A good process safety management (PSM) program in an ethanol plant is thorough down to the details, including a diagram of every pipe, valve and sensor, showing model and make—the pipe and instrument diagram (P&ID). Backing that up are files of process safety information (PSI), including, but not limited to material safety data sheets (MSDS). There's also SOPs, MIPs, the PSSR, MOC and PHA to consider.
"A producer would be wise to have someone who understands all of those acronyms and what they mean," says Charles Palmer, a partner with the law firm Michael Best and Friedrich LLP. While ethanol producers know well that an accident or complaint can trigger an inspection by the Occupational Health and Safety Administration, in the past two years, OSHA has also randomly selected several plants for inspection. Since November 2011, OSHA has had a national emphasis program on process safety management.
Though ethanol plants are small compared to mammoth oil refineries or petrochemical manufacturers, they are held to the same comprehensive process safety standards. There is one big difference. "One of the nice things about the ethanol industry is that it is a relatively new area of energy production," says Greg Dale, a partner with Faegre Baker Daniels LLP. "As an industry, it's relatively new compared to petroleum. We're dealing with newer equipment, more modern technology and, associated with that, more modern safety parameters built into the system."
A search of the OSHA database for records involving ethyl alcohol manufacturers shows that, indeed, older facilities generally have the most violations. Over the past three years, the number of violations per plant ranged from just one to the highest at 17, with most being less than five violations. The penalties ranged from just under $1,000 to nearly $10,000 per violation. The initial penalty was almost always reduced. In 2011, 23 plants were inspected and in 2012 another 15. Ten plants were inspected through June of this year.
The database reveals that in the 12 inspections conducted between October 2011 and September 2012, there were 77 violations and a total of $160,000 in penalties. By far, the largest category was for process safety management violations, at 37, accounting for $113,000 in penalties. The other categories trailed far behind, with six violations on permit-required confined spaces and five citations each for respiratory protection, hazard communication and general requirements. Other categories received one or two citations each.
"The guys that got five citations, but who really put a lot of work into their PSM and felt they had their ducks in a row and were really on top it, were surprised that they got five citations," Palmer says. "You're talking about people who take a lot of pride in what they do, and one citation is too much." It can be challenging, too, to explain the fines to a board of directors, he says. "But there's hundreds of different ways you can be cited under the PSM standard and it's unusual that if OSHA is doing a PSM inspection you don't get a citation."
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