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New U.S. Chemical Plant Safety Inspections - Is Your Company Prepared?
9:19 AM MDT | March 28, 2012 | By DOROTHY SHATTER
In response to the tragic BP-Texas City refinery incident of 2005, OSHA initiated the Petroleum Refinery PSM National Emphasis Program (Refinery NEP) which resulted in lengthy and thorough inspections, followed by numerous citations and substantial penalties for many of the facilities. OSHA recently finalized a nation-wide follow-up program—the PSM Covered Chemical Facilities NEP (Chem NEP)—which applies to all other facilities that are subject to OSHA’s PSM Standard (29 CFR 1910.119), including facilities that manufacture explosives. There are, however, important differences between the two NEP programs:
Rather than performing an exhaustive review of a facility’s entire PSM program, the Chem NEP protocol seeks specific documents and information as the basis for performing a quick evaluation of a facility’s PSM program. This evaluation is followed by 10-to-15 undisclosed and periodically changing questions to examine in detail the facility’s PSM compliance status. This streamlined approach means that each Chem NEP inspection will use far fewer OSHA and site resources compared to a typical Refinery NEP inspection. However, Chem NEP inspections also target known compliance “soft spots,” such as actual and “near miss” incident investigation reports, the facility’s PSM compliance audit reports, and previous OSHA PSM citations.
When OSHA inspects a facility, they focus on proper PSM implementation to see if it matches the site’s written PSM policies and procedures. Thus far, about 75% of the Refinery and Chemical NEP citation items have fallen under just four of the PSM elements—Mechanical Integrity, Process Safety Information, Process Hazards Analysis, and Operating Procedures. While many of the citation items are as basic as inaccurate P&IDs or operating procedures that lack required features, others have resulted from expectations that have evolved over the life of OSHA’s PSM Standard. OSHA is looking closely at equipment testing and inspection programs, and perceived gaps in those programs. OSHA citations have clearly targeted facility siting and relief systems stemming from the BP tragedy. Since that incident, new industry facility siting consensus standards have been published for both temporary and permanent structures.
Preparation is the key to handling any government inspection successfully, particularly a Chem NEP inspection by OSHA. Making sure that your facility’s written programs and procedures are in compliance with the PSM Standard is an important starting point. Equally and perhaps more important is making sure that what you have on paper accurately describes how your facility achieves PSM compliance in your plant – and that this matching of PSM documentation and implementation will be reflected in every employee interview conducted by OSHA during the inspection. Good preparation also includes understanding OSHA’s authority as well as your rights as the employer during an inspection, and having a plan in place to manage the OSHA inspection. There are some universal inspection do’s and don’t’s, and you should know them.
To help companies prepare for OSHA inspections, BakerRisk’s experts will provide information on the Chem NEP in a free-to-view webcast hosted by Chemical Week on April 12th at 10:00 AM CDT. BakerRisk’s experts participating in the webcast will provide information about the Chem NEP, including advice about preparing for- and handling- Chem NEP inspections. Free registration to attend the webcast is now available at IHS Chemical Week’s website at http://www.chemweek.com/oshachemicalplantinspection/
By Dorothy Shatter, Principal Consultant, BakerRisk