Last year our good friends at OSHA finally started moving their PSM inspectors away from the oil refineries. A National Emphasis Plan was created to audit PSM. The NEP is targeted at Ammonia and Chlorine users – 32411 NAICS code is exempt so this only applies to NON-refineries.
A few years ago you’ll recall they trained some 200 inspectors to audit the oil refineries and the concern was these same inspectors would be released on the rest of us when they were done. I had an outside PSM audit a few years ago from a consultant who had previously worked only with oil refineries – it was an extremely frustrating experience compared to working with someone experienced in ammonia refrigeration PSM.
Regions 1, 7 and 10 have already been dealing with increased programmed inspections since the programs inception in July 0f 2009. The NEP was to expire on July 26th but last week OSHA has announced that they have extended the National Emphasis Program (NEP) for Process Safety Management (PSM) inspections until September 30, 2010. Furthermore, State Plan adoption has been encouraged. Unprogrammed inspections associated with this program will be done in all regions. For further information download the pdf. 09-06 (CPL 02), PSM Covered Chemical Facilities National Emphasis Program
Here is the relevant portion of the CPL concerning when an unprogrammed inspection can occur:
a. Complaint or referral. If a formal complaint or referral is received relating to a PSM-covered process and it:
- involves an application of the PSM standard – the AD shall evaluate the complaint or referral item(s) in the usual manner (CPL 02-00-148 – Field Operations Manual) and conduct an inspection using this notice.
- does not involve an application of the PSM standard (for example, there is a complaint about PPE requirements in a PSM covered process) – the inspection or inquiry will normally be limited to the complaint and referral item(s)/subject(s) only. However, if the facility has not already been inspected using this notice, a concurrent inspection using this NEP may be conducted at the AD’s discretion.
b. Accidents and Catastrophes. Responses to accidents and catastrophes in facilities that contain PSM-covered processes shall follow the guidelines contained in CPL 02-00-148 – Field Operations Manual and, where appropriate, in OSHA Instruction CPL 02-00-094, OSHA Response to Significant Events of Potentially Catastrophic Consequences in addition to this Notice’s guidelines.
When an accident or catastrophe occurs in a facility that contains a PSM-covered process, and it:
- involves an application of the PSM standard – an inspection will be conducted as per CPL 02-00-148 in addition to this notice.
- does not involve an application of the PSM standard – the inspection will normally be limited to the accident investigation item(s)/subject(s) alone. However, if the facility has not already been inspected using this notice, a concurrent inspection using this NEP may be conducted at the AD’s discretion.
Brian is there any good training out there for NEP? i’m looking on expanding my knowledge base and be better prepared for any compliance audits from Osha.
The one I hear about consistently is the CGAP NEP course. I’m quite a believer in their programs.