Emergency preparedness and response require significant employee involvement. Marathon's
Corporate Emergency Response Team (CERT) comprises employee volunteers who are available
at all times to respond to spills, natural disasters and other business interruption
scenarios at any Marathon location. In 2007, 170 CERT members participated in the triennial
Spill of National Significance (SONS) exercise mandated by the U.S. Oil Pollution Act of
1990. The SONS exercise provides training for federal agencies to respond to a catastrophic
release. Marathon's CERT members helped set up a base of operations for the exercise in
Evansville, Indiana, and responded to incident scenarios. The drill involved approximately
5,000 state, federal and private sector employees from 13 states, four U.S. Environmental
Protection Agency (EPA) regions and four U.S. Coast Guard sectors.
Process Safety
PSM is a system for managing process safety associated with highly hazardous chemicals.
In the U.S., OSHA's Process Safety Management of Highly Hazardous Chemicals Standard is
the main regulation to reduce and/or eliminate hazards related to potential chemical or
hydrocarbon releases. Regulatory authorities in some non-U.S. countries maintain similar
standards.
Marathon applies PSM principles in its operations worldwide, both in government-regulated facilities as required and in facilities that are not covered by host government regulations. In the U.S., 12 Marathon facilities, including refineries, natural gas plants, terminals and a chemical plant, are subject to OSHA's PSM standard. U.S. Gulf of Mexico operations comply with U.S. Minerals Management Service regulations similar to OSHA PSM.
Marathon focuses on preventing process safety incidents by designing appropriate safety systems into processes and equipment, operating according to established procedures, applying safe work controls, maintaining equipment, employing management of change, learning from incidents, being prepared for emergencies, assessing and improving performance, and involving workers. These practices are formalized in the Marathon PSM Standard.
To comply with government regulations and Company policy, Marathon has a three-tiered auditing program for regulated facilities. The tiers include internal audits, compliance audits generally performed by a third party and management system audits. All regulated facilities are expected to conduct formal internal audits or inspections on a three-year cycle. In 2007, all regulated U.S. refineries and the chemical plant conducted internal PSM inspections, and some facilities conducted audits led by third parties. Upstream PSM sites performed audits, some of which focused on specific PSM elements.
In 2007, OSHA launched a PSM National Emphasis Program (NEP) to review PSM at all U.S. refineries. Marathon's Canton, Ohio, refinery was randomly selected as one of the first OSHA NEP audit sites. The NEP inspection reviewed compliance with PSM requirements and other workplace safety regulations administered by OSHA. The Canton audit resulted in 46 citations, including 32 related to PSM, and a total fine of $321,500. The refinery had addressed more than half of the NEP findings by year-end 2007 and plans to address the remaining issues in the first half of 2008. Lessons learned from the NEP audit were incorporated into the corporate PSM Standard.
