PSM Covered Chemical Facilities National Emphasis Program goes NATIONWIDE!

OSHA promulgated the PSM standard in 1992 in response to a number of catastrophic incidents that occurred worldwide (See Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119).  These incidents spurred broad recognition that releases of highly hazardous chemicals could lead to incidents that may occur relatively infrequently, but, due to their catastrophic nature, often result in multiple injuries and fatalities.

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On September 13, 1994, OSHA issued Instruction CPL 02-02-045, Process Safety Management of Highly Hazardous Chemicals – Compliance Guidelines and Enforcement Procedures.  This instruction established policies, procedures, clarifications, and compliance guidance for enforcement of the PSM standard.  The instruction acknowledged that Program Quality Verification (PQV) inspections were resource intensive, and, therefore, OSHA would perform only a limited number each year.

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Consequently, very few PQV inspections have been conducted since Instruction CPL 02-02-045 was issued in 1994.

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In July 2009, OSHA implemented a pilot NEP for PSM-covered chemical facilities.  The pilot outlined a new approach for inspecting PSM-covered facilities that allowed for a greater number of inspections using better allocation of OSHA resources.  Under the pilot, OSHA was able to increase the number of PSM facilities inspected with relatively limited resources.

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Based on data collected and feedback from OSHA personnel, this Instruction outlines a slightly modified Chemical NEP that will be launched OSHA-wide…

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This Instruction expands the PSM-Covered Chemical Plants National Emphasis Program nationwide to all OSHA Regions and State Plans.

  • Facility categories have been reduced from three in the pilot NEP to two: facilities likely to have ammonia used for refrigeration as the only Highly Hazardous Chemical (HHC) and all other facilities.
  • The number of programmed inspections required per Area Office has been reduced.
  • Significant industry and/or OSHA experience has been recognized for CSHO qualifications to conduct PSM inspections.
  • A requirement to verify abatement of previous OSHA PSM citations has been added.
  • Instructions for preparing targeting lists have been clarified, and program evaluation requirements have been reduced.
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You can read the directive CPL 03-00-01 here.

Other than the above changes it’s the same as it has been for the past two years. I’d suggest you schedule yourself for an NEP level PSM course in the near future. Reading the questions in the refinery PSM NEP are a good way to get yourself oriented towards the current view of acceptable PSM implementation.

The NEP is focused on PSM Ammonia Refrigeration Systems as Category 1 facilities and non-refrigeration Ammonia and other non-refinery PSM covered facilities as Category 2.

About Brian Chapin

PSM / RMP Compliance Consultant
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