Accendo Reliability

Your Reliability Engineering Professional Development Site

  • Home
  • About
    • Contributors
  • Reliability.fm
    • Speaking Of Reliability
    • Rooted in Reliability: The Plant Performance Podcast
    • Quality during Design
    • Critical Talks
    • Dare to Know
    • Maintenance Disrupted
    • Metal Conversations
    • The Leadership Connection
    • Practical Reliability Podcast
    • Reliability Matters
    • Reliability it Matters
    • Maintenance Mavericks Podcast
    • Women in Maintenance
    • Accendo Reliability Webinar Series
    • Asset Reliability @ Work
  • Articles
    • CRE Preparation Notes
    • on Leadership & Career
      • Advanced Engineering Culture
      • Engineering Leadership
      • Managing in the 2000s
      • Product Development and Process Improvement
    • on Maintenance Reliability
      • Aasan Asset Management
      • CMMS and Reliability
      • Conscious Asset
      • EAM & CMMS
      • Everyday RCM
      • History of Maintenance Management
      • Life Cycle Asset Management
      • Maintenance and Reliability
      • Maintenance Management
      • Plant Maintenance
      • Process Plant Reliability Engineering
      • ReliabilityXperience
      • RCM Blitz®
      • Rob’s Reliability Project
      • The Intelligent Transformer Blog
    • on Product Reliability
      • Accelerated Reliability
      • Achieving the Benefits of Reliability
      • Apex Ridge
      • Metals Engineering and Product Reliability
      • Musings on Reliability and Maintenance Topics
      • Product Validation
      • Reliability Engineering Insights
      • Reliability in Emerging Technology
    • on Risk & Safety
      • CERM® Risk Insights
      • Equipment Risk and Reliability in Downhole Applications
      • Operational Risk Process Safety
    • on Systems Thinking
      • Communicating with FINESSE
      • The RCA
    • on Tools & Techniques
      • Big Data & Analytics
      • Experimental Design for NPD
      • Innovative Thinking in Reliability and Durability
      • Inside and Beyond HALT
      • Inside FMEA
      • Integral Concepts
      • Learning from Failures
      • Progress in Field Reliability?
      • Reliability Engineering Using Python
      • Reliability Reflections
      • Testing 1 2 3
      • The Manufacturing Academy
  • eBooks
  • Resources
    • Accendo Authors
    • FMEA Resources
    • Feed Forward Publications
    • Openings
    • Books
    • Webinars
    • Journals
    • Higher Education
    • Podcasts
  • Courses
    • 14 Ways to Acquire Reliability Engineering Knowledge
    • Reliability Analysis Methods online course
    • Measurement System Assessment
    • SPC-Process Capability Course
    • Design of Experiments
    • Foundations of RCM online course
    • Quality during Design Journey
    • Reliability Engineering Statistics
    • Quality Engineering Statistics
    • An Introduction to Reliability Engineering
    • An Introduction to Quality Engineering
    • Process Capability Analysis course
    • Root Cause Analysis and the 8D Corrective Action Process course
    • Return on Investment online course
    • CRE Preparation Online Course
    • Quondam Courses
  • Webinars
    • Upcoming Live Events
  • Calendar
    • Call for Papers Listing
    • Upcoming Webinars
    • Webinar Calendar
  • Login
    • Member Home

by Sanjeev Saraf Leave a Comment

OSHA Chemical NEP

OSHA Chemical NEP

On July 27, 2009 OSHA launched its National Emphasis Program (NEP) targeted at chemical facilities. The NEP will operate as a one-year pilot program during which OSHA will conduct planned inspections of chemical facilities.

Which Chemical Facilities Will Be Reviewed? 

