osha’s new chemical nep: how to make the grade and earn extra credit

CEP October 2012 www.aiche.org/cep 27

Safety

The U.S. Occupational Safety and Health Administra-tion (OSHA) pursues its overall objective of ensur-ing the health and safety of American workers in a

variety of ways. Some of its enforcement efforts are based on special emphasis programs (SEPs), which focus atten-tion on industries where high injury or illness rates are likely to occur, as well as those industries where there may be inherent exposures to health hazards. One type of SEP is a national emphasis program (NEP). OSHAinitiatedthepetroleumrefineryprocesssafetymanagement(PSM)nationalemphasisprogram(refineryNEP)in2007followingtheBPTexasCityrefineryexplo-sion to evaluate the level of implementation of existing PSMprogramswithintherefiningindustry(1). These inspections were very labor-intensive, requiring approxi-mately 1,000 man-hours per inspection, compared to the 25 man-hours typically needed for routine OSHA inspections. TherefineryNEPinspectionsfoundcompliancewiththePSM standard (2)throughouttherefiningindustrytobeextremely inconsistent (3). Before implementing an SEP, OSHA sometimes creates apilotprogramforinspectorstofine-tunetheirapproachtotheSEP,definetheefficacyofanuntriedcomplianceprocedure, or determine the true extent of potential hazards inaparticularfield.Thefinalprogramtypicallyhasthesamebasicformatasthepilotprogram,sometimeswithmodifica-tions based on the lessons learned from the pilot (4). With the introduction of the pilot PSM-covered chemi-cal facilities NEP, or chemical NEP, OSHA shifted its focus fromrefineriestoothertypesofPSM-coveredfacilities.The

pilot was limited to OSHA Region 1 (CT, MA, ME, NH, RI, VT), Region 7 (IA, KS, MO, NE), and Region 10 (AK, ID, OR, WA), and was intended to be less comprehensive and lessresource-intensivethanitsrefinerypredecessor. Many of the safety-related issues found during the pilot of the chemical NEP were the same as those found during therefineryNEP.Onestrikingsimilarity:EmployersinbothrefineryandchemicalfacilitiesmayhaveextensivewrittenPSM programs, but implementation of these programs is oftenincompleteorotherwiseinsufficient(5). On Nov. 30, 2011, OSHA announced that the pilot chem-ical NEP would be expanded into a formal NEP covering all OSHA regions of the United States (6). This new chemical NEPtookeffectimmediately,andincludesseveralmodifica-tions based on the experience gained from the pilot program. To reach as many facilities as possible, OSHA intends to complete more, but shorter and less elaborate, inspections thanintherefineryandpilotchemicalNEPprograms. The chemical NEP currently has no expiration date, so chances are good that eventually OSHA inspectors will visit your facility. This article gives an overview of the chemical NEP, outlines what to expect during an inspection, and pro-vides tips that will help your facility to proactively — rather than reactively — address any PSM issues.

The basics of the chemical NEP OSHA performs two main types of inspections — unpro-grammed and programmed; related inspections can be included in either process (Table 1). Under the chemical NEP, programmed inspections of

The Occupational Safety and Health Administration evaluates chemical facilities’ process safety management

systems through a new national emphasis program. Follow these tips to reduce your risk of receiving citations,

streamline the inspection process, and pave the way for future excellence.

Henry Ozog Heather R. ForgioneioMosaic Corp.

OSHA’s New Chemical NEP: How to Make the Grade and

Earn Extra Credit

Copyright © 2012 American Institute of Chemical Engineers (AIChE)

28 www.aiche.org/cep October 2012 CEP

Safety

facilities within each OSHA region are chosen at random from two lists. These lists are compiled from facilities that are known to manufacture explosives; listed EPA Program 3 Risk Management Plan (RMP) facilities (Table 2); the OSHA Integrated Management Information System (IMIS) data-base of facilities with previous PSM citations; and facilities known to have processes covered by the PSM standard. As with other OSHA programs, sites with an approved Vol-untary Protection Program (VPP) (see sidebar) or facilities participating in the Safety and Health Achievement Recogni-tion Program (SHARP) (see sidebar) are removed from the list of programmed inspection sites (7). In selecting the facilities to be inspected, OSHA attempts to assure that all hazardous processes are repre-

