Preserve the Process Context Behind Every Refinery Event
Classify Events by Their Safety Significance
Relevant categories include:
- Hydrocarbon or chemical loss of containment
- Fire, flash fire, and explosion
- Unplanned pressure or temperature excursions
- Hydrogen sulfide and benzene exposure concerns
- Acid contact where applicable
- Oxygen-deficient atmospheres
- Steam, hot-product, and thermal burns
- Unexpected energization or equipment movement
- Confined-space incidents
- Hot-work events
- Catalyst and coke-handling exposures
- Dropped objects and lifting failures
- Falls during access or maintenance
- Protective-device failures or unavailability
- Startup, shutdown, and procedure deviations
Preserve distinctions between an alarm, an operating deviation, a release, and a confirmed exposure. These observations require different assessments.
Capture Equipment and Operating-State Details
Record:
- Refinery, unit, area, and equipment tag
- Normal operation, shutdown, turnaround, startup, or abnormal condition
- Material involved and relevant hazards
- Available pressure, temperature, level, or flow information
- Timeline of alarms and operator responses
- Isolation and equipment-preparation status
- Safeguards available at the time
- Temporary modifications or bypasses
- Maintenance and inspection history
- Personnel location and task
- Gas readings and exposure information
- Immediate response and restrictions
- Photographs, statements, and supporting documents
Keep the source and timing of process information identifiable. Conditions recorded after stabilization may differ from those that initiated the event.
Investigate Across Operations and Engineering
Event → Process Timeline → Equipment Condition → Safeguard Performance → Contributing Causes → Corrective Actions → Verification
Questions may include:
- Were operating limits understood and available?
- Did instrumentation represent the actual process condition?
- Was a known equipment deficiency involved?
- Had feedstock, chemistry, or operating severity changed?
- Was the equipment prepared adequately for opening?
- Did the procedure reflect the installed configuration?
- Were temporary changes communicated at shift handover?
- Had similar findings appeared in earlier inspections or investigations?
The investigation should identify actions addressing the underlying failure rather than relying solely on reminders or retraining.
Apply the Refinery’s Process Safety Requirements
OSHA’s Process Safety Management standard, 29 CFR 1910.119, is central to covered refinery processes. Applicability must be established for the process; the operating label alone is not the determination.
Dexur EHS can support the organization and follow-up of PSM records, including:
| PSM element |
Refinery application |
Information to retain |
| Process Safety Information |
Chemical hazards, process technology, and equipment information. |
Identified gaps, document references, and assigned updates. |
| Process Hazard Analysis |
Evaluation of process hazards and safeguards. |
Recommendations, dispositions, schedules, and resolution evidence. |
| Operating Procedures and Training |
Instructions for relevant operating phases and tasks. |
Revisions, affected roles, and required training records. |
| Mechanical Integrity |
Inspection, testing, and maintenance of covered equipment. |
Deficiencies, technical assessments, and corrective work. |
| Management of Change |
Changes other than replacement in kind. |
Technical basis, safety review, authorization, and documentation updates. |
| Pre-Startup Safety Review |
Required review of new or sufficiently modified facilities. |
Findings and confirmation of applicable prerequisites. |
| Incident Investigation |
Events meeting the standard’s investigation criteria. |
Findings, recommendations, resolution, and required communication. |
| Compliance Audits |
Periodic evaluation of compliance with the standard. |
Audit findings, responses, and correction evidence. |
OSHA’s refinery guidance highlights recurring concerns involving these elements. OSHA: Process Safety Management for Petroleum Refineries
Process Hazard Analysis: Document Resolution
For covered processes, PSM requires a system to address recommendations promptly, document their resolution, establish a written schedule, and communicate relevant actions to affected personnel.
Record the disposition and technical basis. An unexplained “closed” status does not show how the recommendation was addressed. OSHA: Process Safety Management
Mechanical Integrity: Preserve the Deficiency Decision
Connect inspection findings to the equipment’s acceptable limits and the required corrective response.
Where continued use is considered, retain the assessment and measures required by the applicable provision. An overdue repair date alone is not a justification for continued operation. OSHA: Mechanical Integrity Requirements
Management of Change: Follow Temporary Changes
Track the technical basis, duration, authorization, affected procedures, and personnel communication for changes requiring MOC.
