Oil Market Report – May 2022

Source: IEA

Fuel report — May 2022

About this report

The IEA Oil Market Report (OMR) is one of the world’s most authoritative and timely sources of data, forecasts and analysis on the global oil market – including detailed statistics and commentary on oil supply, demand, inventories, prices and refining activity, as well as oil trade for IEA and selected non-IEA countries.

Highlights

  • World oil demand growth is forecast to slow to 1.9 mb/d in 2Q22 from 4.4 mb/d in 1Q22 and is now projected to ease to 490 kb/d on average in the second half of the year on a more tempered economic expansion and higher prices. As summer driving escalates and jet fuel continues to recover, world oil demand is set to rise by 3.6 mb/d from April to August. For 2022, demand is expected to increase by 1.8 mb/d on average to 99.4 mb/d.
  • Russia shut in nearly 1 mb/d in April, driving down world oil supply by 710 kb/d to 98.1 mb/d. Over time, steadily rising volumes from Middle East OPEC+ and the US along with a slowdown in demand growth is expected to fend off an acute supply deficit amid a worsening Russian supply disruption. Excluding Russia, output from the rest of the world is set to rise by 3.1 mb/d from May through December.
  • Global refinery margins have surged to extraordinarily high levels due to depleted product inventories and constrained refinery activity. Throughputs in April fell 1.4 mb/d to 78 mb/d, the lowest since May 2021, largely driven by China. Between now and August, runs are forecast to ramp up by 4.7 mb/d, but the tightness in product markets is expected to continue based on our current oil demand outlook.
  • Global observed oil inventories declined by a further 45 mb during March and are now a total 1.2 billion barrels lower since June 2020. In the OECD, the release of 24.7 mb of government stocks during March halted the precipitous decline in industry inventories. OECD industry stocks rose by 3 mb to 2 626 mb, but remained 299 mb below the five-year average. Preliminary data for April show OECD industry inventories increased by 5.3 mb.
  • Crude prices fell in April to trade in a narrow $10/bbl range above $100/bbl. ICE Brent last traded around $105/bbl and WTI $102/bbl. Rapid early-May advances on the sixth round of EU sanctions for Russia drove renewed price tensions. High crude prices and exceptional product cracks are supporting strong inflation trends. 

Pressure mounting

Russia’s isolation following its invasion of Ukraine is deepening as the EU and G7 contemplate tougher sanctions that include a full phase out of oil imports from the country. If agreed, the new embargoes would accelerate the reorientation of trade flows that is already underway and will force Russian oil companies to shut in more wells. Even so, steadily rising output elsewhere, coupled with slower demand growth, especially in China, is expected to fend off an acute supply deficit in the near term. Amid the widening supply and demand uncertainties, oil market volatility remains rife, but prices are trading in a lower and narrower $10/bbl range above $100/bbl. Brent last traded at $ 105/bbl and WTI $102/bbl.

Despite mounting international pressure and falling oil production, Russian exports have so far held up by and large. But now major trading houses are winding down deals ahead of a 15 May deadline to halt all transactions with state-controlled Rosneft, Gazprom Neft and Transneft. Following a supply decline of nearly 1 mb/d in April, losses could expand to around 3 mb/d during the second half of the year.

Global refinery maintenance and capacity constraints are exacerbating dislocations caused by Russia’s war in Ukraine. During April, crude and product markets saw diverging trends. While crude prices trended lower overall, diesel and gasoline cracks surged to record levels, pulling up refinery margins and end-user prices.

Limited spare capacity in the global refining system, together with reduced exports of Russian fuel oil, diesel and naphtha have aggravated the tightness in product markets, which have now seen seven consecutive quarters of stock draws. While a first tranche of SPR releases halted the precipitous decline in OECD industry stocks in March, crude made up the majority of it and product stocks have continued to fall. Notably, middle distillate reserves reached their lowest levels since April 2008.

Soaring pump prices and slowing economic growth are expected to significantly curb the demand recovery through the remainder of the year and into 2023. Moreover, extended lockdowns across China where the government struggles to contain the spread of Covid-19 are driving a significant slowdown in the world’s second largest oil consumer. For the year as a whole, global oil demand is forecast to average 99.4 mb/d in 2022, up 1.8 mb/d y-o-y.