sented. Although the pilot chemical NEP focused mainly on ammonia and chlorine, it also included any other highly hazardous chemicals (HHCs) at the inspected facilities. Based on the results of the pilot program, ammonia refrig-erationfacilitiesweregiventhehighestpriorityinthefinalNEP. Approximately 25% of the programmed inspections will be at facilities in which the only HHC is likely to be ammonia used for refrigeration purposes (Category 1); 75% of the inspections will be at facilities that have ammonia used for processes other than refrigeration or HHCs other than ammonia (Category 2). In regions where this break-downdoesnotreflectthetruedistributionofCategory1and Category 2 facilities, the ratio may be adjusted (8). Inspectors will arrive onsite, prepared to thoroughly review every element included in the entire PSM program. Although they are there to perform an inspection according to the chemical NEP, if they notice something that could be an issue based on another OSHA standard, they have the freedom to issue a citation for that as well. If an inspection at one company facility results in citations, OSHA is likely to move other facilities within that company to a higher priority on its inspection agenda. As long as a facility has one or more PSM-covered processes,anyincidentsthereorcomplaintsfiledaboutitcan result in an NEP-based inspection. The complaints do not have to be related to PSM. Visits initiated under such cir-cumstances are considered unprogrammed inspections and are performed at the discretion of the director with respon-sibility for that regional area. VPP and SHARP facilities are not exempt from potential unprogrammed inspections initiated under the chemical NEP. It is mandatory that states participate in this directive,

Table 1. OSHA conducts inspections in response to incidents and complaints, as well as based on neutral selection criteria.

Type of Inspection Who It Targets For Example …

Unprogrammed Inspections conducted as the direct result of an accident report, a complaint, or a referral. Includes follow-up inspections. Applies to single-employer or multi-employer sites. May include multiple employers at the site if they are directly involved in the reason for the inspection.

A worker fatality at a multi-employer job site is reported, and OSHA arrives to perform an inspection of all employers who may have been directly involved in the incident.

Unprogrammed Related

Inspections of additional employers on a multi- employer work site who were not involved in the issues that brought about the unprogrammed inspection.

Another employer who is installing equipment at the multi-employer work site is inspected, although it was in no way involved in the fatality.

Programmed Inspections that are based strictly on neutral selection criteria according to current emphasis programs. Applies to single-employer or multi-employer sites.

A facility with no previous OSHA record of injuries or citations is included on a list of scheduled inspections because it meets the basic qualifications for the chemical NEP.

Programmed Related Inspections of additional employers on a multi- employer work site that were not identified in the selection criteria for the programmed inspection.

A PSM-covered employer is working on a multi- employer site. Another employer at this work site is inspected even though its work does not involve any PSM-covered processes.

Table 2. Any facility that processes, handles, produces, distributes or stores certain toxic or flammable chemicals is required to submit a Risk Management Plan to the EPA.

Program 1 Processes

No accidental releases resulting in offsite impacts within five years of RMP submittal

No public receptors in worst-case scenario zone

Emergency response procedures coordinated with local emergency organizations

Program 2 Processes

Not eligible for Program 1, not subject to Program 3

Program 3 Processes

Not eligible for Program 1

Subject to OSHA process safety management standard OR In North American Industry Classification System (NAICS) Code 32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211, 325311 or 32532



which was not the case with the pilot program. A state may opt out only if it effectively demonstrates that it already has an existing program that meets or exceeds the scope of the OSHA chemical NEP directive.

Preparation strategies While every company faces unique challenges, there are strategies that any facility can implement to better prepare for an NEP inspection. To provide a solid foundation for suc-cessfullynavigatingtheexperience: •developamethodforhandlinganinspection •determinethepersonnelinvolvedandtheirresponsibilities •ensurethatallrecordsarecompleteandwellorganized •formulateaplanforhowtodocumentproceedings •establishastrategyforpromptlyrespondingtoanynegativefindings. Above all, if your facility is chosen as an inspection site for the chemical NEP, treat your inspectors with courtesy and tact. Be cooperative and ready to provide any informa-tion they request. Thefirststepindevelopinganoverallapproachtoorganizing your documentation is to methodically review the most recent PSM compliance audit for the facility. Any action items cited during the audit should have been addressed, or there must be thorough tracking of the correc-tive measures currently underway, either of which should be fully documented. Next, systematically review the items listed in the check-list on p. 30. This checklist is not intended to be an exhaus-

