceivedThis link opens a new window

2001-02-I-IN-5

Ensure that Burns Harbor and contractor employees are trained with regard to the potential presence of flammable liquids when working with or opening COG or condensate piping and equipment.

Status: Closed - Acceptable ActionThis link opens a new window

2001-02-I-IN-6

Establish procedures to ensure that insulation is replaced when removed for maintenance.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: December 06, 2001

2001-02-I-IN-10

Communicate findings of this report to your membership.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 13, 2007

2006-3-I-FL-11

Revise CDM policies and procedures to ensure that appropriate quality control measures are applied so that designs specify appropriate materials and comply with applicable safety standards. Ensure that wastewater treatment plant design engineers are aware of the importance of proper material selection as well as the findings and recommendations of this report.

Status: Closed - Acceptable ActionThis link opens a new window

2006-3-I-FL-12

Communicate the findings and recommendations of this report to all companies that contracted with CDM for methanol and other flammable liquid systems that were constructed with aboveground plastic pipe. Recommend replacing plastic pipe with an appropriate material in accordance with NFPA 30 and OSHA 1910.106.

Status: Closed - Acceptable ActionThis link opens a new window

2006-3-I-FL-13

Communicate the findings and recommendations of this report to all companies that contracted with CDM for flammable liquid systems that included a flame arrester. Emphasize the importance of periodic maintenance of the flame arrester to ensure its effective performance.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 13, 2007

2006-3-I-FL-3

Adopt city ordinances to require departments to implement policies, practices, and procedures concerning safety and health in the workplace for city employees that are at least as effective as relevant OSHA standards. Emphasize compliance with chemical standards, including hot work procedures (OSHA Welding, Cutting, and Brazing Standard, Sections 1910.251 and 1910.252) and chemical hazard communication (OSHA Hazard Communication Standard 29 CFR 1910.1200). Implement procedures to ensure compliance with these policies, practices and procedures.

Status: Closed - Acceptable ActionThis link opens a new window

2006-3-I-FL-4

Ensure that flammable liquid storage tanks used throughout the city comply with NFPA 30 and minimum federal standards in 29 CFR 1910.106, including appropriate piping and flame arresters.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 13, 2007

2006-3-I-FL-1

Enact legislation requiring state agencies and each political subdivision (i.e. counties and municipalities) of Florida to implement policies, practices, procedures, including chemical hazards covering the workplace health and safety of Florida public employees that are at least as effective as OSHA. Establish and fund a mechanism to ensure compliance with these standards. Consider legislation providing coverage of Florida public employees under an occupational safety and health program in accordance with Section 18(b) of the Occupational Safety and Health Act of 1970, and Code of Federal Regulations 29 CFR 1956.1.

Status: Closed - Unacceptable Action/No Response ReceivedThis link opens a new window

2006-3-I-FL-2

Develop and fund a workplace safety and health consultation program for Florida public employees similar to the private sector program currently administered by the Florida Safety Consultation Program at the University of South Florida.

Status: Closed - Unacceptable Action/No Response ReceivedThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 13, 2007

2006-3-I-FL-9

Work with the Water Environment Federation to prepare and distribute a technical bulletin containing information on the safe receipt, storage, use, and dispensing of methanol in wastewater treatment plants. In addition, include information on basic fire and explosion prevention measures when using bulk methanol (e.g., flame arrester maintenance, hot work programs, electrical classification).

Status: Closed - Acceptable ActionThis link opens a new window

2006-3-I-FL-10

Work with the Water Environment Federation to prepare safety training materials for wastewater treatment facilities that use methanol.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 13, 2007

2006-3-I-FL-5

Revise NFPA 30 to specifically exclude the use of thermoplastics in aboveground flammable liquid service.

Status: Closed - Acceptable ActionThis link opens a new window
Recommendation Status Change Summary This link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 13, 2007

2006-3-I-FL-6

Revise 29 CFR 1910.106 to specifically exclude the use of thermoplastics in above ground flammable liquid service.