As restrictions in China ease, summer driving picks up and jet fuel continues to recover, world oil demand is set to rise by 3.6 mb/d from an April low through August. If refiners cannot keep pace, product markets and consumers could come under additional strain. The IEA’s recent 10-Point Plan to Cut Oil Use outlines measures that can be taken immediately to cut consumption and ease the pain caused by high oil prices.

Process Hazard Analysis Methodologies and Refinery Applications

Source: AIChE

Process Safety Management System starts with managing the process related risks and from the first step of establishing a new process unit that is needed to evaluate the risks and define the necessary measurements. Process Hazard Analysis methodologies are the systematic tools which help to evaluate the risks in a process. For different needs there are several methodologies like DOW FETI, HAZOP, What if, HAZID, Fault Tree and Event Tree Analysis, Scenario Modelling, Facility Siting etc. Some of these methodologies are semi quantitative some are quantitative methodologies. In order to define and prevent major industrial accidents in our refinery we use DOW FETI, HAZOP, FTA and ETA and Scenario modelling. Moreover for some kind of projects we may also apply What if and HAZID analysis instead of HAZOP depending on the complexity. Facility Siting is another tool for risk related studies which is used to evaluate the risks for buildings in order to protect people inside the buildings.

The workflow for a full unit PHA study starts with DOW FETI calculation which is used for risk ranking of al static equipment inside the unit. DOW FETI calculation is done in accordance with the equipment temperature, pressure, hold-up amounts, components and also reaction types if there is any. Then risk assessment process continues with HAZOP studies which is for scenario identification. In HAZOP, first step is chopping the unit into small parts to be evaluated which is called nodes. After that all nodes are evaluated using P&IDs and PFDs by keywords like temperature, pressure, flow, level etc. HAZOP helps to understand what kind of scenarios are possible inside the unit and these critical scenarios are taken through FTA and ETA studies. HAZOP is a semi quantitative risk assessment method where FTA and ETA are quantitative methods. FTA is applied for critical scenarios in order to find out the probability of top event then ETA is then applied in order to find out the probability of scenarios like fire, explosion, toxic dispersion etc. caused by this top event. FTA and ETA analysis all use the statistical PFD and failure rate values of all initiating events and barriers defined in HAZOP for the related scenario.

Scenario Modelling is the following step which is used for understanding the effect of the probable scenario. The most probable scenarios coming from ETA is modelled to see the effect zones. These effect zones are used to plan Emergency Response Studies for all these potential major accidents.

Facility Siting is another check point in a unit PHA study all potential scenario modelling results are used to evaluate the risks for the buildings and also if there are any in the effect zones of fire, explosion or toxic release then there should be actions defined.

Oil Market Report – March 2022

Read Extract

About this report

The IEA Oil Market Report (OMR) is one of the world’s most authoritative and timely sources of data, forecasts and analysis on the global oil market – including detailed statistics and commentary on oil supply, demand, inventories, prices and refining activity, as well as oil trade for IEA and selected non-IEA countries.

Highlights

  • Surging commodity prices and international sanctions levied against Russia following its invasion of Ukraine are expected to appreciably depress global economic growth. As a result, we have revised down our forecast for world oil demand by 1.3 mb/d for 2Q22-4Q22, resulting in 950 kb/d slower growth for 2022 on average. Total demand is now projected at 99.7 mb/d in 2022, an increase of 2.1 mb/d from 2021.
  • The prospect of large-scale disruptions to Russian oil production is threatening to create a global oil supply shock. We estimate that from April, 3 mb/d of Russian oil output could be shut in as sanctions take hold and buyers shun exports. OPEC+ is, for now, sticking to its agreement to increase supply by modest monthly amounts. Only Saudi Arabia and the UAE hold substantial spare capacity that could immediately help to offset a Russian shortfall.
  • Global refinery throughput estimates for 2022 have been revised down by 860 kb/d since last month’s Report as a 1.1 mb/d reduction in Russian runs is not expected to be fully offset by increases elsewhere. In 2022, refinery intake globally is projected to rise by 2.9 mb/d year-on-year to 80.8 mb/d. Despite a downgrade to demand, product markets remain tight with further stock draws expected throughout the year.
  • OECD total industry stocks were drawn down by 22.1 mb in January. At 2 621 mb, inventories were 335.6 mb below the 2017-2021 average and at their lowest level since April 2014. Industry stocks covered 57.2 days of forward demand, down by 13.6 days from a year earlier. Preliminary data for the US, Europe and Japan indicate that industry stocks decreased by a further 29.8 mb in February.
  • As this Report went to print, ICE Brent oil futures slid to around $100/bbl after touching an intraday high of nearly $140/bbl on 8 March. Prices jumped from $90/bbl in early February following the invasion of Ukraine and as supply concerns mounted. Prices have eased again on economic concerns, surging Covid cases in China and traders reducing positions due to extreme volatility.

