WA DOSH update – Damage Mechanism Reviews (DMR)

On December 27, 2023, the Washington Division Occupational Safety and Health (DOSH) filed a permanent rulemaking motion to adopt changes to how Process Safety Management (PSM) is handled for oil refineries within the state of Washinton.  This regulation was approved in response to high-profile industry incidents in the state of Washington in the last 5 to 10 years.  This regulation closely mirrors the updated PSM standard passed in California in 2017.

Some key elements added in this regulation are:

• Damage Mechanism Reviews (DMRs) – reviews that consider where corrosion, mechanical damage, environmental cracking, etc. are identified for process equipment
• Hierarch of Hazard Controls Analysis – a review to identify appropriate the most appropriate means for managing hazards
• Management of Organizational Change – applying the principles of management of change (MOC), part of the PSM process, to changes in personnel within the refinery.
• Root Cause Analysis – utilizing a root cause approach to investigate any instance that could reasonable result in a major incident

Specifically, Damage Mechanisms Reviews are not necessarily new to the refining industry, but DOSH has defined them and listed required elements in the new safety order.  DMRs are intended to be part of the Process Hazard Analysis (PHA) which has long been a part of PSM regulations.  The DMR is intended to review the process unit from a corrosion and materials standpoint.  Some of the key elements required to meet the new regulation include:

• Assessment of process flow diagrams
• Identification of all potential damage mechanisms
• Determination that the current materials of construction are appropriate for the application and are resistant to potential damage mechanisms
• Methods to prevent/mitigate damage
• Review of operating parameters to identify conditions that could accelerate damage
• For items where no potential damage exists, the rationale must be documented as well.

DMRs must be documented and available to the PHA team as well as those working with the process unit.  All DMRs must be kept for the life of the process unit.  Also included in the new regulation is a time frame to implement the new requirements.  The schedule is presented below

• The first set of DMRs must be completed within 5 years of the approval of the new safety order
• 50% of the intial DMRs must be completed within 3 years of the approval of the new safety order
• The DMR for a process unit must be revalidated at least once every 5 years.
• DMRs are required to be reviewed as part of a major process change

Becht’s Corrosion, Materials, and Integrity Division has a broad array of Corrosion and Metallurgical experts with owner-operator experience covering the refining, petrochemical and chemical industries.  We have experts in a wide range of materials including metals, refractories and non-metallics.  In addition, we have Chief Inspectors who work with the materials team to provide practical inspection advice.  We also team with Becht’s Process Engineering group to provide process corrosion troubleshooting.  Since our experts typically join us from long-standing careers within owner-operator organizations, we approach corrosion and materials problems from an owner’s perspective.

If Becht can help with facilitating a DMR assessment at your refinery, please contact us.