(55bn) 2023 Washington State “PSM for Refineries” Rulemaking and Lessons-Learned from California 5189.1 and Calarp P4

The State of Washington Department of Safety and Health (DOSH) has been overseeing the implementation of Process Safety Management in the state, primarily based on the core elements of PSM as first adopted in 1992. Recently, the State of Washington has updated its PSM requirements specifically for petroleum refineries to address a perceived need for additional elements/requirements for petroleum refineries to address accidents that have occurred in the state and elsewhere.

In California, a similar impetus to address lessons-learned from previous accidents resulted in significant changes to California’s PSM and RMP requirements as applied to petroleum refineries. State-PSM and State-RMP (CalARP) requirements applicable to California refineries were finalized and made effective on October 1, 2017. Cal/OSHA's requirements are driven by a separate PSM regulation focused on petroleum refineries, and CalEPA/CalOES requirements include a new program level (Program 4), initially applying primarily to petroleum refineries. These two California requirements are nearly identical. These changes have already been detailed in other GCPS papers and will only be referenced here.

The updates to the State of Washington PSM requirements for petroleum refineries are extensive, largely align with the analogous California requirements, and are considered by the state to be necessary to ensure that employers and employees are safe while working in the refineries as processes and technology in the industry advance over time.

The focus of this paper will be to provide relevant background information, a summary of the changes, and, as well as providing the reader with a "roadmap" for effective implementation.

The objective of this paper is to:

• provide a brief overview of the changes to the State of Washington petroleum refinery PSM requirements,
• provide a roadmap correlating the changes to the above-mentioned California requirements,
• share some of the lessons-learned from the application of related program elements in California,
• provide tips for addressing key technical and regulatory challenges, and
• share some strategies for effective implementation, especially cost-effective things that can be done currently to buffer later efforts

Although the implementation of these new requirements may appear quite ominous, with the experience of implementing California PSM for petroleum refineries and CalARP-P4 one can develop strategies for effective implementation.