At a crossroads

Faced with what could turn into the biggest supply crisis in decades, global energy markets are at a crossroads. Russia’s invasion of Ukraine has brought energy security back to the forefront of political agendas as commodity prices surge to new heights. While it is still too early to know how events will unfold, the crisis may result in lasting changes to energy markets.

The implications of a potential loss of Russian oil exports to global markets cannot be understated. Russia is the world’s largest oil exporter, shipping 8 mb/d of crude and refined oil products to customers across the globe. Unprecedented sanctions imposed on Russia to date exclude energy trade for the most part, but major oil companies, trading houses, shipping firms and banks have backed away from doing business with the country. For now, we see the potential for a shut-in of 3 mb/d of Russian oil supply starting from April, but losses could increase should restrictions or public condemnation escalate.

Russian oil continues to flow for the time being due to term deals and trades made before Moscow sent its troops into Ukraine, but new business has all but dried up. Urals crude is being offered at record discounts, with limited uptake so far. Some Asian oil importers have shown interest in the much cheaper barrels, but are for the most part sticking to traditional suppliers in the Middle East, Latin America and Africa for the bulk of their purchases. 

Refiners, particularly in Europe, are scrambling to source alternative supplies and risk having to reduce activity just as very tight oil product markets hit consumers. There are scant signs of increased supplies coming from the Middle East, or of a significant reallocation of trade flows. The OPEC+ alliance agreed on 2 March to stick with a modest, scheduled output rise of 400 kb/d for April, insisting no supply shortage exists. Saudi Arabia and the UAE – the only producers with substantial spare capacity – are, so far, showing no willingness to tap into their reserves.

Prospects of any additional supplies from Iran could be months off. Talks over a nuclear deal that paves the way for sanction relief have apparently stalled just before the finish line. Should an agreement be reached, exports could ramp up by around 1 mb/d over a six-month period. Outside of the OPEC+ alliance, growth will come from the US, Canada, Brazil and Guyana, but any near-term upside potential is limited.

In the absence of a faster ramp up in production, oil stocks will have to balance the market in the coming months. But even before Russia’s attacks on Ukraine, the industry’s oil inventories were depleting rapidly. At the end of January, OECD inventories were 335 mb below their five-year average and at eight-year lows. IEA emergency stocks will provide a welcome buffer, and member countries stand ready to release more oil from strategic reserves if and when needed, in addition to the 62.7 mb of crude and products already pledged. 

Surging oil and commodity prices, if sustained, will have a marked impact on inflation and economic growth. While the situation remains in flux, we have lowered our expectations for GDP and oil demand in this Report. We now see oil demand growing by 2.1 mb/d on average in 2022, a downgrade of around 1 mb/d from our previous forecast. There are actions governments and consumers can take to cut short-term demand for oil more rapidly to ease the strains and the IEA will publish recommendations for how to do so later this week. The current crisis comes with major challenges for energy markets, but it also offers opportunities. Indeed, today’s alignment of energy security and economic factors could well accelerate the transition away from oil.

Safety: Do companies have the right tools to make proactive safety decisions?

A process safety management/operational risk management survey conducted by Sphera in 2020 polled respondents on the following items:

  • Safety culture
  • The reality of risk across hazardous industries
  • The methods organizations use for identifying, understanding and communicating risk
  • Priorities and company plans for digital transformation.

The industry breakdown included oil and gas (36%), chemicals and petrochemicals (19%) and manufacturing (17%), as well as other industries like oilfield services, utilities, metals and mining. Participation was offered globally, and feedback was received across all regions.

