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Api RP 578 RP 578 - 59c0cef01723ddbea5dd0513 PDF
Api RP 578 RP 578 - 59c0cef01723ddbea5dd0513 PDF
on
API RP 578
By
Don Mears
Analytical Training Consultants
October 2-6, 2011
¾ G Industry
Oil & Gas I d C l
Consultant f Thermo
for Th Fi h Scientific
Fisher S i ifi
By
Don Mears
Analytical Training Consultants
• 52 employee deaths
• Includes 250 employee injuries, 98 with hospitalization
Region 2
Region 10
Region 3
Region 4
Region 9
Region
g 6
Author Don Mears Confidential 9
% Change
OSHA Violation Statistics FY2003 FY2004 FY2005 FY2006 FY2007
2003-2007
Total Violations 83,539 86,708 85,307 83,913 88,846 6.4%
Total Serious Violations 59,861 61,666 61,018 61,337 67,176 12.2%
Totall Willful
illf l Violations
i l i 404 462 747 479 415 2.7
Total Repeat Violations 2,147 2,360 2,350 2,551 2,714 26.4%
T t l Other-than-Serious
Total Oth th S i 20 552
20,552 21 705
21,705 20 819
20,819 19 246
19,246 18 331
18,331 -10.8%
10 8%
BP Texas City, Texas
Fined $30.7 Million
For 439 willful Violations
On 10/30/09
¾ Chemical Safety Board ( CSB ) Report-BP
Report BP Texas City Texas
¾ NY Times report on BP Texas City Fines
Safety Bulletin-BP Texas City.pdf
BP Faces Record Fine NY Times
Times-10-30-09.pdf
10 30 09 pdf
¾ Safety Bulletin from U.S. Chemical Safety and Hazard
Investigation Board (CSB)-Chlorine Transfer Hose Failure due to
improper material braid construction (i.e., 316L and not the
recommended braid of Hastelloy C-276). On August 14, 2002, a
1-inch transfer line ruptured
p during
g a railcar offloading
g operation
p
at DPC Enterprises in Festus, Missouri and released 48,000
pounds of Chlorine into neighboring areas
SafetyBulletin-ChlorineShutdown.pdf
y p
¾ Chemical Plant NEP effective on July 27
27,2009
2009
¾ Extended through end of 2010
¾ Outlines
O tli a diff
differentt approach
h for
f inspecting
i ti
PSM covered chemical facilities
¾ NOT comprehensive
h i
¾ LESS resource intensive for both OSHA and
Chemical Plants
Region 2
Region 10
Region 3
Region 4
OSHA by Region
Region 9
Region 6
In response to increasing industry safety demands, Analytical Training
Consultants has pproduced the API 578 PMI Certification Training
g Course
www.ATC578.com
ATC578
¾ Why Should this Course be Given ?
¾ “Recognized
Recognized And Generally Accepted Good
Engineering Practice” (RAGAGEP) – are
engineering, operation, or maintenance activities
based on established codes, standards, published
technical reports or recommended practices (RP) or
a similar
i il document.
d t RAGAGEPs
RAGAGEP d detail
t il generally
ll
approved ways to perform specific engineering,
inspection or mechanical integrity activities
activities, such as
fabricating a vessel, inspecting a storage tank, or
servicing a relief valve (See CCPS [Ref. 33]).
¾
Author Don Mears Confidential 15
¾ Important information is found in APPENDIX A regarding the
“Static
Static List of”
of Inspection Priority Items (IPI) and contains
questions that the Compliance Safety and Health Officer
(CSHO)’s are to address in their compliance evaluation of an
employer’s
l ’ refinery
fi “Process
“P Safety
S f t Management”
M t” (PSM)
program.
¾ It should be noted that both PMI and proper OPERATOR
TRAINING programs are QUESTIONS that the (CSHO) will
address to the Owner/Operator as to compliance with their
Process Safety Management (PSM) program.
¾ As
A off A
August,
t 2010
2010, 112 iinspections
ti opened
d
38 Unprogrammed (34%)
74 P
Programmed d (66%)
9 resulted in no inspection occurring because there was no
PSM covered process
¾ 62inspections have issued citations
¾ Average 9
9.00 citations per inspection
¾ Average $3,500 per citation
¾ Over 60 different standards cited
¾ 44% of all citations were other than PSM
Chemical Plant NEP Citations by PSM
Element
% of PSM
Element Description Citations Cumulative %
j Mechanical Integrity 23.8% 23.8%
d y
Process Safety Information 20.2%
% 44.0%
%
e Process Hazard Analysis 19.0% 63.0%
f Operating Procedures 13.9% 76.9%
g Training 4.8% 81.7%
h Contractors 3.8% 85.6%
o Compliance Audits
Compliance Audits 3 4%
3.4% 88 9%
88.9%
l Management of Change 3.1% 92.1%
n Emergency Planning & Response 2.9% 95.0%
m Incident Investigation 2.6% 97.6%
i Pre‐startup Review 1.4% 99.0%
k Hot Work
Hot Work 1 0%
1.0% 100 0%
100.0%
Training Course Explained
on
API RP-578
By
Don Mears
Analytical Training Consultants
¾ Joint US and Mexico Efforts to Ensure Safe and Healthful Working Conditions for Workers from
Mexico and other Latin American Countries. True also with North America, Europe & China
http://www.osha.gov/international/index.html