The Chemical NEP will focus on facilities in the following regions:

  • Regions I: Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont
  • Region VII: Iowa, Kansas, Missouri, and Nebraska; and
  • Region X: Alaska, Washington, Oregon, and Idaho

The facilities selected for planned inspections will be a sub-set of the following:

  • OSHA PSM facilities that are covered by EPA’s Risk Management Program (RMP) as Tier 3 sites;
  • Explosive manufacturers; and
  • Facilities that have been previously cited for PSM violations (IMIS Database or based on area office knowledge )

The master list of facilities created using the above criteria will be sub-divided into three categories:

  • Facilities likely to have ammonia used for refrigeration as the only Highly Hazardous Chemical (HHC)
  • Facilities likely to have chlorine used for water treatment as the only HHC; and
  • Facilities likely to have both ammonia and chlorine, ammonia or chlorine used for other than refrigeration or water treatment, or HHCs other than ammonia or chlorine.

What Does OSHA Chemical NEP Inspection Involve?

OSHA Chemical NEP inspections will be staffed by at least one “Level 1” qualified Compliance and Safety Health Officer (CSHO).  Each inspection is expected to have one week of on-site data gathering stage followed by 6-8 weeks of review. Each on-site inspection will begin with a kick-off conference. During the initial meetings, CSHO will ask management representatives to provide an overview of the process, worst case catastrophic scenarios and controls in place to prevent them.

Documents Requested

Following is a list of documents that will be requested at the beginning of the inspection:

  • All contract employee injury and illness logs as required by 1910.119(h)(2)(vi)
  • List of all PSM-covered process/units in the complex
  • A list of all units and the maximum intended inventories of all chemicals (in pounds) in each of the listed units
  • A summary description of the facility’s PSM program
  • Unit process flow diagrams
  • Piping and instrumentation diagrams (P&IDs) including legends
  • Unit Plot plans
  • Unit Electrical classification diagrams
  • Process narrative descriptions
  • Descriptions of safety systems (e.g. interlocks, detection or suppression systems)
  • Design codes and standards employed for process/equipment in the Selected Unit (s)
  • A list of all employees (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)
  • The initial process hazard analysis(PHA) and the most recent “update/”redo” or revalidation for 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.

Dynamic Questions – Who is the Weakest Link?

To conduct inspection OSHA will create a dynamic list of questions – these questions will not be disclosed publicly and will be changed periodically.The dynamic list of questions will be created in five broad categories:

  1. PSM General (applicable to all processes)
  2. Ammonia Refrigeration
  3. Water and/or wastewater treatment
  4. Storage
  5. Chemical processing

During each inspection approximately 15 questions will be drawn from the applicable dynamic list for each evaluation of a selected unit – ten questions from the applicable chemical process dynamic list and five questions from the PSM general dynamic list.

For further details, read the notice from OSHA – PSM Covered Chemical Facilities National Emphasis Program

Filed Under: Articles, on Risk & Safety, Operational Risk Process Safety

« So how Should I use the SAP-PM Breakdown Indicator?
Are your Asset Management efforts worth your TIME? »

Leave a Reply Cancel reply

Your email address will not be published. Required fields are marked *

Photo of Sanjeev SarafArticles by Sanjeev Saraf
in the Operational Risk, Process Safety article series

Join Accendo

Receive information and updates about articles and many other resources offered by Accendo Reliability by becoming a member.

It’s free and only takes a minute.

Join Today

Recent Posts

  • What is the Difference Between Quality Assurance and Quality Control?
  • Covariance of the Kaplan-Meier Estimators?
  • Use Of RFID In Process Safety: Track Hazardous Chemicals And Track Personnel
  • How to Reduce Maintenance Cost The Right Way
  • Significance Over Success. Innovation Over Change. Anticipation Over Agility

© 2023 FMS Reliability · Privacy Policy · Terms of Service · Cookies Policy

This site uses cookies to give you a better experience, analyze site traffic, and gain insight to products or offers that may interest you. By continuing, you consent to the use of cookies. Learn how we use cookies, how they work, and how to set your browser preferences by reading our Cookies Policy.