Some of the key statistics include 88% of participants indicating that safety is part of corporate value structures, supported by upper management; 78% of respondents continuously monitoring safety performance; and 60% of participants striving to reduce operational and major accident hazard risk exposure. The survey suggested additional drivers for improving safety performance, including continuous process improvement, operational excellence, regulatory compliance, and satisfying corporate and board priorities, among others.

Risk awareness can pay for itself

Despite good intentions, 49% of survey respondents said most organizations are unaware of their major accident hazard risk vulnerability, and only 37% are confidently and proactively managing process safety risk exposure. For the last 5 yr, the percentage of companies that proactively manage safety have been surveyed; year on year, the result is somewhere in the 36%–40% range.

This statistic gives reason for pause. Earlier this year, Marsh published its 100 largest hydrocarbon loss report. It is striking that over the past 2 yr, the industry faced its largest losses on record—$4.5 B, which is 10% of the combined 50-yr total. Aging infrastructure and high utilization in the downstream sector were largely to blame (FIG. 1). Over those 2 yr, the oil and gas industry was recovering from its previous oil price downturn, which may very well repeat itself again 2 yr from now. It begets the question: Do companies actually have the right tools to proactively manage infrequent, high-consequence events?FIG. 1. Aging infrastructure and high utilization in the downstream sector are largely to blame for the $4.5 B of hydrocarbon losses reported over the past 2 yr.

Sphera asked companies how they identify risks. Audits and inspections, hazard and operability studies (HAZOPs), “what-if” studies and process hazards analyses (PHAs) are the most common means. Around 46% of participants suggested that they have deployed technology systems to support their risk assessments. However, they also highlighted concerns about the frequency and effectiveness of those studies. Half of the companies said they review risk every 1 yr–6 yr, with only 8% reporting that they review risk daily or weekly. Approximately 53% indicated that they are assessing only a portion of their facilities, while half are concerned with the consistency and quality of their assessment and audit practices. On average, companies reported that they are able to complete only 68% of their average safety-critical maintenance and asset integrity inspections every year. Data is siloed, systems are static and information is dated and incomplete.

Also, only 51% of respondents said they thought it was practical to set 100% of their planned maintenance and inspections to active, because limited resources (72%), conflicting priorities (71%) and limited budget (49%) were getting in the way—the same three challenges seen in every survey for the last 5 yr running. Also, average scheduled maintenance and inspections achieved has hovered at the 70% level for the last 3 yr. These results reinforce the thinking that perhaps the right tools are not available to make proactive safety decisions.

Lacking and lagging insights are perhaps the reason the majority of industry leaders told us there are gaps between well-engineered process safety approaches and the reality on assets. They also agreed that risk changes between periodic process safety review periods due to a loss of experienced personnel, lack of operational risk visibility, conflicts between procedures and work practices, and poor process execution and management of change. The factors with the most impact on those elements, however, are organizational culture, senior leadership and human factors.

Shoring up safety with real-time technologies

Companies know they are operating without the right insights—they need something more comprehensive. They also understand the value of technology and how it makes their companies and teams safer. In fact, 2020 witnessed an 11% growth in this trend over last year. Survey participants also told us that they are using technology to remotely monitor facility and operational performance, to improve work prioritization and planning, and to monitor asset health.

Some of the technology solutions companies are using today are helping them understand process safety lessons learned, changes in operating procedures and changes in equipment health and performance. Organizations also shared that they are making big investments to implement remote sensors and equipment-related risk identification tools. In fact, equipment sensors (59%) and condition monitoring (50%) are the most commonly implemented systems, with 23% deploying new equipment performance solutions at the regional level to monitor when an answer requires service.

Companies understand that they are presently operating with piecemeal data. With that understanding, it is interesting to note that 39% of companies are working their digital strategies to integrate environment, health, safety and sustainability (EHS&S) and operational risk management (ORM) solutions at the enterprise level. Integration goals are in service of creating new, data-driven business processes across functions, understanding where to make safety improvements and map dynamic risk pathways. Such dynamic risk pathways are new. Sphera’s subject matter experts have shared more about this trend.