tive resource to meet the needs of every situation; it does, however, provide a thorough foundation on which to base your preparation tactics. For each category on the checklist, it is vital that docu-mentation of procedures is complete, up-to-date, easily understood, and readily accessible to company personnel andOSHAinspectorsatanytime.Youshouldfeelconfidentthatinspectorswillfindthatthisdocumentationisproperlymanaged,regularlyreviewed,andfiledcorrectly. The following sections, gleaned directly from the NEP directive (6), outline what you can expect during each of the ten sections of the inspection. Once you are familiar with what will be expected of you, developing a strategy to prepare your team should come more easily.

Step 1: The opening conference The opening conference is an opportunity for inspectors to become familiar with the facility and its daily operations. Include the PSM program expert in this initial conference and ensure that he or she is comfortable explaining the program. Provide an overview of the processes and units atthefacility,includingprocessflowdiagrams(PFDs)thatidentifythechemicalsandprocessesinvolved.Brieflydescribe emergency alarms and response procedures, as well as worst-case release scenarios and any controls currently in place to prevent or mitigate them. During this step, OSHA evaluates the nature of the facility’s PSM-covered processes to determine which questions to ask later. TIP: Once the plant’s documentation and procedures have been reviewed, even if your facility has not been noti-

Voluntary Protection Program (VPP) What it is The VPP is a voluntary program through which OSHA can officially recognize companies that have already made extraordinary efforts toward improving occupational safety and health. VPP facilities are exempt from programmed OSHA inspections, although they are still subject to unpro-grammed inspections.

How to participate A facility must fill out an application for review. A meticulous onsite assessment will be completed by an OSHA team of health and safety experts. Approved sites will be categorized as follows: Star (excellent hazard prevention); Merit (good safety and health management systems requiring some additional improvements); and Demonstration (effective safety systems, but which meet different requirements than the current VPP).

For more information Go to www.OSHA.gov and search for “VPP.” You will get a list of links with information on the elements of the program, the application process, potential interview questions, etc.

Safety and Health Achievement Recognition Program (SHARP)

What it is This program was initiated to recognize small businesses that are operating with exceptional safety and health manage-ment systems in place. SHARP facilities are exempt from programmed OSHA inspections, although they are still sub-ject to unprogrammed inspections.

How to participate A business must request a comprehensive consultation visit from the state’s On-site Consultation office. Employees must be involved in the consultation process, and all hazards iden-tified by the consultant must be addressed. Small businesses that do not fully meet the conditions of the SHARP mandate may be approved for pre-SHARP status.

For more information Go to www.OSHA.gov and search for “SHARP.” You will get a list of links with information on how to contact the On-site Consultation office in your state, documentation require-ments to meet SHARP requirements, the benefits of being a SHARP site, etc.



Safety

OSHA Chemical NEP Inspection Preparation ChecklistAdditional action is recommended for any “No” answers

Compliance Category and PSM Element* Issue Yes No

Mechanical Integrity Program

(Section j)

Are written procedures based on Recognized and Generally Accepted Good Engineering Practices (RAGAGEPs), and are they available for inspectors?

Are regular inspections performed, and are they scheduled in keeping with RAGAGEPs standards?

Have deficiencies in equipment been addressed?

Process Safety Information (PSI)

(Section d)

Are piping and instrumentation diagrams updated to reflect the current conditions onsite?

Are relief-system design analyses properly documented, and do they take reactivity into consideration?

Is there documentation to verify that equipment meets the standards of RAGAGEPs for each process?

Have all chemical reactivity hazards been identified, evaluated, and documented?

Is process safety information (PSI) properly managed, filed correctly, and accessible?

Electrical Classification

(Section d)

Has the OSHA standard covering electrical equipment (29 CFR 1910.302–308) been reviewed?

Does electrical equipment, particularly in hazardous areas, meet OSHA electrical standards?

Are electrical classifications documented and well understood by personnel?

Prior Process Hazard Analysis (PHA) Results

(Section e)

Was the five-year revalidation of the PHA performed on schedule?

Are facility siting and human factors included, and do they comply with current design standards?

Have all action items been closed?

Have closed action items, as well as any ongoing corrective measures underway, been thoroughly documented?

