Tuesday, June 8, 2010

This presentation will cover three basic elements related to the OSHA Chemical National Emphasis (CNEP) Program Directive: an overview, pertinent details, and actions to take now. The overview will discuss the CNEP pilot regions, facility selection, exemptions, and inspection scheduling of PSM covered facilities. Pertinent details will include the dynamic questions process, inspection protocol, documents requested, selection of unit(s), involvement of contractors, and the citation process. The discussion of possible actions to take now will discuss initial considerations, preparation before and after the pilot period, and general strategies for handling CNEP inspections.

This presentation will cover four elements related to the OSHA Chemical National Emphasis (CNEP) Program Directive. First, it will compare the CNEP with the Refinery National Emphasis Program (RNEP) that has previously been implemented. This comparison will include duration of the inspections, units inspected, categories, and questions asked. Second, it will reflect on what industry has learned from the RNEP activities, discussing aspects including the number of inspections, inspection emphasis areas, and types of citations issued. Third, it will discuss CNEP inspection preparation including what type of plan is needed, documentation requirements, use of the existing site PSM activities, and what preparation approaches might be used regarding the dynamic questions. Finally, managing the inspections will be covered by giving guidelines to follow during the actual inspection.

Currently there are two on-going U.S. DOL - OSHA (OSHA) enforcement initiatives involving PSM covered processes in the chemical and refining industries. On June 7, 2007, OSHA initiated a Petroleum Refinery Process Safety Management (PSM) National Emphasis Program (Refinery NEP) in response to a large number of fatal or catastrophic incidents in the petroleum refining industry. Knowing that similar catastrophic hazards exist in chemical facilities outside the refining industry, OSHA initiated its PSM Covered Chemical Facilities NEP (Chem NEP) on July 27, 2009. The Chem NEP is a pilot program targeted at chemical facilities with PSM covered processes. This presentation will describe OSHA’s NEPs and associated findings to date, including the elements of the PSM standards that were most frequently cited.

On July 27, 2009 OSHA published Directive 09-06 (CPL 02), PSM Covered Chemical Facilities National Emphasis Program. This instruction, which follows the agency's process safety emphasis program for petroleum refineries, details the agency's plans to conduct programmed inspections at chemical facilities covered by the PSM Standard. This presentation offers a legal perspective on preparing for and then managing an inspection under the Chemical NEP.

The OSHA Refinery National Emphasis Program (RNEP) and OSHA Voluntary Protection Program (VPP) incorporate specific questions relative to many recognized and generally accepted good engineering practices (RAGAGEP). Many of the same RAGAGEP can be expected to be used in the OSHA Chemicals NEP (CNEP) as well. In order to comply with OSHA’s process safety management (PSM) regulation and improve process safety at their sites, chemical industry personnel should be aware of what RAGAGEP OSHA is recognizing and inspecting against and their key requirements.

This presentation will discuss:

1. OSHA’s expectations for compliance with RAGAGEP, including the RAGAGEP OSHA references in compliance directives, instructions, and citations,
2. some citations issued by OSHA involving RAGAGEP, and
3. common RAGAGEP compliance issues ABSG Consulting Inc. (ABS Consulting) observes when conducting PSM audits and assessments throughout the petrochemical and related industries