Industry is now looking for real-time condition monitoring solutions to bring operating and asset conditions together. The creation and ongoing validation of PHAs, HAZOPs and other risk studies are time-consuming and expensive, and it can be difficult to capture ongoing and evolving information. Operators know that when well-designed and well-specified processes and equipment enter service, things begin to change. Over time, assets age; but there are also daily interventions on the plant. Things change—whether because of new management-of-change (MOC) procedures being put into place or because of existing MOCs being extended.

Impairments, startups, shutdowns and permitted maintenance activities introduce hazards and risk to the assets. This is an interesting statistic because process safety leaders see technology as the digital leap needed to overcome their siloed, lagging situations. They are now moving in a direction to simulate and visualize, in real time, the health status of risk pathways that pertain to specific scenarios captured through bowtie risk visualization diagrams and PHAs. This idea would essentially bring live data from historian distributed control systems (DCSs), maintenance systems, inspection/MOC and control of work databases to understand the operational, maintenance and verification conditions and status of safety-critical equipment in real time.

One area where technology is rapidly taking off is fog/edge computing, which enables the gathering of more data that sits closer to the asset. Industry leaders expect sixfold growth in this area. Another area is digital twin technology, which promises to support safer operations, plantwide productivity and performance, and safer, more efficient shutdowns and turnarounds. Digital twin technology is anticipated to post threefold growth.

How to know what you don’t know

Looking at the results of this year’s survey, one of the industry trends that is visible between the data presented here and the data coming from others like Marsh, is that complex systems migrate toward states of high risk, but operators often do not realize it until something bad happens. For some companies, it is not that process safety is simply “out of sight, out of mind.” These companies have done their risk studies. They have noted their lagging indicators and lessons learned. What they do not have is a joined-up, real-time view of asset and operating conditions. They know the risk this poses, and they know that no single, siloed system provides good safety indicators. Here is seen the big leap from 51% reviewing risk every 1 yr–6 yr, to 52% wanting access to the nuanced state of process safety barriers in real time and wanting the ability to simulate operating conditions based on certain risk scenarios.

The stakes are simply too high to ignore the financial and reputational savings offered by advanced asset safety monitoring. The oil and gas industry, in particular, needs this level of resilience due to the critical nature of its assets. A recent article published in the Houston Chronicle described Total’s perspective: The combination of the coronavirus pandemic and the oil crash are accelerating digital transformation to help companies boost efficiency, cut costs and make money at lower commodity prices. We hope they also find value in improving safety.

Going back a couple of years to our 2018 survey, we asked the industry what they thought the safety impact would be following the low oil price. Of the total respondents, 72% said process safety risk increases. As we saw with the Marsh data and expectations about future years, meeting those projections will require a dramatic digital transformation today. HP

Remotely Performing PHAs in a Quarantined World

With the recent global health crisis temporarily closing schools, restaurants, and businesses, and most of the global workforce operating remotely, it’s easy to wonder whether our world of face-to-face interaction will ever fully return. Though much of the world is quarantined, essential businesses like refineries must find ways to continue their operations as usual, ensuring that their engineering processes like PHAs, HAZOPs, and LOPAs are being completed to ensure the safety of employees, consumers, and the environment. The good news is that performing PHAs, HAZOPs, and LOPAs remotely is an efficient and cost-effective option during these uncertain times. With advances in video calling platforms and the willingness of teams to use more flexible communication platforms, it has never been a better time to host a remote PHA to keep your teams and facilities safe, without compromising quality.

To complete a remote PHA at your facility, it is essential to plan and organize the people and technology you will need to make the analysis a success. This includes arranging any special needs around video-calling and telecommunication, such as additional computers, monitors, and a strong internet connection at each streaming location. It is also imperative to establish a main point-of-contact at each remote location who can troubleshoot challenges around equipment and technology and maintain order amongst their team.

Once you have established the initial team members and technology, the next step in carrying out your remote PHA is preparing your leadership and facilities for the meeting. An example of this is making arrangements for site access, technological support teams, and reserving meeting rooms at each remote location. Additionally, leadership should be communicating with internal teams to pre-define questions and causes that your team can review and focus on in advance. Not only does pre-defining questions and causes improve the completeness of the analysis, but it also facilitates structured brainstorming that will make the remote PHA more productive.

