Description
The chemical facility National Emphasis Program (NEP) is a focused inspection program by OSHA to verify compliance with OSHA's Process Safety Management (PSM) standard (29 CFR 1910.119) at covered facilities. It began in November, 2011 and follows on from a pilot chemical facility NEP initiated in July, 2009 and a petroleum refinery NEP that began in June 2007 and is now concluded.
Previously, OSHA conducted Program, Quality, Verification (PQV) inspections but few such inspections were possible as they are resource intensive. PQV inspections are broad and open-ended, while chemical NEP inspections rely on specific investigative questions. The goal of the chemical NEP is to conduct a large number of focused inspections. The chemical NEP inspections will focus on whether companies have properly implemented their PSM programs.
Companies perform a triennial audit under OSHA's PSM program but such audits usually do not achieve the depth of chemical NEP inspections. Consequently, facilities that have passed a triennial audit may not pass a chemical NEP inspection. Therefore, covered facilities should take steps to prepare for the possibility of a chemical NEP inspection. OSHA inspectors likely will arrive unannounced at chemical plants. Preparation for a chemical NEP inspection will not only assist in reducing regulatory liability but also help to ensure a safe and productive workplace.
What Should You Do?
- Ensure your PSM program is not only documented but also implemented
- Orient management and employees regarding the chemical NEP
- Ensure your PSM documents and files are organized and readily available
- Close out aging PSM action items
- Ensure PSM projects are on schedule
- Arrange for an independent review and gap analysis and institute any needed remedial measures before you are visited by OSHA
- Arrange for any needed assistance
You may wish to obtain the sevices of an experienced consultant to assist your preparations.
Why Primatech?
Primatech has performed many PSM audits, reviews, and evaluations for a variety of clients in all areas of the process industries. For over 20 years, we have operated the Primatech Training Institute that provides process safety training in over 30 courses, including courses on PSM and auditing. Primatech has developed the software tool, AUDITWorks, to facilitate audits and customized audit protocols that reflect the issues of concern to OSHA in the chemical NEP. We have an intimate understanding of process safety and OSHA's PSM standard having been a leader in PSM consulting for 25 years.
Primatech was selected by OSHA to produce an annotated version of the PQV checklist to assist OSHA inpectors in understanding the requirements of the PSM standard. Primatech was also selected by the Baker panel to perform an independent assessment of the PSM audit performed by BP for the Texas City refinery as part of the investigation of the explosion and fire that occurred on March 23, 2005.
Our highly-experienced consultants provide clients with comprehensive, needs-based solutions that are tailored to meet their implementation challenges.
Services Offered
- Assistance in preparing for a chemical NEP inspection
We assist you in assembling and executing a plan for managing OSHA's inspection. We help to ensure your PSM records are in order and readily accessible. We review documents and records to ensure they demonstrate you are implementing your PSM program as designed. We advise on recognized and generally accepted good engineering practices (RAGAGEP) that are a key focus of the chemical NEP. - Performance of a gap analysis
We review key parts of your PSM program against OSHA requirements and identify deficiencies so they can be corrected in advance of a chemical NEP inspection. - PSM program improvements and gap closure
We advise and assist in improving any part of your PSM program to meet anticipated OSHA requirements. - Process safety studies
We conduct projects to complete items that may be missing from your PSM program such as facility siting studies. - On-site support
We provide experienced process safety personnel on a temporary basis to assist in closing out PSM action items and improving PSM practices. - Management and employee briefings
We orient your staff to the chemical NEP so they will be prepared for OSHA's arrival. - Support during inspections
We assist you in responding to OSHA feedback and citations resulting from the chemical NEP inspection. - Support after inspections
We can assist you in addressing OSHA findings and correcting deficiencies in your PSM program.
