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OSHA Publishes Chemicals NEP |
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The PSM Covered Chemical Facilities National Emphasis Program [OSHA Directive #09-06 (CPL 02)] was published on July 27, 2009 (http://www.osha.gov/OshDoc/Directive_pdf/CPL_02_09-06.pdf). The directive announces a one-year OSHA NEP for Programmed Inspections of targeted chemical facilities covered by PSM/RMP in Regions I, VII, and X known to OSHA as having a risk of catastrophic releases of HHCs. Facilities having ammonia and/or chlorine are most vulnerable and on OSHA's initial “target list” of facilities to be inspected in this pilot program.
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OSHA intends to do 5-10 programmed inspections per Area Office per year, not just 5-10 per Region. When this NEP expands from just being a pilot program to being a full national program, this “quota” approach per Area Office is likely to be increased. Therefore, it is best to start preparing in advance.
Based on PSRG knowledge and experience with NEP, OSHA will typically arrive to your Site unannounced and request a list of documents similar to the list from the Petroleum Refinery Process Safety Management National Emphasis Program (OSHA Directive #CPL 03-00-004). Note that not all of the documents requested by OSHA may be explicitly required by 29CFR1910.119, but PSRG recommends that you assess what you have and don't have in advance and be ready to respond appropriately when OSHA requests the document.
Having a good PSM program in place is considered to be the best preparedness for a Chemical NEP inspection. However, OSHA has taken steps in the Chemical NEP to ensure that you can't just "prepare for the test" Should you happen to be inspected, it is highly unlikely that you can avoid citations, but, by critiquing facility PSM/RMP documentation and implementation in advance and developing a plan on "How to Prepare for an OSHA NEP Inspection", you should definitely be able to minimize them.
If you would like to learn more about the Chemical NEP and how PSRG can help you to start preparing for a Chemicals NEP inspection, please do not hesitate to contact us at 1-800-250-8511 or via email:
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