While these are just a few foundational steps for planning for a remote PHA, there are resources available to support you and your team in completing a successful analysis. If you have a PHA scheduled in 2020 and are interested in hosting a remote PHA, Engineering and Technical Associates (ETA) is here to help. For over 20 years, ETA has supported some of the largest refineries in identifying potential hazards, conducting a thorough analysis of all systems and operations, and developing plans and procedures to ensure safety standards are in place in the future. Learn more about how ETA’s PHA experiences and processes can support your facility.

The Top 3 Benefits Outsourcing Your PSM Services Can Bring Your Facility

Most facilities in the chemical, petrochemical, and refining industries strive to meet the strict compliance guidelines of OSHA standard 1910.119.

Unfortunately, following all these process safety management (PSM) standards can often prove to be harder than anticipated.

And in many cases, it makes more sense to partner with an outside resource for PSM services than to handle everything in-house.

Outsourcing your PSM services can bring your facility many benefits. Here are the top three.  

1) Guaranteed Expertise in all 14 PSM Elements = Prevention of Future Incidents

Most – if not all – industrial facilities run lean operations nowadays. Employees have to wear multiple hats, and as a result, many companies don’t have the manpower to build an internal team that has expertise in all 14 PSM elements:

  • Employee Participation
  • Process Safety Information
  • Process Hazard Analysis
  • Operating procedures
  • Training
  • Contractors
  • Pre-Startup Safety Review
  • Mechanical Integrity
  • Hot Work Permit
  • Management of Change
  • Incident Investigation
  • Emergency Planning and Response
  • Compliance Audits
  • Trade Secrets

By outsourcing your PSM services to the right organization, though, you can ensure that your PSM partners have expertise in all these elements – many of which have specific, detailed requirements.

You can then rest assured that all aspects of your PSM operations are being met fully to OSHA standards.

Key Takeaway: You can guarantee that all 14 PSM elements will be met – and effectively – by working with the right outside resource for your PSM services. 

2) A Wealth of Knowledge Beyond Just What’s in Your Facility = Industry Expertise

Most internal teams involved in PSM gain their knowledge and undergo their training in-house. This has some benefits in that your internal teams know your facility already, know your company’s goals and understand how your company works.

But the pitfalls can far outweigh the benefits.

Here’s the problem. In scenarios like this, your internal team’s knowledge only extends as far as the facility. They most likely don’t have outside PSM knowledge of best practices beyond their facility – and, indeed, beyond their industry. 

Also, PSM staff turnover is a real and common problem in many facilities, where chemical engineers assume this role but only view it as a stepping stone in their careers. Often, employees who work in PSM do so for a short time and do not want to do this permanently.

That’s why partnering with an outside resource who specializes in and has a wealth of knowledge about PSM can bring many benefits to your facility.

Their years of experience and expertise can provide you with more best practices and an impartial approach to all elements of PSM from training to compliance audits. You can also work with a team with years of experience in PSM instead of, say, recent training so that you know that you’re working with industry experts.

Consequently, you can mitigate the possibility of risks and hazards in your facility, avoid or prevent violations, and more.

Key Takeaway: Many internal PSM teams have limited time and knowledge, but an outside resource can have the industrywide knowledge and experience your facility needs to have the utmost in safety procedures.

3) A Questioning Attitude that Helps You Uncover – and Prevent – the Root Causes of Incidents and Violations

As we previously mentioned, many refineries, chemical facilities, and petrochemical facilities have tended to run lean in recent years. Often, the internal teams handling PSM aren’t always passionate about their jobs. So, what happens when you have an incident?

Here’s something we’ve seen more times than we can count in our PSM work throughout the years.

An incident occurs. The facility gets in trouble. They’re already on the OSHA and EPA radars. Then there’s another follow-up incident. Things quickly snowball.

Why is this?

After the initial incident occurs, many teams do not have the time, expertise, or dedicated staff to do a root cause analysis and keep digging and questioning until the real root(s) of the problem are found. And that makes sense; this takes quite a bit of time.

Due to a lack of time, though, many facilities will just take what the problem is at face value, identify measures to remedy it, and then move on. But that often doesn’t solve the actual cause(s) of the problem. So, another incident occurs. And the issue isn’t really solved at all.

But by outsourcing your PSM services, you will have a team that has the time, expertise, and experience to find out the root causes of incidents in your facility. That way, you can identify these causes, come up with a plan of action to ensure they don’t happen again and prevent future violations.