Status: Closed - Reconsidered/SupersededThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 13, 2007

2006-3-I-FL-7

Work with the Methanol Institute to prepare and distribute a technical bulletin containing information on the safe receipt, storage, use, and dispensing of methanol in wastewater treatment plants. In addition, include information on basic fire and explosion prevention measures when using bulk methanol (e.g., flame arrester maintenance, hot work programs, electrical classification).

Status: Closed - Acceptable ActionThis link opens a new window
Recommendation Status Change Summary This link opens a new window

2006-3-I-FL-8

Work with the Methanol Institute to prepare safety training materials for wastewater treatment facilities that use methanol.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: September 17, 2003

2003-06-I-TX-16

Revise API RP-2219, Safe Operation of Vacuum Trucks in Petroleum Service, and API Order No. G00004, Guidelines for Commercial Exploration and Production Waste Management Facilities, to discuss the hazards of unloading potentially flammable or flammable liquids onto an open unloading area, such as a concrete pad. Recommend other alternatives for minimizing vapor generation, such as unloading of flammable liquids into a closed piping system.

Status: Closed - Acceptable ActionThis link opens a new window

2003-06-I-TX-17

Communicate the findings and recommendations of this report to your membership. Emphasize that basic sediment and water (BS&W) removed from crude oil and condensate storage tanks requires special handling, in addition to compliance with Occupational Safety and Health Administration (OSHA) or U.S. Department of Transportation (DOT) regulations, if it contains sufficient hydrocarbons (either residual or mixed in during the removal process) to be classified a flammable liquid as defined by each regulation.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: September 17, 2003

2003-06-I-TX-8

Develop a written Waste Acceptance Plan as recommended by API Order No. G00004, Guidelines for Commercial Exploration and Production Waste Management Facilities. Require the shipper or carrier to properly classify the flammability hazard of exploration and production (E&P) waste liquids. Require the hauler to provide information that identifies the flammability hazard of the material before accepting the load, such as a material safety data sheet (MSDS).

Status: Closed - Acceptable ActionThis link opens a new window

2003-06-I-TX-9

Develop and implement written procedures and provide training to employees on the safe handling of all waste liquids delivered to the facility in accordance with API Order No. G00004, Guidelines for Commercial Exploration and Production Waste Management Facilities; and API RP-2219, Safe Operation of Vacuum Trucks in Petroleum Service. Include requirements for proper grounding of trucks and eliminating other sources of ignition (e.g., facility electrical equipment and smoking in unloading areas). Ensure that the material is presented in languages or formats that are clearly understood by all affected personnel.

Status: Closed - Acceptable ActionThis link opens a new window

2003-06-I-TX-10

Develop written procedures and provide training to employees on unloading all flammable or potentially flammable E&P waste liquids. Avoid unloading flammable liquids onto an open work area, such as the mud disposal and washout pad. Include alternative unloading method(s), such as using a closed piping system to minimize vapor generation. Ensure that the material is presented in languages or formats that are clearly understood by all affected personnel.

Status: Closed - Acceptable ActionThis link opens a new window

2003-06-I-TX-11

Develop written emergency procedures and provide training to employees on response to abnormal or emergency situations, including uncontrolled flammable vapor releases that can result in a fire or explosion hazard. Ensure that the material is presented in languages or formats that are clearly understood by all affected personnel.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: September 17, 2003

2003-06-I-TX-12

Publish an information document for exploration and production (E&P) industry employers (including producers/shippers/offerors, motor carriers, and disposal facility operators) involved in the transportation of basic sediment and water (BS&W) and other E&P waste liquids on public highways. (2003-06-I-TX-R12): -Emphasize the importance of, and responsibility for, properly classifying and identifying flammable waste liquids. -Reference the Occupational Safety and Health Administration (OSHA) requirements for obtaining material safety data sheets (MSDS) from the shipper and the required content of DOT shipping papers. -Include specific reference to this CSB Investigation Report and the American Petroleum Institute (API) recommended practices cited in this report.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: September 17, 2003

2003-06-I-TX-18

Communicate the findings and recommendations of this report to your membership. Emphasize emergency response to diesel engine overspeed caused by exposure to flammable vapor atmospheres.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: September 17, 2003

2003-06-I-TX-1

Provide documentation of the potential flammability hazard of exploration and production (E&P) waste liquids-such as a material safety data sheet (MSDS)- to all employees, contract personnel, and haulers handling waste liquids generated at well sites. Emphasize that mixing condensate with basic sediment and water (BS&W) during the removal process can significantly increase the flammability hazard. The mixture in the transport container should be treated as a flammable liquid absent positive identification to the contrary.

