OSHA Compliance

In 1992 we had an event that released over 50,000 pounds of methyl mercaptan. We had been sold out but as a result of the leak we were shut down for over six weeks. At the time there were not any consultants to help us get compliant to OSHA 1910 because it only just been written in 1991. Our company received an "agreed board order" from the Federal Courts and OSHA/EPA that the plant would get into full compliance with CFR1910.119, Process Safety Management, by the end of 1994. So over the next 12 to 18 months we put together a team to produce a process safety management program that met all fourteen elements. Our plant manager issued an internal statement that we had three priorities going forward:

• Safety

• Environmental Compliance

• Production

1992 - Since we were a corporate cash cow, costs were not an issue as profit margins were exceeding 40%. Another positive note was the plant had relatively young innovative leaders. We realized that our license to operate depended on the success of our two year commitment to achieve compliance.

1994 - By 1994 damage mechanisms were more clearly understood as were our inspection strategies that now included profile radiography - better for finding localized corrosion.. We had spent over $20M on asset integrity and became compliant with CFR1910.119. OSHA audited the plant and found NO violations.

1999 - By the time I left the facility to become the mechanical integrity manager for another major chemical manufacturer, the plant earned and became an OSHA star facility. In 1992 our rated production was 250,000 lbds/day when I left we were producing 600 to 650,000 lbs./day primarily achieved through a debottleneck project and a good asset integrity program.

My title had changed to Chief Engineer and I was moving on to my next challenge as manager of mechanical integrity for one of the most innovative chemical companies in the world. When I arrived at my new job I quickly determined that 1500 vessels had overdue inspections. Here I was again, out of compliance. I put together and submitted an $8,000,000 budget to get our asset integrity program compliant. I was told no, it was too much money. My response was simple, thet we had to implement an RBI program. We needed a reliability revolution.

Mike Hurley - Principal at Asset Optimization Consultants

AOC provides a comprehensive compliance audit solution that entails pre-audit evaluation, on-site audit execution, documentation, and follow-up services. The OSHA PSM and EPA RMP mandates require companies to conduct compliance audits of their process safety and accidental release prevention programs every three (3) years. OSHA has also established a National Emphasis Program (NEP) for both refineries and chemical plants due to unacceptable safety records. The stated focus of the NEP is on implementation and not documentation of the program. Therefore, our purpose of assessing the PSM and EPA programs is help continuously monitor and improve the effectiveness of those programs designed to protect the environment, on-site and off-site communities, and assets.

AOC implements PSM solutions across the energy cycle as one of its core business services, therefore, we know what it takes to build and maintain effective and practical PSM and RMP programs. Our experience and breadth of exposure to many and different types of facilities allow us to tailor each audit per the client's need. Our consultants are also up to date on the industry's performance level with respect to regulatory compliance standards.

Our compliance auditors are multi-disciplined engineers with training in electrical, mechanical, and chemical engineering fundamentals. The following case study provides the experience of one of our principals not as a consultant but as an owner operator faced with an event that ultimately paved the way for getting compliant all within 20 months.

In summary we deliver value:

• Prepare facilities for the NEP implementation audits

• Flexibility depending on needs of facility:

  • One week gap analysis to identify high-level gaps

  • Multi-week comprehensive analysis to provide a road map that will:

    • improve the safety culture
    • empower personnel to achieve excellence
    • streamline work processes to efficiently achieve desired results
    • establish leading and lagging key performance indicators to drive continuous improvement
    • maximize existing information systems so areas that need attention are visible to leadership

• Efficient assessment process:

  • minimizes load on personnel while maximizing evaluation of documentation
  • targeted interviews - most are completed in 15 minutes and the longest only lasts 30 minutes

• Effective evaluation:

  • variety of sources used to justify scores including interviews, document review, record checks and a limited number of personnel observations

• Powerful protocol:

  • Covers OSHA Process Safety Management and EPA Chemical Accident Prevention

  • Two measures of success for each element:

    • How well does the documented program comply with regulations?
    • How well is the program implemented?
  • Provides numerical ranking for each element that enables a prioritized response
  • Fast report generation - preliminary draft issued at Closing Meeting

• Experienced teams:

  • Developed, implemented and managed Process Safety Management programs
  • Trained in auditing methods