Key Takeaway: If you outsource your PSM services to an organization that specializes in PSM, you will have the time, the team, and the process to uncover the root causes of incidents in your facilities and stop them in the future.   

Conclusion

Working with an outside resource for your PSM services can provide you with many advantages including:

  • Guaranteed expertise in all 14 PSM elements
  • A wealth of knowledge beyond just what’s in your facility
  • A questioning attitude that helps you uncover – and prevent – the root causes of incidents and violations

As experts in PSM consulting, ETA has been at the forefront of developing OSHA-specific programs and helping companies in the chemical, petrochemical, and refining industries to meet the strict compliance guidelines of OSHA standard 1910.119 since it was first issued in 1992.

ETA consultants and project managers serve as industry leaders in the world of PSM. If you are looking for a dedicated and experienced partner for your PSM services, start the conversation today. Get in touch with ETA.

The Top 4 Process Safety Management (PSM) Elements for OSHA Citations

Of the 14 elements which make up OSHA standard 1910.119, there are four which most refineries, chemical facilities, and petrochemical facilities can get citations from OSHA.

In today’s article, we’re going to explore what those elements are, why companies have findings for them, and how ETA can help ensure that you don’t have violations in the future.

Let’s dive in.

1) Operating Procedures

OSHA Number: OSHA Standard 1910.119(f)

How OSHA Defines It: “The employer shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements.”

Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.

  • An employer’s written operating procedures did not address emergency shutdowns.
  • One company did not certify annually that their operating procedures were accurate and current.
  • Another facility did not provide their employees with written operating procedures which provided clear instructions that addressed elements like temporary operations, operating limits, emergency operations, and consequences of deviations.

2) Process Hazard Analysis (PHA)

OSHA Number: OSHA Standard 1910.119(e)

How OSHA Defines It: “The employer shall perform an initial process hazard analysis (hazard evaluation) on processes covered by this standard. The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process.”

Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.

  • One facility’s use of the What-if methodology did not completely evaluate the hazards of the process being analyzed.
  • Another employer did not complete a finding to address the toxic gas hazard from an uncontrolled release and dispersion identified in a previous study.
  • One company received a serious violation for not performing an initial process hazard analysis for their chlorine process.

3) Mechanical Integrity

OSHA Number: OSHA Standard 1910.119(j)

How OSHA Defines It: This relates to all aspects of process equipment in a facility, from written procedures to training for process maintenance activities, inspection and testing, quality assurance, and corrections to equipment deficiencies.

Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.

  • One facility did not perform inspection and tests on process equipment in their propane container filling and evaluation areas.
  • Another employer did not develop and implement a written integrity procedure for evaluating valves in the chlorine process.
  • One facility didn’t develop and implement a written mechanical integrity procedure that addressed inspective pressure vessels and piping for minimum wall thickness.

4) Management of Change

OSHA Number: OSHA Standard 1910.119(l)

How OSHA Defines It: “The employer shall establish and implement written procedures to manage changes (except for ‘replacements in kind’) to process chemicals, technology, equipment, and procedures; and, changes to facilities that affect a covered process.” 

Why Violations Occur with This Element: Here are some real-life examples of why companies received citations for this element in the past few years.

  • An employer did not ensure that written procedures were established and implemented for the installation of a larger container filling station.
  • Another facility did not establish procedures to address all process changes, and as a result, modifications affecting the covered process could not be completed without proper analysis and assessment.

How ETA Can Help

Through our PSM consulting services, we work with all of your staff to ensure that they are trained in the basics of PSM and the specifics of their role in implementing a PSM program.

Our goal is that every employee will fully understand the hazards involved in their industries and their specific role in eliminating and/or minimizing those hazards.

Most findings are uncovered during PSM audits. During this time, we turn these finds over to our clients so they can identify ways to prevent these findings from turning into citations.

We can work with your staff to develop programs to address potential issues and establish procedures for best practices within your facility.

But there’s more. In addition to PSM audits, we also can work with you for your PHAs and help you identify all potential hazards by using the HAZOP method to ensure that this element is fully addressed per OSHA standards.

Contact ETA today to prevent future violations and ensure that you do not have citations for these four – or any – PSM elements.