The state of Washington is taking a significant step forward in modernizing Process Safety Management (PSM) standards for petroleum refineries. This initiative is driven by the need for refineries to adapt and align with evolving regulations, particularly with a focus on bringing these standards in line with those of California, exemplified by the California Code of Regulations, Title 8, Section 5189.1. This section provides a comprehensive framework outlining the stringent requirements for Process Safety Management in the context of Petroleum Refineries.

The Washington State Department of Labor and Industries (L&I) has proposed a new rule aimed at updating process safety management (PSM) standards specifically for petroleum refineries. The existing PSM rule in Washington is outdated, having remained unchanged since the federal standard issued by OSHA in 1992. In contrast, neighboring California took the proactive step of revising its regulations in 2017, introducing stricter requirements for petroleum refineries. Washington’s L&I aims to achieve consistency with California’s regulations, which is a particularly significant move given that 80% of Washington’s refiners also operate in California. This alignment with California’s PSM requirements is expected to enhance safety for employees and contractors working at refineries in both states.The proposed regulation introduces several noteworthy changes to Washington’s PSM, and these requirements are comparable to the deviations from the federal standards enacted in California in 2017. Some key elements of the proposed rule include:

  1. Expanding the Scope of Process Hazard Analyses (PHA): This expansion includes mandates for safeguard protection analysis, addressing damage mechanism reviews and requiring a Hierarchy of Hazard Controls Analysis (HCA).
  2. Management of Organizational Changes (MOOCs): This assessment becomes mandatory for any changes affecting refinery operations, health and safety, staffing levels, and more.
  3. Inclusion of Human Factors: The proposed rule requires refiners to develop and maintain a written human factors program that takes into account factors such as staffing levels, fatigue, training, and task complexity.
  4. Root Cause Analyses (RCA): These are mandated after significant accidents, with a focus on preventing future incidents.
  5. Process Safety Culture Assessment: Employers must conduct assessments to ensure workplace safety and employee collaboration.
  6. Definition of Recognized and Generally Accepted Good Engineering Practices (RAGAGEP): The new definition relies solely on codes, standards, and technical reports published by recognized industry organizations, excluding internal guidelines and procedures.

The proposed rule is slated for implementation by the end of the year, with a public comment period open until August 24. Hearings have been scheduled for August 10 and 17 in Bellingham, with a virtual hearing on August 15. With these updates, Washington aims to modernize its PSM standards, ultimately prioritizing the safety and well-being of those working in the petroleum refining industry.

At Saltegra Consulting LLC, we have been at the forefront of assisting California refineries in adapting to these stringent regulations since their inception in 2017. Our proven track record in navigating complex regulatory landscapes and fostering a culture of safety can provide your company with a strategic advantage in this changing environment. We invite you to join the growing number of refineries in California that have trusted us to guide them through these challenging regulatory changes. Get a head start now with our support in planning, developing, and executing refinery PSM compliance requirements. You can directly contact us for any inquiries or concerns or visit our website for more information about these requirements.