Temporary arrangements need a defined review and disposition. Preserve whether the change was removed, extended through the designated process, or incorporated permanently. OSHA: Management of Change Requirements
Startup Readiness: Confirm the Applicable Prerequisites
For facilities requiring a pre-startup safety review, the review must confirm specified conditions before introducing highly hazardous chemicals.
Track construction conformance, procedures, applicable hazard-review actions, MOC requirements, and training. The regulatory PSSR trigger is specific; additional restart reviews may arise from refinery procedures. 29 CFR 1910.119: Pre-Startup Safety Review
Incident Investigation: Recognize the PSM Threshold
PSM requires investigation of incidents that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical. Investigation must begin as promptly as possible, and no later than 48 hours after the incident.
Preserve the determination, investigation findings, and documented resolution of recommendations. 29 CFR 1910.119: Incident Investigation
Maintain Occupational Safety Programs Alongside PSM
| Requirement |
Refinery application |
Supporting records |
| Benzene — 29 CFR 1910.1028 |
Covered occupational exposure during relevant processing, sampling, maintenance, and handling tasks. |
Exposure determinations and applicable monitoring, training, and medical-surveillance records. |
| Hazard Communication — 29 CFR 1910.1200 |
Hazardous feedstocks, intermediates, products, and treatment chemicals. |
Safety data sheets, labels, chemical information, and instruction. |
| Respiratory Protection — 29 CFR 1910.134 |
Tasks requiring respirators. |
Program records, medical evaluation status, fit testing, and training. |
| Permit-Required Confined Spaces — 29 CFR 1910.146 |
Qualifying vessels, tanks, and other spaces. |
Evaluations, permits, atmospheric testing, and rescue arrangements. |
| Control of Hazardous Energy — 29 CFR 1910.147 |
Covered servicing and maintenance. |
Equipment-specific procedures, inspections, and employee training. |
| Welding and Cutting — 29 CFR 1910 Subpart Q |
Applicable hot-work activities. |
Fire precautions, work-area reviews, and supporting records. |
| Occupational Noise Exposure — 29 CFR 1910.95 |
Compressors, turbines, pumps, and other noisy equipment. |
Exposure assessments and hearing-conservation documentation where required. |
| Electrical Work Practices — 29 CFR 1910.333 |
Electrical maintenance and troubleshooting. |
Work assessments, deenergization practices, and protective measures. |
| HAZWOPER Emergency Response — 29 CFR 1910.120(q) |
Covered emergency response to hazardous-substance releases. |
Response planning and role-specific training. |
| Recordkeeping — 29 CFR Part 1904 |
Covered occupational injuries and illnesses. |
Recordability decisions, applicable OSHA forms, and case documentation. |
Benzene: Evaluate the Task and Material
Exposure assessment should reflect actual activities, including sampling, draining, line opening, and equipment cleaning where benzene may be present.
Record the material, task duration, work practices, and measurement basis. Apply the benzene standard’s scope and requirements rather than assuming the same exposure profile throughout the refinery. OSHA: Benzene
Startup and Shutdown: Review the Transition
Transient operations involve procedures and conditions that differ from steady production. CSB investigations emphasize the importance of accurate instructions, preparation, communication, and management of changes during these periods.
Connect the readiness review to the actual configuration and unresolved findings. CSB: Incidents During Startups and Shutdowns
Distinguish the Evidence Supporting Each Decision
| Record |
What it supports |
Important distinction |
| Work permit |
Authorization under specified work conditions. |
Does not independently establish equipment fitness for service. |
| Isolation record |
Documented energy and material separation arrangements. |
Must correspond to field conditions and the task. |
| Inspection report |
Findings about equipment condition. |
May require further engineering interpretation. |
| MOC record |
Review and authorization of an applicable change. |
Does not replace required field verification or training. |
| PSSR record |
Confirmation of applicable startup prerequisites. |
Must address the actual facility and modification. |
| Exposure result |
Information about a sampled task or condition. |
Does not establish every worker’s exposure throughout the unit. |
Prepare Reports for Unit and Refinery Reviews
Examples include:
- Loss-of-containment events by unit and equipment type
- Repeat leaks following repair
- Overdue PHA recommendations
- Mechanical-integrity deficiencies awaiting resolution
- Temporary changes approaching review dates
- Impaired safeguards and associated restrictions
- Startup prerequisites not yet completed
- Exposure-control recommendations by task
- Audit findings recurring across units
- Investigation actions requiring engineering verification