California Approves Regulation to Reduce Risk of Catastrophic Events at Refineries
June 14, 2017
On May 18, 2017, California’s Occupational Safety and Health Standards Board approved a landmark regulation to strengthen workplace safety and health at oil refineries across the state. The new regulation provides a framework to help employers anticipate, prevent, and respond to hazards at refineries that can threaten workers and area residents.

Among the elements outlined in the regulation to be enforced by Cal/OSHA, refinery employers are required to conduct Damage Mechanism Reviews, conduct a Hierarchy of Hazard Controls Analysis, and implement a Human Factors Program for their worksites.

The approved regulation introduces a new refinery safety order enforced by Cal/OSHA’s Process Safety Management (PSM) Unit, adding section 5189.1 to Title 8 of the California Code of Regulations.

The elements outlined in the regulation require refinery employers to:

  • Conduct Damage Mechanism Reviews for processes that result in equipment or material degradation. Physical degradation, such as corrosion and mechanical wear, are common technical causes of serious process failures. 
  • Conduct a Hierarchy of Hazard Controls Analysis to encourage refinery management to implement the most effective safety measures when considering competing demands and costs when correcting hazards. 
  • Implement a Human Factors Program, which requires analysis of human factors such as staffing levels, training and competency, fatigue and other effects of shift work, and the human-machine interface. 
  • Develop, implement and maintain written procedures for the Management of Organizational Change to ensure that plant safety remains consistent during personnel changes. 
  • Utilize Root Cause Analysis when investigating any incident that results in, or could have reasonably resulted in, a major incident. 
  • Perform and document a Process Hazard Analysis of the effectiveness of safeguards that apply to particular processes and identify, evaluate and control hazards associated with each process. 
  • Understand the attitudes, beliefs, perceptions and values that employees share in relation to safety and evaluate responses to reports of hazards by implementing and maintaining an effective Process Safety Culture Assessment program. 

How Exponent Can Help


Exponent is a leading consulting firm in the investigation and prevention of chemical and industrial process accidents, with a 50-year history in incident investigation, failure analysis, and safety consulting. The wealth of knowledge gained from thousands of process safety related investigations in industrial, chemical, oil, and gas facilities provides a valuable reservoir of lessons learned. Exponent’s consultants assist clients in evaluating risk, investigating failures and process upsets, and in identifying and evaluating preventive measures in a manner sensitive to both risk and financial sustainability. Our services span the elements of Process Safety Management, and the life cycle of an industrial facility, from process design, construction, operation, and maintenance to facility decommissioning.

Our capabilities and expertise are further evidenced by our participation, as chairs and committee members, on many of the industrial standards and guidance documents that plant operators look to for process safety guidance (e.g., NFPA, ASME, ASTM, API, ISO, and the Hydraulic Institute). Our professionals publish numerous papers in their field of expertise. Exponent is also a corporate member company of the Center for Chemical Process Safety (CCPS).

For more details, read the news release.

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