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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