Status: Closed - Acceptable ActionThis link opens a new window

2003-06-I-TX-2

Review and revise company gauging and waste liquid removal protocols as necessary to minimize the inadvertent removal and subsequent disposal of hydrocarbon product when removing BS&W from product storage tanks.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: September 17, 2003

2003-06-I-TX-13

Issue a Safety and Health Information Bulletin on the potential flammability hazard associated with bulk transportation of oilfield exploration and production (E&P) waste liquids. Summarize OSHA requirements for proper hazard classification by the shipper and for the use of material safety data sheets (MSDS). Summarize U.S. Department of Transportation (DOT) requirements for proper hazard classification and manifesting of flammable liquids, approved container design, and periodic testing. Discuss safe handling to minimize the generation of flammable vapor and to control ignition sources from vehicle-mounted equipment and facility equipment. Discuss the need for the employer to provide all worker safety information in languages or formats that are clearly understood by all affected personnel. Summarize the requirements for proper labeling of storage tanks to clearly identify the hazard of the contents to all employees and contractors working at the well site.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: September 17, 2003

2003-06-I-TX-3

Ensure that the written procedures for hazard identification require that all customers requesting loading and transportation of exploration and production (E&P) waste liquids provide written notification, such as a material safety data sheet (MSDS), listing the potential flammability hazard.

Status: Closed - Acceptable ActionThis link opens a new window

2003-06-I-TX-4

Ensure that the written procedures for safe operation of vacuum trucks incorporate applicable good practices, including techniques to minimize the possibility of exposing the diesel engine to flammable vapor, as provided in API RP-2219, Guidelines for Commercial Exploration and Production Waste Management Facilities.

Status: Closed - Exceeds Recommended ActionThis link opens a new window

2003-06-I-TX-5

Develop written operating procedures that incorporate best practices for unloading storage tank waste liquids, such that drivers accurately measure the quantity of liquid removed from the storage tank and minimize removal of product, such as flammable condensate.

Status: Closed - Acceptable ActionThis link opens a new window

2003-06-I-TX-6

Ensure that written emergency procedures address the safe response to abnormal diesel engine operation due to a flammable vapor atmosphere. Explain that the normal engine shutoff method will not function as long as flammable vapor continues to enter the intake system.

Status: Closed - Acceptable ActionThis link opens a new window

2003-06-I-TX-7

Conduct and document training for all personnel who handle waste liquids, using languages or formats that are clearly understood by all affected personnel. Address the potential flammability hazard associated with E&P waste liquids, emphasizing how the withdrawal procedure is likely to increase the flammability of the vacuum truck contents through unavoidable mixing of product and basic sediment and water (BS&W). Describe operating and emergency response to diesel engine overspeed caused by a flammable vapor atmosphere.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: September 17, 2003

2003-06-I-TX-14

Require that all permitted drillers and producers identify and document (e.g., material safety data sheet [MSDS]) the potential flammability hazard of exploration and production (E&P) waste liquids. Provide the information to workers and contractors in languages clearly understood by the recipients.

Status: Closed - Acceptable ActionThis link opens a new window

2003-06-I-TX-15

Provide information (e.g., safety bulletin) to industry on the potential flammability hazard associated with basic sediment and water (BS&W) and other E&P waste liquids. Waste liquids can contain sufficient hydrocarbons to be classified as flammable liquids. The waste liquid removal method can result in removing significant quantities of flammable hydrocarbon product such that the mixture in the transport container may require classification as a flammable liquid under Occupational Safety and Health Administration (OSHA) or U.S. Department of Transportation (DOT) regulations.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 100% | Closed: 0%