Operating Procedures

(Section f)

Is each phase of operation detailed in the documentation?

Are temporary operations included in the procedures?

Do the details of emergency shutdown procedures include when they are to be initiated and who is responsible for each task?

Facility Safe Work Practices

(Section f)

Is documentation of this program up to date and complete?

Are practices used consistently by personnel and contractors?

Use of Personal Protective Equipment (PPE)

(Section f)

Are personal protective equipment (PPE) procedures and requirements fully documented?

Are training records complete and readily accessible?

Is there documentation to demonstrate that employees and contractors are correctly and adequately following the procedures?

Management of Change Procedures

(Section l)

Are management of change (MOC) procedures documented?

Are written procedures up to date and being implemented properly?

Employee Participation Plan

(Section c)

Is there a written employee participation plan regarding PSM?

Is documentation of this plan complete and readily available for inspectors?

Incident Investigations

(Section m)

Have investigations been performed correctly and in a timely manner?

Have resulting action items been addressed, and is there documentation to that effect?

* OSHA Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119



fiedofanupcominginspection,performatrialrunoftheopening conference to prepare the PSM manager for the possibility of an inspection. Although it could be months or years away, requiring personnel to prepare notes and presentations as if the meeting were a certainty can go a long waytowardboostingconfidenceandproficiency.Itwillalsoprovide the PSM manager with a template that should be fairly simple to update as necessary in the future. If your facility is chosen for an inspection, make sure a representative of the company is with the inspector(s) at all times from this point forward to answer questions and to verify what information and documentation the inspection team received. You need to know what they know.

Step 2: Documentation to have ready Table 3 lists the types of documentation that need to be updated and ready for viewing by OSHA inspectors. Such documentsareoftenkeptonfileinPSM-coveredfacili-ties, and even though the PSM standard does not require an employer to retain all of these records, OSHA representa-tives may request any or all of them during the inspection. TIP: Make sure that all PSM-covered chemicals handled onsite are listed in the PSM Program Manual, even if they are exempt. Thoroughly document the rationale for any exemptions of chemicals. Perform a detailed review of all of the documents on this list. Ensure that the latest revi-sion of each document is available, and that older versions are archived or clearly separated so you don’t pull up an outdated version of a document during the inspection. Avoid the anxiety of rushing to locate the correct version of an item and getting your inspection off to a bad start.

Step 3: Presentations to prepare Havebriefpresentationsreadyonthefollowingtopics: •overviewofthePSMprogramandhowitisimplemented •personnelresponsibleforeachPSMelement

•descriptionsofcompliancedocumentscurrentlyinuseat the facility •reviewofthewrittensummarydescriptionofthePSMprogram. TIP: Make these presentations short and to the point. The OSHA inspectors need to review and make sense of numer-ous items during their visit. Lengthy or rambling presenta-tions may cause confusion or generate more questions. Keep it simple.

Step 4: Personal protective equipment and cameras Inspectors will review the facility’s procedures for selecting personal protective equipment (PPE). They will also inquire about the presence and use of any still or video cameras onsite to ensure they are intrinsically safe where necessary. TIP: Inspectors may want to verify that all cellular phones and portable electronic devices in sensitive areas are turned off and that the plant has a training module that covers this safety issue. Preparation for an inspection is a good time to review safety protocol regarding electronic devices with all personnel at the facility. Provide a refresher training course on this topic, or include it regularly in routine safetybriefings(e.g., toolbox chats or tailgate meetings) for applicable units.

Step 5: The walk-around The inspectors will perform a quick walk-around of the facility to get a feel for the units and processes involved. They will be looking for any disparities between what you have just presented to them and what is actually happening inthefield.Thisisanopportunityforthemtotakenoteofany potential hazards, such as leaking equipment, atmo-spheric relief devices, or control room siting issues. Inspec-tors may approach personnel and contractors at any time for inputregardingpotentialPSMdeficiencies. TIP: Prepare your personnel. This does not mean pres-

Table 3. OSHA inspectors are likely to request these documents during a chemical NEP inspection.

