Sunday, March 30, 2014

OSHA PSM and Emergency Response Planning

This is part of a continuing look at the public comments that have been posted to the docket for the OSHA Process Safety Management program advance notice of proposed rulemaking. Earlier posts in the series include:

In Saturday’s post I mentioned that a “commenter noted that natural gas transmission and distribution facilities are already required to maintain close coordination with local emergency response authorities under 49 CFR 192.615”. That comment by the American Gas Association (AGA) points to one of the few places in Federal Regulations that provides specific requirements for the type and scope of emergency planning that must be undertaken by a chemical facility. As such, I thought that it would be a good idea to look at those requirements in some detail.

Emergency Planning

Section 192.615 outlines the requirements that every gas pipeline operator must adhere to for the establishment of emergency plans. Subparagraph (a) outlines the requirements for establishing a written plan for responding to gas pipeline emergencies. Subparagraph (b) establishes the requirements for communicating that plan to the employees of the gas pipeline operator. And subparagraph (c) addresses the requirements for coordinating with police, fire and other public officials.

Written Plan

Subparagraph (a) requires each operator to “establish written procedures to minimize the hazard resulting from a gas pipeline emergency”. The plan must address:

• Receiving, identifying, and classifying notices of events which require immediate response by the operator;
• Establishing and maintaining adequate means of communication with appropriate fire, police, and other public officials;
• Prompt and effective response to a notice of each type of emergency;
• The availability of personnel, equipment, tools, and materials, as needed at the scene of an emergency;
• Actions directed toward protecting people first and then property;
• Emergency shutdown and pressure reduction in any section of the operator’s pipeline system necessary to minimize hazards to life or property;
• Making safe any actual or potential hazard to life or property;
• Notifying appropriate fire, police, and other public officials of gas pipeline emergencies and coordinating with them both planned responses and actual responses during an emergency;
• Safely restoring any service outage;
• Beginning incident investigations under §192.617, if applicable, as soon after the end of the emergency as possible; and
• Actions required to be taken by a controller during an emergency in accordance with control room management regulations under §192.631.

Now the scope of the pipeline emergency plan may be a bit more expansive than one would expect to see at more typical chemical facilities. This is inherent in the fact that by their very nature, gas pipelines are mainly off-site facilities. Many of them run through or near inhabited areas which may significantly expand the scope of a gas pipeline incident.

This is further reflected in 192.615(a)(3) which defines the types of emergencies for which the pipeline written plan must provide a ‘prompt and effective response’. The four specific emergencies specified are:

• Gas detected inside or near a building;
• Fire located near or directly involving a pipeline facility;
• Explosion occurring near or directly involving a pipeline facility; and
• Natural disaster.

Employee Communications

Just having a written plan is not sufficient. This section of the pipeline safety regulations maintains that pipeline operators must share the written plan with their employees in a fairly specific manner. Section 192.615(b) requires operators to:

• Furnish its supervisors who are responsible for emergency action a copy of that portion of the latest edition of the emergency procedures;
• Train the appropriate operating personnel to assure that they are knowledgeable of the emergency procedures and verify that the training is effective; and
• Review employee activities to determine whether the procedures were effectively followed in each emergency.

While it is not specifically mentioned in the subparagraph (b) requirements the training must not only address what actions must be taken, but training needs to insure that each of the personnel have the capability to identify emergencies at the earliest opportunity and to be able to discriminate between the different types of emergencies to determine which action in the emergency plan should be taken.

The last requirement is often overlooked in emergency planning. After each incident where any portion of the emergency plan is put into operation, an after-action review (AAR) needs to be undertaken to ensure that not only were the employees’ actions correct with respect to the plan requirements, but also that the plan requirements were appropriate to the incident in question.

A natural extension of the AAR {again not specifically mentioned in §192.615(b)} is the need to revise the emergency plan based upon the lessons learned in the AAR.

Community Coordination

Since many gas pipeline incidents or accidents can have an immediate and devastating impact on the local community, close coordination between the gas pipeline operator and the local emergency response community is very important. This is reflected in the actions specified in §192.615(c). This subparagraph establishes the requirement for a pipeline operator to “establish and maintain liaison with appropriate fire, police, and other public officials”. This liaison is required in order to:

• Learn the responsibility and resources of each government organization that may respond to a gas pipeline emergency;
• Acquaint the officials with the operator’s ability in responding to a gas pipeline emergency;
• Identify the types of gas pipeline emergencies of which the operator notifies the officials; and
• Plan how the operator and officials can engage in mutual assistance to minimize hazards to life or property.

While the scope of the area that the operator is responsible for coordinating with local officials for emergency response actions is much larger than for most chemical facilities because of the length of most gas pipelines, the same reasons exist for making such coordination exist for any facility that houses or produces hazardous chemicals.

OSHA PSM Implications

In considering the current OSHA PSM standard and evaluating how well that standard addresses the requirement for emergency planning and community coordination, OSHA would do well to take a good hard look at §192.615. With very little modification to the wording in this portion of the Pipeline Safety Regulations, OSHA would have a fairly comprehensive set of requirements for PSM covered facilities upon which to base their emergency planning operations.

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