If you aren’t familiar with the NEP (National Emphasis Program) currently going on in specific regions it would be well worth your time to get up to speed. Even if you have a top-notch program you’ve got a LOT of work to do to become compliant with the way OSHA is interpreting the requirements of the PSM standard under the NEP.
What is the NEP?
The NEP is a pilot program implemented in 2009 covering regions 1, 7 and 10 that was supposed to last for a year. It is still going on while they rewrite and extend the program with the intent of making it permanent and nation-wide. The old PQV (Program Quality Verification) audits under CPL 2-2.45 are child’s play compared to an NEP inspection. NEP focuses on implementation: what your program does rather than what it says – it’s a performance audit. The average NEP compliance audit is done by a specially trained team and results in over 7 citations in each facility inspected.
What can I do?
Arm yourself with the knowledge you need to improve your program’s performance so that it meets the higher standards required under the NEP. Here are some steps I would recommend:
- Read the Petroleum Refinery NEP paying specific attention to appendix A. This lists the questions to be asked and the possible violations. Some of what you read here is refinery specific, but the inspection is about Process Safety and the vast majority of it is applicable to an NH3 Refrigeration Process.
- Expand your personal library to include CCPS books. The Center for Chemical Process Safety publishes many books on effective implementation of PSM programs. Many of those books are directly referenced as RAGAGEP under the NEP. Specifically consider the following:
- Guidelines for Mechanical Integrity Systems
- Guidelines for Investigating Chemical Process Incidents
- Guidelines for Writing Effective Operating and Maintenance Procedures
- Find a good NEP class to attend. Obviously I’m partial to the GCAP NEP course. You’ll learn more in this 40hr class there than you can possible imagine.
- Network: At a NEP class, you’ll make some important contacts with fellow PSM practitioners. Join the “Ammonia Refrigeration Operators” discussion group on LinkedIn to discuss implementation strategies and NH3 PSM best practices.
The first response to a lot of this information (especially when reading the questions in the refinery NEP) is usually despair: there’s a lot of work ahead. Just remember – you aren’t alone in this unless you choose to be! There are resources out there to assist you. If you are willing to put in the time and effort, compliance to the NEP is achievable!
Previous post on this subject here.
OSHA memo explaining that the NEP will become permanent here.