From the Facility From the Inspected Unit(s)

Summary description of the facility’s PSM program

List of all PSM-covered processes

Process descriptions (narrative)

Unit process flow diagrams and plot plans

List of maximum intended inventories of chemicals (in pounds) for each unit

List of PSM incident reports organized by unit

OSHA 300 Log of Work-Related Injuries and Illnesses for the previous three years for the employer being inspected and for process-related contractors

Contract employee injury and illness logs

Piping and instrumentation diagrams (P&IDs), including legends

Electrical classification diagrams

Design codes/standards employed for process and equipment

Safe upper and lower operating limits

Descriptions of safety systems (interlocks, suppression systems)

List of all current personnel (name, title, shifts, start date in unit, supervisor)

Initial process hazard analysis (PHA) and most recent revalidation (reports, worksheets, follow-up action schedules, etc.)

All PSM incident reports



Safety

suring them or training them in appropriate responses to questions. It does mean explaining to them the potential for an inspection, and informing them that anyone may be stopped during the course of their work for an impromptu chat. Employees should be open and honest, but stick strictly to the questions being asked.

Step 6: Selecting the unit to inspect At this stage, the OSHA personnel will decide which unit(s) at the facility will be the focus of the inspection. They can select more than one unit if they feel this is warranted by the information they have received or what they have observedthusfar.Manyfactorsareconsideredforeachunit: •thenatureofthechemicalsinvolved •recordsregardingincidentreports,emergencyshut-down history, and compliance audits •unitoperatorandworkerinput •observationsmadeduringthewalk-around •currenthotworkormaintenanceactivities •thenumberofpersonnelandthepresenceofcontractors •theageoftheunit. TIP: You cannot change details such as the age of a unit, what chemicals are in use, or the number of employees required to run a process. You can control — and should be diligent about — the completeness of your records and the quality of work currently being performed in the unit. For instance, have action items been handled and documented? Have incidents been thoroughly investigated? Verify that mechanical integrity documentation is complete and that chemical inventories are consistent with reported maximum intended inventories. Concentrate on what you can correct, not the things that are out of your control.

Step 7: Inspecting contractors Next,theinspectionswitchestoaunit-specificagenda.OSHA will inspect all contractors who are currently work-ing within the targeted unit(s) or adjacent areas. If there are nocontractorswithinthespecifiedunit(s),theinspectorsreserve the right to select another PSM-covered unit and inspect the contractors working there. As mentioned earlier, inspectors may ask for the OSHA Form 300 logs of contrac-tor injuries and illnesses. They may also request an employ-er’s own injury and illness records for any contractors that have performed work onsite. During the walk-around described in Step 5, contractors may be asked for input regarding any potential PSM issues they may have observed. TIP: Double-check your contractor documentation. You needtofeelconfidentthateverycontractorwhoiswork-ing at the facility has been appropriately trained regarding unit-specifichazards,PPE,generalfacilityinformation,safework practices, emergency procedures, and health and safety

policies. Thoroughly check that contractor permits for hot work, lockout/tagout, etc., are properly completed. It is also a good idea to periodically observe contractor work practices and even inquire as to any PSM-related concerns they may have.Thismayenableyoutocorrectanyred-flagitemsbefore they become problematic.

Step 8: Time for questions The inspectors will ask questions that fall into three categories — general PSM information, ammonia refrig-eration, and chemical processing. The actual questions (which are changed periodically and not published outside of OSHA (9)), depend on the types of processes in the chosen unit(s).Questionsarequitespecificandgenerallyrequirea“Yes/No/Not Applicable” response; “No” answers usually result in a citation. If inspectors have concerns that there may be PSM-related compliance issues outside of a chosen unit, they can expand the inspection to include other units after obtaining the area director’s permission. TIP: OSHA is at the facility to check compliance with the PSM Standard, but do not get complacent during your preparation. OSHA inspectors have the ability to issue cita-tions for any concerns that violate any of their directives. During the pilot program, citations referred to more than 60 OSHA standards. Get your ducks in a row now.

Step 9: Reviewing previous PSM citations The inspectors will review any PSM citations within the chosen unit(s) issued during the past six years to determine whether the cited hazards still exist. If a follow-up inspection has occurred since a particular citation was issued, then that citation does not need to be reviewed. TIP: OSHA can issue failure-to-abate citations based on the review of past PSM citations. Take the extra time to ensure that corrective actions for any PSM-related action items from previous inspections have been meticulously documented.

