The Washington State Department of Labor & Industries announced June 25 that it found 23 “serious” safety and health violations at the Shell Puget Sound Refinery during an inspection aimed at reducing the likelihood of catastrophic events associated with operations.

There were shortcomings in their processes, said Elaine Fischer, L&I media contact for workplace safety and health. The violations carry proposed penalties totaling $109,600. They ranged from engineering safety controls that could fail because they were not properly tested to employees not being trained to respond to emergencies, she said.

The department cites companies for violations in three categories. A serious classification is when a violation has the potential to cause death or serious physical injury. A general violation pertains to actions not likely to cause injury or death and typically does not come with a penalty. A willful violation is cited in the case an employer knows of the situation and does nothing to correct it.

The company had 15 working days to appeal the citation.

“We have until July 1 to review the statement and determine our next course of action,” Shell spokesperson Brian Sibley said last week. “We’re reviewing it right now.”

The violations were found during a focused inspection by L&I.

The Shell refinery was the first of four large refineries in the state to go through a comprehensive inspection as part of a federal National Emphasis Program aimed at inspecting all U.S. petroleum refineries.

The program spurred from a 2005 explosion and fire at a BP America refinery in Texas that killed 15 employees and injured 170.

Previously, inspections were typically only conducted if L&I received a complaint or report of an injury.

The Tesoro refinery on March Point next to Shell will go through an inspection within the next two years, Fischer said.

The inspections focus on a refinery’s development and implementation of systems designed to reduce or mitigate the potential for catastrophic releases of highly hazardous chemicals. Refineries are required to identify, evaluate and control process hazards; develop and implement mechanical integrity programs; and train operators who must monitor and respond to deviations in the process.

L&I officers were at the refinery two days a week for two months conducting on-site inspections, interviewing employees and reviewing 10,000 pages of documents.

They found deficiencies in the compilation of process safety information; failure to identify, evaluate and control process hazards such as those relating to atmospheric releases of highly hazardous chemicals into the work area, potential failure of existing engineering and administrative safety controls, and human performance issues during emergencies; deficiencies with the development and implementation of mechanical integrity programs, such as inspection and testing of safety systems and other control devices designed to prevent or mitigate catastrophic events; inadequate training programs to ensure operators understand and respond appropriately to process upsets and other emergency operating conditions; failure to evaluate changes to process equipment and ensure safety reviews are completed prior to placing equipment back into service; and controlling activities in covered process areas.