Final Report Released On: June 24, 2024

2022-01-I-OH-5

Develop a new publication or revise an existing publication, such as API Recommended Practice 556 Instrumentation, Control, and Protective Systems for Gas Fired Heaters, to incorporate the process hazards associated with Fuel Gas Mix Drum overflow. The publication should include the following at a minimum:

a) Description of the process hazards associated with Fuel Gas Mix Drum overflow and the consequential impacts on equipment using fuel gas,

b) Guidance for Fuel Gas Mix Drum design and sizing criteria which includes consideration of condensation, entrainment, overflow, and draining,

c) Guidance for instrumentation to detect high level to prevent overfilling of Fuel Gas Mix Drums, and

d) Recommended practices for selecting preventive safeguards to prevent overfilling of Fuel Gas Mix Drums.

Status: Open - Awaiting Response or Evaluation/Approval of ResponseThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

2022-01-I-OH-6

Develop a publication that addresses preventing the overflow of pressure vessels such as towers and drums. The publication should be applicable to both new and existing pressure vessels. Include the following at a minimum:

a) Description of typical overflow events that could result during normal, upset, or transient operations (startup, shutdown, standby) including the formation of a vapor cloud,

b) Recommended practices for instrumentation to monitor and detect a pressure vessel overflow,

c) Process hazard analysis guidance for pressure vessel overflow scenarios,

d) Recommended practices for safeguards to prevent a pressure vessel overflow,

e) Recommended field and board operator process safety training topics and methods to prevent a pressure vessel overflow,

f) Guidelines for process safety assessments to prevent a pressure vessel overflow, and

g) Incorporate lessons learned from this CSB investigation and the CSB’s BP Texas City Refinery investigation throughout the document.

Status: Open - Awaiting Response or Evaluation/Approval of ResponseThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

Open: 100% | Closed: 0%

Final Report Released On: June 24, 2024

2022-01-I-OH-7

Revise American National Standard ANSI/ISA 18.2-2016, Management of Alarm Systems for the Process Industries, to include performance targets for short-term alarm flood analysis so that users can evaluate alarm flood performance for a single alarm flood event. The performance targets should include:

a) number of alarm floods,
b) duration of each flood,
c) alarm count in each flood, and
d) peak alarm rate for each flood.

At a minimum, a target peak alarm flood rate should be defined, such as in the guidance provided by the ASM Consortium or Engineering Equipment and Materials Users Association (EEMUA), to establish trigger points that require alarm performance improvement actions.

Status: Open - Awaiting Response or Evaluation/Approval of ResponseThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

Open: 75% | Closed: 25%

Final Report Released On: June 24, 2024

2022-01-I-OH-1

Revise the safeguards used in the refinery’s process hazard analyses high level and overflow scenarios. At a minimum, establish effective preventive safeguards that use engineered controls to prevent liquid overfill and do not rely solely on human intervention.

Status: Open - Acceptable Response or Alternate ResponseThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

2022-01-I-OH-2

Revise the Abnormal Situation Management policy to incorporate guidance provided by the ASM Consortium and the Center for Chemical Process Safety (CCPS). The revised policy should include, at a minimum:

a) A broader definition of abnormal situations, such as that defined by the CCPS,

b) Additional predictable abnormal situations and their associated corrective procedures. At a minimum include the following abnormal situations:

1) unplanned crude slate changes,
2) continued operation of the Crude 1 unit with the naphtha hydrotreater unit shut down, and
3) an emergency pressure-relief valve opening.

c) Guidance to determine when an abnormal situation is becoming too difficult to manage and the appropriate actions to take, such as shutting down a process, putting it into a circulation mode, or implementing proper procedures for bringing it to a safe state.

Status: Open - Acceptable Response or Alternate ResponseThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

2022-01-I-OH-3

Develop and implement a policy or revise existing policy that clearly provides employees with the authority to stop work that is perceived to be unsafe until the employer can resolve the matter. This should include detailed procedures and regular training on how employees would exercise their stop work authority. Emphasis should be placed on exercising this authority during abnormal situations, including alarm floods.