Step 10: Issuing citations Double-check that you have provided the inspectors with all relevant documentation that could impact their decision to issue a citation. There is not much else you can do at this point.Citationsarebasedonthefindingstheinspectorshavegatheredthroughoutthefirstninestepsoftheinspection. TIP: If you have thoroughly and conscientiously pre-pared your personnel and your PSM program for the even-tuality of an OSHA inspection, you have most likely caught some issues and corrected them before OSHA ever appeared at your door. Position yourself and your supervisors to con-sider this as a learning experience rather than an opportunity to punish or criticize. There are opportunities for appeals and future conversations built into the inspection process.



… But I object! Notices regarding citations or proposed penalties are sent tothefacilityviacertifiedmail.Itisimperativethatyoudotwothings: 1. Post each citation in the area where that particular violation was observed. 2. Begin the appeals process. To set the process in motion, contact the area director for your OSHA region and request an informal meeting to dis-cuss the inspection results. He or she is authorized to amend citations and discuss settlement options. The area director must also receive a written notice of contest within 15 days ofthedateyoureceivethecertifiedletter. If, after meeting with the area director, you still want to appeal the citations, the case can be forwarded to the Occupa-tional Safety and Health Review Commission (OSHRC), an independent body that assigns the case to an administrative law judge. Once this judge makes a decision, you can ask for anadditionalreviewofyourcasebytheOSHRC.Thefinalappeal would be to the U.S. Court of Appeals. If the citation has been escalated to this level, you should obtain legal repre-sentation to ensure you receive appropriate guidance.

When “good enough” isn’t — aim for excellence As you prepare for the possibility that your plant might be chosen for a chemical NEP inspection, your philosophy should not be, “Let’s hope we don’t get picked.” Instead, imagineyourfacilityhasalreadybeennotifiedthatyouwillbe inspected, and proceed accordingly. Once you have developed a basic strategy, consider how togetthegreatestpossiblebenefitoutofthetasksyouneedto complete. This is a hidden opportunity — it could be the motivation for your team to strive for PSM excellence, and therebyaccruealloftheresultingbenefits. Review the preparation checklist. Your team should already be working to ensure that the requirements of each category are met. Consider how each of these areas could be improved upon beyond mere compliance. In many cases, going that one step further may not require much more effort. Suppose that temporary operations or emergency shutdown procedures have a minor mention in the operat-ing procedures, or are not included at all. This may be a good time to institute a regular training program on special-ized operating circumstances. Consider initiating a mentor program in which veteran operators regularly train and quiz younger employees about the protocols for atypical operat-ing conditions. Management of change (MOC) procedures typically involve the administration of any physical or procedural changes within the facility. Although not required by OSHA, companies on the leading edge of process safety also apply the MOC process to organizational changes — for example,

broader issues such as reorganization of plant management andpolicyrevisions,ormore-specificissuessuchasperson-nel retirement and changes in a position’s responsibilities. Including organizational change management in your MOC procedures goes beyond what is required for the chemical NEP and is an outstanding addition to an already-compliant PSM program.

Final thoughts With no expiration date yet announced by OSHA, chances are good that your facility will undergo a chemi-cal NEP inspection at some point in the future. The steps involved in preparing for this eventuality provide an oppor-tunity to effect lasting change throughout your organization. Many methods for improving your overall PSM system require minimal effort, although some involve more coordi-nation and commitment from executives. It is essential that all levels of management not only buy into this philosophy, but also effectively sell it to their employees if this atmo-sphere is to endure and thrive. Updating and improving an existing PSM system requires the commitment of resources, and the company can

Literature Cited 1. U.S. Occupational Safety and Health Administration, “Petro-

leumRefineryProcessSafetyManagementNationalEmphasisProgram,” Directive CPL 03-00-004 (effective Jun. 7, 2007).

2. U.S. Occupational Safety and Health Administration, “Process Safety Management of Highly Hazardous Chemicals,” 29 CFR 1910.119, www.osha.gov/STLC/processsafetymanage-ment/index.html.

3. Steinway, D., et al., “Before OSHA Comes Knocking …,” Chem. Eng. Progress, 105 (3), pp. 28–31 (Mar. 2009).

4. U.S. Occupational Safety and Health Administration, “OSHA’s Field Operations Manual (FOM),” Directive CPL 02-00-150 (effective Apr. 22, 2011).

5. U.S. Occupational Safety and Health Administration, “PSM Covered Chemical Facilities National Emphasis Program,” Directive CPL 03-00-014 (effective Nov. 29, 2011).

