Since 2011, Ammonia Refrigeration facilities with 10,000lbs. or more of Anhydrous Ammonia have been subject to ChemNEP inspections under CPL 03-00-14. OSHA has replaced this program with a new program that makes some changes:<\/p>\n
The details of the new program are posted in the new CPL 03-00-021<\/a> which is available on the OSHA website or, if you use our templates, in the References section of the Google Drive shared folders. Here are some highlights of the new inspection program:<\/p>\n Documents Requested Prior to Identifying the Selected Unit(s):<\/p>\n * OSHA 300 logs for the previous three years for the employer and the process-related contractors.<\/p>\n * All contract employee injury and illness logs as required by 1910.119(h)(2)(vi).<\/p>\n * A list of all PSM-covered process\/units in the complex.<\/p>\n * A list of all units and the maximum intended inventories of all chemicals (in pounds) in each of the listed units. * Unit process flow diagrams.<\/p>\n * Process narrative descriptions.<\/p>\n * Host employer\u2019s program for evaluating contract employer\u2019s safety information.<\/p>\n * Host employer\u2019s program\/safe work practices for controlling the entrance\/exit\/work of contractors and their workers in covered process areas.<\/p>\n * Emergency Action Plan; and Emergency Response Plan if the facility is also required to comply with 29 CFR 1910.120(q).<\/p>\n * Host employer\u2019s program for periodically evaluating contractor performance.<\/p>\n Documents Requested After the Selected Units are Identified:<\/p>\n * Piping and instrumentation diagrams (P&IDs) including legends.<\/p>\n * Unit electrical classification documents.<\/p>\n * Descriptions of safety systems (e.g., interlocks, detection or suppression systems).<\/p>\n * Design codes and standards employed for process and equipment in the Selected Unit(s).<\/p>\n * A list of all workers (i.e., hourly and supervisory) presently involved in operating the Selected Units(s), including names, job titles, work shifts, start date in the unit, and the name of the person(s) to whom they report (their supervisor).<\/p>\n * The initial process hazard analysis (PHA) and the most recent update\/redo or revalidationfor the Selected Unit (s); this includes PHA reports, PHA worksheets, actions to address findings and recommendations promptly, written schedules for actions to be completed, and documentation of findings and recommendations.<\/p>\n * Safe upper and lower operating limits for the Selected Unit(s).<\/p>\n * A list by title and unit of each PSM incident report; all PSM incident reports for the Selected Unit.<\/p>\n * Contract employer\u2019s safety information and programs (this will be requested from the host employer after it is determined which contractor(s) will be inspected).<\/p>\n * Contractor employer\u2019s documentation of contract workers\u2019 training, including the means used to verify employees\u2019 understanding of the training (this will be requested from the respective contractor employer(s) after it is determined which contractor(s) will be inspected).<\/p>\n * Other documents as specified in the Dynamic Lists.<\/p>\n * Prior ChemNEP Dynamic List questions Note that this guidance specifically includes the CCPS book \u201cGuidelines for Hazard Evaluation Procedures, 3rd Edition\u201d which focuses on PHAs. We have long counseled using the CCPS guidance to better understand what a successful PSM program looks like from both a design perspective as well as an implementation one.<\/p>\n Coupled with the EPA\u2019s announcement that they have begun implementing their enforcement initiative<\/a>, there has never been a better time to consider a thorough 3rd party\u00a0Compliance Audit<\/a>.<\/p>\n","protected":false},"excerpt":{"rendered":" Since 2011, Ammonia Refrigeration facilities with 10,000lbs. or more of Anhydrous Ammonia have been subject to ChemNEP inspections under CPL 03-00-14. OSHA has replaced this program with a new program that makes some changes: Merges the Petroleum and Chemical NEPs … Continue reading \n
\n* A summary description of the facility\u2019s PSM program.<\/p>\n\n
\n* Old Petroleum NEP (CPL 03-00-010) questions
\n* CPL 2-2.45 PQV (CPL 2-2.45a) questions
\n* CCPS Guidelines for Hazard Evaluation Procedures, 3rd Edition<\/p>\n