Status: Open - Awaiting Response or Evaluation/Approval of ResponseThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

2022-01-I-OH-4

Revise the ‘Toledo Alarm Philosophy’ by incorporating the Engineering Equipment and Manufacturers Users Association (EEMUA) guidance for alarm rate following an upset and not limiting alarm performance to a single metric averaged over a month. In addition to including analyzing individual alarm flood events, the revised philosophy document should improve refinery alarm performance to reduce alarm flood duration and peak rate for events similar to the September 20, 2022, incident. Consult EEMUA Publication 191, Chapter 6.5.1, for guidance regarding abnormal condition performance levels. Apply the improved performance levels where applicable, but specifically to the Crude 1 control board alarm performance.

Status: Closed - Acceptable ActionThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 20, 2007

2005-4-I-TX-2 URGENT!

In light of the findings concerning the March 23rd incident at BP's Texas City refinery, revise your Recommended Practice 752, Management of Hazards Associated with Location of Process Plant Buildings or issue a new Recommended Practice to ensure the safe placement of occupied trailers and similar temporary structures away from hazardous areas of process plants. Ensure that the new recommended practice:

- Protects occupants from accident hazards such as heat, blast overpressure, and projectiles;

- Establishes minimum safe distances for trailers and similar temporary structures away from hazardous areas of process plants; and

- Evaluates the siting of trailers under a separate methodology from permanent structures, since trailers are more susceptible to damage, are more readily relocated, and likely do not need to be placed near hazardous areas.

Status: Closed - Acceptable ActionThis link opens a new window

2005-4-I-TX-3 URGENT!

Issue a safety alert to your membership to take prompt action to ensure the safe placement of occupied trailers away from hazardous areas of process plants.

Status: Closed - Acceptable ActionThis link opens a new window

2005-4-I-TX-4

Revise API Recommended Practice 521, Guide for Pressure Relieving and Depressurizing Systems to ensure that the guidelines:

- Identifies overfilling vessels as a potential hazard for evaluation in selecting and designing pressure relief and disposal systems;

- Addresses the need to adequately size disposal drums for credible worse-case liquid relief scenarios, based on accurate relief valve and disposal collection piping studies; and

- Warns against the use of atmospheric blowdown drums and stacks attached to collection piping systems that receive flammable discharges from multiple relief valves and urges the use of appropriate inherently safer alternatives such as a flare system

Status: Closed - Acceptable ActionThis link opens a new window
Recommendations Status Change SummaryThis link opens a new window

2005-4-I-TX-6

Develop a new consensus American National Standards Institute (ANSI) standard that creates performance indicators for process safety in the refinery and petrochemical industries. Ensure that the standard identifies leading and lagging indicators for nationwide public reporting as well as indicators for use at individual facilities. Include methods for the development and use of the performance indicators. Ensure that:

a. the committees are accredited and conform to ANSI principles of openness, balance, due process, and consensus;

b. include representation of diverse sectors such as industry, labor, government, public interest and environmental organizations and experts from relevant scientific organizations and disciplines.

Status: Closed - Acceptable Alternative ActionThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

2005-4-I-TX-7

Develop a new consensus American National Standards Institute (ANSI) standard with fatigue prevention guidelines for the refining and petrochemical industries that, at a minimum, limit hours and days of work and address shift work. In the development of the standard, ensure that the committees:

a. are accredited and conform to ANSI principles of openness, balance, due process, and consensus;

b. include representation of diverse sectors such as industry, labor, government, public interest and environmental organizations and experts from relevant scientific organizations and disciplines.

Status: Closed - Acceptable ActionThis link opens a new window
Recommendation Status ChangeThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 20, 2007

2005-4-I-TX-1 URGENT!