6. U.S. Occupational Safety and Health Administration, “PSM Covered Chemical Facilities National Emphasis Program,” Directive CPL 02-09-06 (effective July 27, 2009).

7. U.S. Environmental Protection Agency, “RMPs Are on theWay!”EPA550-B99-003,EPAOfficeofSolidWasteandEmergency Response (5104) (Nov. 1999).

8. Marshall, M.,“OSHA’sRefinery&ChemicalNationalEmphasis Programs,” presented at the United Steelworkers 2012 Health, Safety, and Environment Conference, Pittsburgh PA (Mar. 12, 2012).

9. Hager, M.,“OSHARefineryandChemicalNEPFindings,”presented at the Mary Kay O’Connor Process Safety Center International Symposium 2012, Houston, TX (Nov. 9, 2011).

10. Center for Chemical Process Safety, “The Business Case for Process Safety,” 2nd ed., American Institute of Chemical Engineers, New York, NY (2006).



Safety

quickly reap tangible returns on this investment. A vibrant culture of process safety inherently leads to a reduction in the risk of not only major disasters, but also worker injuries, environmental impact, and the costs associated with mitigat-ingtheseissues.Thesereductions,inturn,leadtobenefitslike less time lost investigating incidents, fewer regulatory penalties, lower insurance premiums, and higher productiv-ity. Investors, employees, prospective clients, and the local community will recognize that these enhancements give you a natural advantage over your competitors, improve your reputation within your industry, and ultimately make your company a safer place to work (10). The approaches you implement at your plant must be determined based on your particular facility’s needs and capabilities. Developing an atmosphere of continual improvement—whetherintheoffice,inthefield,orinthecontrol room — is fundamental to the success of your com-pany and to the effective execution of your PSM program. Satisfying the mandates of the OSHA chemical NEP should be your minimum objective. Challenge your company to excel beyond what is expected and become a true industry frontrunner in process safety.

HENRy OzOg is the general partner at ioMosaic Corp. (93 Stiles Rd., Salem, NH 03079; Phone: (603) 893-7009; Email: [email protected]), a provider of safety and risk-management consulting services, training, and software solutions. He is an expert in process safety management (PSM); risk management; process hazard analy-sis (PHA), including hazard and operability (HAZOP) studies, failure mode and effect analysis (FMEA), fault tree analysis (FTA), layer of protection analysis (LOPA), and quantitative risk analysis (QRA); and facility siting. He has audited companywide and plant-level PSM programs relative to regulatory requirements and company standards and has developed implementation plans to achieve compliance. He has helped numerous companies and government agencies identify process risks and implement cost-effective mitigation measures. He teaches courses in these areas. A member of the AIChE, Ozog holds a BS and an MS in chemical engineering, both from the Massachusetts Institute of Technology.

HEaTHER R. FORgIONE was a safety and risk management consultant at ioMosaic Corp. when she wrote this article. There, she focused on pressure-relief and flare systems analysis and PSM auditing in the petrochemical, chemical, and pharmaceutical industries in the U.S. Previously, she worked in environmental, health, and safety, industrial hygiene, and mechanical engineering consulting, and has provided OSHA-required training to clients for a variety of health and safety topics. Forgione is a member of the American Society of Mechanical Engineers and holds a BS in aerospace engineering from Boston Univ. She is now employed as a hazardous materials specialist and project manager at Ransom Environmental Consultants.

Attendees receive CCPS’ Guidelines for Risk Based Process Safety

For more information and to register visitwww.aiche.org/ilt

Your process safety program has to meet OSHA PSM Regulation 29CFR 1910.119 and the EPA Prevention Program requirements. Take this CCPS course and make sure your program meets them.

You’ll leave ready to effectively implement, evaluate and audit an OSHA or EPA process safety management program for your organization.

Meeting in Orlando, FLDecember 5–7, 2012

2013 Dates Also Available

Your PSM Program Meets All Your Internal Requirements.

Does it Meet OSHA’s?This December attend CCPS’ The OSHA Regulatory Approach to Process Safety Management Course and Make Sure.

© 2012 AIChE 7909 • 10.12

CEP


www.aiche.org/ilt

osha’s new chemical nep: how to make the grade and earn extra credit

Documents