psm national emphasis program for chemical facilities(nep) columbia colstor, inc

PSM National Emphasis PSM National Emphasis Program for Chemical Program for Chemical

Facilities(NEP)Facilities(NEP)

Columbia Colstor, Inc. Columbia Colstor, Inc.

HISTORY OF Process Safety HISTORY OF Process Safety Management (PSM)Management (PSM)

OSHA developed the OSHA developed the PSM standard in 1992 PSM standard in 1992 following a number of following a number of

catastrophic incidents at catastrophic incidents at refinery and chemical refinery and chemical

facilities.facilities.

HISTORY OF Process Safety HISTORY OF Process Safety Management (PSM)Management (PSM)

The standard is intended The standard is intended to prevent or minimize the to prevent or minimize the

consequences of a consequences of a catastrophic release of catastrophic release of

toxic, reactive, flammable toxic, reactive, flammable or explosive highly or explosive highly

hazardous chemicals.hazardous chemicals.

NATIONAL EMPHASIS NATIONAL EMPHASIS PROGRAM (NEP)PROGRAM (NEP)

The NEP establishes an The NEP establishes an inspection program to inspection program to

ensure compliance with ensure compliance with the Process Safety the Process Safety

Management Program.Management Program.


It is a one-year pilot program It is a one-year pilot program with programmed inspections with programmed inspections targeting Regions I, VII, and targeting Regions I, VII, and X, and with unprogrammed X, and with unprogrammed inspections in all regions.inspections in all regions.


We are in Region X and are We are in Region X and are subject to programmed and subject to programmed and unprogrammed inspections. unprogrammed inspections.

After one year, OSHA will After one year, OSHA will evaluate the NEP and evaluate the NEP and consider renewal and consider renewal and

expansion of the program.expansion of the program.


Through NEPs, OSHA has Through NEPs, OSHA has identified industries or identified industries or

hazards deserving priority hazards deserving priority attention from its national, attention from its national,

regional and area offices as regional and area offices as well as states that choose to well as states that choose to implement similar programs.implement similar programs.


Facilities that may be subject Facilities that may be subject to programmed (i.e., planned) to programmed (i.e., planned) inspections will be identified inspections will be identified

through the coordinated through the coordinated development of a “master list”development of a “master list”


The list will target the The list will target the following facilities:following facilities:

•OSHA PSM facilities that are OSHA PSM facilities that are covered by EPA’s Risk covered by EPA’s Risk Management Program as Management Program as RMP Program 3 sites;RMP Program 3 sites;

THE TARGETED LIST CONT.THE TARGETED LIST CONT.

•Explosive Manufacturers; Explosive Manufacturers; andand•Facilities that have been Facilities that have been previously cited for PSM previously cited for PSM violations.violations.


Facilities identified in each Facilities identified in each master list will be divided into master list will be divided into three catagories:three catagories:1.1.Facilities likely to have Facilities likely to have ammonia used for ammonia used for refrigeration as the only refrigeration as the only Highly Hazardous Chemical Highly Hazardous Chemical (HHC);(HHC);


2.2. Facilities likely to have Facilities likely to have chlorine used for water chlorine used for water treatment as the only treatment as the only HHC; andHHC; and

3.3. Facilities likely to have Facilities likely to have both ammonia and both ammonia and chlorine, ammonia or chlorine, ammonia or chlorine used for otherchlorine used for other


3.3. Cont. than refrigeration or Cont. than refrigeration or water treatment, or HHCs water treatment, or HHCs other than ammonia or other than ammonia or chlorine. Facilities that chlorine. Facilities that are participants in OSHA are participants in OSHA VPP or Safety and Health VPP or Safety and Health Achievement Recognition Achievement Recognition Program, as well as Program, as well as


3.3. Cont. facilities that have Cont. facilities that have received a received a comprehensive PSM comprehensive PSM inspection within the inspection within the previous two years, will previous two years, will not be included in the not be included in the national list.national list.


They will target facilities They will target facilities having received a complaint having received a complaint or referral or that have had a or referral or that have had a catastrophic incident. Some catastrophic incident. Some facilites may be selected for facilites may be selected for inspection pursuant to the inspection pursuant to the current Site-Specific current Site-Specific Targeting Plan.Targeting Plan.

FIVE SUBSTANTIVE FIVE SUBSTANTIVE CATAGORIESCATAGORIES

1.1. PSM generalPSM general2.2. Ammonia RefrigerationAmmonia Refrigeration3.3. Water and/or wastewater Water and/or wastewater

treatmenttreatment4.4. Storage; andStorage; and5.5. Chemical processingChemical processing

INSPECTION PROCEDURESINSPECTION PROCEDURES

Each inspection will consist Each inspection will consist of:of:1.1.An opening conference.An opening conference.2.2.A facility-led overview of the A facility-led overview of the site’s PSM programs.site’s PSM programs.3.3.An initial walkaround.An initial walkaround.


4.4. A compliance evaluation A compliance evaluation of a selected PSM-of a selected PSM-covered unit within the covered unit within the facility.facility.

5.5. An inspection of An inspection of contractors working on or contractors working on or adjacent to the selected adjacent to the selected unit; andunit; and


6.6. Issuance of citations for Issuance of citations for any alleged PSM any alleged PSM violations.violations.

Approx. 15 questions will be Approx. 15 questions will be drawn from the applicable drawn from the applicable dynamic list for each dynamic list for each evaluation of a selected evaluation of a selected unit.unit.

INSPECTION PROCEDURESINSPECTION PROCEDURESIf an inspection reveals If an inspection reveals deficiencies outside of the deficiencies outside of the dynamic list questions, the dynamic list questions, the scope of the inspection may scope of the inspection may be expanded. There may be be expanded. There may be citations for hazardous citations for hazardous conditions or violations conditions or violations regardless if the are regardless if the are addressed by the dynamic addressed by the dynamic list.list.

CONCLUSIONCONCLUSIONBe prepared there could be Be prepared there could be an inspection at your facility an inspection at your facility at any time, if you fall under at any time, if you fall under the PSM/RMP program. the PSM/RMP program. Make sure all your ducks are Make sure all your ducks are in a row. Review every in a row. Review every aspect of your program, aspect of your program, discuss it with employees and discuss it with employees and be ready on a moments be ready on a moments notice.notice.

CONCLUSIONCONCLUSIONWe have 5 facilities that fall We have 5 facilities that fall under PSM because of under PSM because of ammonia, and because we ammonia, and because we have received a PSM have received a PSM violation, I think I am on violation, I think I am on someone’s list. I hope I am someone’s list. I hope I am ready. Preparing this ready. Preparing this presentation has given me a presentation has given me a list of things I need to do. list of things I need to do.

DO YOU?DO YOU?

Have any Have any questions for questions for

me?me?

psm national emphasis program for chemical facilities(nep) columbia colstor, inc

Documents

inspection program

master list slide

psm national emphasis

national list

targeted list

sites osha psm facilities

psmrmp program

chemical processing