The Baker Panel Report - ABSA

System Finding 7 – Action item completion. At all five refineries, over the past fewyears, BP had many process safety-related action items that had not been resolved orimplemented in a timely fashion. BP also had many action items that were seriouslyoverdue based on BP’s established implementation schedule.3.8 Area Electrical Classification – Out-of-Date Drawings, UnpressurizedStructures and Enclosures with Inadequate Gas Monitoring, andUncontrolled Ignition SourcesOSHA’s PSM standard requires a facility to maintain process safety information forcovered processes, including information regarding area electrical classification. Onebasis for this requirement is that ignition sources in refinery areas where flammable vaporclouds can form represent a hazard that a site should control to reduce the risk of firesand explosions.Various organizations have published recommended practices, codes, and standards forcontrolling the design and placement of electrical devices in such areas, including APIand the National Fire Protection Association (NFPA). These guidance documentsprovide guidance about (1) classifying areas according to the potential for formation offlammable vapor clouds, (2) restricting or controlling the types of electrical devices thatare allowed in the classified areas, and (3) addressing the design of structures andventilation systems within classified areas. Refinery buildings and equipment enclosuressubject to such standards include control rooms, operator shelters, motor control centers,computer rack rooms, instrument panels, and analyzer boxes.At all five refineries, the PSM Review Team observed instances where the refinery didnot conform to area electrical classification guidance contained in API RecommendedPractice 500 or National Fire Protection Association Standard NFPA 496. 18,19 Theseinstances included (1) rooms and enclosures where the ventilation and pressurizationsystems and seals were out of service or ineffective, (2) inoperative or inadequateflammable gas detection in rooms/enclosures, and (3) outdated electrical areaclassification drawings that inaccurately depicted classified area restrictions.The PSM Review Team also observed uncontrolled vehicle access in electricallyclassified areas. Although API Recommended Practice 500 does not explicitly addressvehicle access in such areas, the PSM Review Team considers internal combustionengines in vehicles as potential ignition sources. Some companies develop andimplement restrictions on vehicle access to areas in close proximity to process units,including plant roadways, with reference to electrical classification. The PSM ReviewTeam considers this to be a good engineering practice.System Finding 8 – Area electrical classification. At all five refineries, BP hadinstances where the refinery did not meet one or more of industry standards,recommended practices, or good practices with respect to area electrical classification.28