PSM National Emphasis Program for Chemical Facilities(NEP)

1
PSM National Emphasis Program for Chemical
Facilities(NEP)

• Columbia Colstor, Inc.

2
HISTORY OF Process Safety Management (PSM)

• OSHA developed the PSM standard in 1992 following
  a number of catastrophic incidents at refinery
  and chemical facilities.

3
HISTORY OF Process Safety Management (PSM)

• The standard is intended to prevent or minimize
  the consequences of a catastrophic release of
  toxic, reactive, flammable or explosive highly
  hazardous chemicals.

4
NATIONAL EMPHASIS PROGRAM (NEP)

• The NEP establishes an inspection program to
  ensure compliance with the Process Safety
  Management Program.

5
NATIONAL EMPHASIS PROGRAM (NEP)

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

6
NATIONAL EMPHASIS PROGRAM (NEP)

• We are in Region X and are subject to programmed
  and unprogrammed inspections. After one year,
  OSHA will evaluate the NEP and consider renewal
  and expansion of the program.

7
NATIONAL EMPHASIS PROGRAM (NEP)

• Through NEPs, OSHA has identified industries or
  hazards deserving priority attention from its
  national, regional and area offices as well as
  states that choose to implement similar programs.

8
NATIONAL EMPHASIS PROGRAM (NEP)

• Facilities that may be subject to programmed
  (i.e., planned) inspections will be identified
  through the coordinated development of a master
  list

9
NATIONAL EMPHASIS PROGRAM (NEP)

• The list will target the following facilities
• OSHA PSM facilities that are covered by EPAs
  Risk Management Program as RMP Program 3 sites

10
THE TARGETED LIST CONT.

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

11
THE TARGETED LIST CONT.

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

12
THE TARGETED LIST CONT.

• 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

13
THE TARGETED LIST CONT.

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

14
THE TARGETED LIST CONT.

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

15
THE TARGETED LIST CONT.

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

16
FIVE SUBSTANTIVE CATAGORIES

• PSM general
• Ammonia Refrigeration
• Water and/or wastewater treatment
• Storage and
• Chemical processing

17
INSPECTION PROCEDURES

• Each inspection will consist of
• An opening conference.
• A facility-led overview of the sites PSM
  programs.
• An initial walkaround.

18
INSPECTION PROCEDURES

1. A compliance evaluation of a selected PSM-covered
   unit within the facility.
2. An inspection of contractors working on or
   adjacent to the selected unit and

19
INSPECTION PROCEDURES

• Issuance of citations for any alleged PSM
  violations.
• Approx. 15 questions will be drawn from the
  applicable dynamic list for each evaluation of a
  selected unit.

20
INSPECTION PROCEDURES

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

21
CONCLUSION

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

22
CONCLUSION

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

23

• DO YOU?

24

• Have any questions for me?