Commission an independent panel to assess and report on the effectiveness of BP North America's corporate oversight of safety management systems at its refineries and its corporate safety culture. Provide the panel with necessary funding, resources, and authority - including full access to relevant data, corporate records, and employee interviews - in order to conduct a thorough, independent, and credible inquiry. Ensure that, at a minimum, the panel report examines and recommends any needed improvements to:

• Corporate safety oversight, including the safe management of refineries obtained through mergers and acquisitions;
• Corporate safety culture, including the degree to which:

- Corporate officials exercise appropriate leadership to promote adherence to safety management systems;

- Process safety is effectively incorporated into management decisionmaking at all levels;

- Employees at all levels are empowered to promote improved process safety;

- Process safety programs receive adequate resources and are appropriately positioned within organizational structures;

• Corporate and site safety management systems, specifically:

- Near-miss reporting and investigation programs;

- Mechanical integrity programs;

- Hazard analysis programs, management-of-change programs, and up-todate operating procedures for processes with catastrophic potential;

- Siting policies for occupied structures near hazardous operating units.

Ensure that the panel has a diverse makeup, including an external chairperson; employee representatives; and outside safety experts, such as experts in process safety; experts in corporate culture, organizational behavior, and human factors; and experts from other high-risk sectors such as aviation, space exploration, nuclear energy, and the undersea navy. Ensure that the report and recommendations of the independent panel, which should be completed within 12 months, are made available to the BP workforce and to the public.

Status: Closed - Acceptable ActionThis link opens a new window

2005-4-I-TX-11

Appoint an additional non-executive member of the Board of Directors with specific professional expertise and experience in refinery operations and process safety. Appoint this person to be a member of the Board Ethics and Environmental Assurance Committee.

Status: Closed - Acceptable Alternative ActionThis link opens a new window
Recommendations Status Change SummaryThis link opens a new window

2005-4-I-TX-12

Ensure and monitor that senior executives implement an incident reporting program throughout your refinery organization that:

a. encourages the reporting of incidents without fear of retaliation;

b. requires prompt corrective actions based on incident reports and recommendations, and tracks closure of action items at the refinery where the incident occurred and other affected facilities; and

c. requires communication of key lessons learned to management and hourly employees as well as to the industry.

Status: Closed - Acceptable ActionThis link opens a new window

2005-4-I-TX-13

Ensure and monitor that senior executives use leading and lagging process safety indicators to measure and strengthen safety performance in your refineries.

Status: Closed - Acceptable ActionThis link opens a new window
DownloadThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 20, 2007

2005-4-I-TX-14

Evaluate your refinery process units to ensure that critical process equipment is safely designed. At a minimum: 

a. Ensure that distillation towers have effective instrumentation and control systems to prevent overfilling such as multiple level indicators and appropriate automatic controls.

b. Configure control board displays to clearly indicate material balance for distillation towers.

Status: Closed - Acceptable ActionThis link opens a new window

2005-4-I-TX-16

Work with the United Steelworkers Union and Local 13-1 to establish a joint program that promotes the reporting, investigation, and analysis of incidents, near-misses, process upsets, and major plant hazards without fear of retaliation. Ensure that the program tracks recommendations to completion and shares lessons learned with the workforce.

Status: Closed - Acceptable ActionThis link opens a new window

2005-4-I-TX-15

Ensure that instrumentation and process equipment necessary for safe operation is properly maintained and tested. At a minimum: 

a. Establish an equipment database that captures the history of testing, inspections, repair, and successful work order completion.

b. Analyze repair trends and adjust maintenance and testing intervals to prevent breakdowns.

c. Require repair of malfunctioning process equipment prior to unit startups.

Status: Closed - Acceptable ActionThis link opens a new window

2005-4-I-TX-17

Improve the operator training program. At a minimum, require:

a. face-to-face training conducted by personnel with process-specific knowledge and experience who can assess trainee competency, and;

b. training on recognizing and handling abnormal situations including the use of simulators or similar training tools.

Status: Closed - Acceptable ActionThis link opens a new window

2005-4-I-TX-18

Require additional board operator staffing during the startup of process units. Ensure that hazard reviews address staffing levels during abnormal conditions such as startups, shutdowns, and unit upsets.

Status: Closed - Acceptable ActionThis link opens a new window

2005-4-I-TX-19

Require knowledgeable supervisors or technically trained personnel to be present during especially hazardous operation phases such as unit startup.

Status: Closed - Acceptable ActionThis link opens a new window

2005-4-I-TX-20

Ensure that process startup procedures are updated to reflect actual process conditions.

Status: Closed - Acceptable ActionThis link opens a new window

2005-4-B-TX-1

Revise the maintenance quality control program to require positive material identification testing or another suitable material verification process for all critical service alloy steel piping components removed and reinstalled during maintenance and inform work crews of special material handling precautions.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 20, 2007

2005-4-I-TX-10

Issue management of change guidelines that address the safe control of the following:

a. major organizational changes including mergers, acquisitions, and reorganizations;

b. changes in policies and budgets;

c. personnel changes; and

d. staffing during process startups, shutdowns and other abnormal conditions.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 20, 2007

2005-4-B-TX-2

Develop / update the written piping component installation quality control procedure to require positive material identification testing or other suitable verification or tracking process for all alloy steel piping components removed during maintenance.

Status: Closed - Acceptable ActionThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 20, 2007

2005-4-I-TX-3 URGENT!

Issue a safety alert to your membership to take prompt action to ensure the safe placement of occupied trailers away from hazardous areas of process plants.

Status: Closed - Acceptable ActionThis link opens a new window
DownloadThis link opens a new window

Open: 33% | Closed: 67%

Final Report Released On: March 20, 2007

2005-4-I-TX-5

Implement a national emphasis program for all oil refineries that focuses on:

- The hazards of blowdown drums and stacks that release flammables to the atmosphere instead of to an inherently safer disposal system such as a flare. Particular attention should be paid to blowdown drums attached to collection piping systems servicing multiple relief valves;

- The need for adequately sized disposal knockout drums to safely contain discharged flammable liquid based on accurate relief valve and disposal collection piping studies

Urge states that administer their own OSHA plan to implement comparable emphasis programs within their respective jurisdictions.

Status: Closed - Acceptable ActionThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

2005-4-I-TX-8

Strengthen the planned comprehensive enforcement of the OSHA Process Safety Management (PSM) standard. At a minimum:

a. Identify those facilities at greatest risk of a catastrophic accident by using available indicators of process safety performance and information gathered by the EPA under its Risk Management Program (RMP).

b. Conduct, or have conducted, comprehensive inspections, such as those under your Program Quality Verification (PQV) program at facilities identified as presenting the greatest risk.

c. Establish the capacity to conduct more comprehensive PSM inspections by hiring or developing a sufficient cadre of highly trained and experienced inspectors.

d. Expand the PSM training offered to inspectors at the OSHA National Training Institute.

Status: Closed - Acceptable Alternative ActionThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

2005-4-I-TX-9

Amend the OSHA PSM standard to require that a management of change (MOC) review be conducted for organizational changes that may impact process safety including:

a. major organizational changes such as mergers, acquisitions, or reorganizations;

b. personnel changes, including changes in staffing levels or staff experience; and

c. policy changes such as budget cutting.

Status: Open - Unacceptable Response/No Response ReceivedThis link opens a new window
DownloadThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 20, 2007

2005-4-I-TX-6

Work with API to develop a new consensus American National Standards Institute (ANSI) standard that creates performance indicators for process safety in the refinery and petrochemical industries. Ensure that the standard identifies leading and lagging indicators for nationwide public reporting as well as indicators for use at individual facilities. Include methods for the development and use of the performance indicators.

Status: Closed - Acceptable ActionThis link opens a new window
Recommendation Status Change SummaryThis link opens a new window

2005-4-I-TX-7

Work with API to develop a new consensus American National Standards Institute (ANSI) standard with fatigue prevention guidelines for the refining and petrochemical industries that, at a minimum, limit hours and days of work and address shift work.

Status: Closed - Acceptable ActionThis link opens a new window
Recommendation Status ChangeThis link opens a new window

Open: 0% | Closed: 100%

Final Report Released On: March 20, 2007

2005-4-I-TX-21

Work with BP to establish a joint program that promotes reporting, investigating, and analyzing incidents, near-misses, process upsets, and major plant hazards without fear of retaliation. Ensure that the program tracks recommendations to completion and shares lessons learned with the workforce.

Status: Closed - Acceptable ActionThis link opens a new window