On July 27, 2009 OSHA published Directive 09-06 (CPL 02), PSM Covered Chemical Facilities National Emphasis Program (NEP). This instruction extends the refinery NEP program to those facilities in the chemical industry that are covered by the PSM Standard. The Chemical NEP will be focused on higher risk chemical facilities and is designed to verify the implementation of process safety programs, rather than confirm the existence of process safety related documentation.
Facilities that manufacture, use, store or distribute toxic or flammable chemicals regulated under 29 CFR 1910.119 Process Safety Management of Highly Hazardous Chemicals may be subject to inspection under the Chemical NEP. While OSHA has not yet published details of these inspections, they have indicated that nearly 8,000 RMP Program 3 facilities may be a main target for selecting sites for implementation.
In addition, OSHA has indicated that additional SICs that are typically covered by PSM but are not necessarily covered by RMP may also be added to the list of facilities targeted for inspection.
AcuTech’s team of consultants provides expert support to achieve your facility process safety requirements. Industry recognizes us as technical leaders in Process Safety regulations, serving as expert witnesses, and Process Safety Auditing as demonstrated by our recent effort in re-writing the Center for Chemical Process Safety “Guidelines for Process Safety Auditing”.
In addition, AcuTech is uniquely qualified to provide auditing services, expert consultation during OSHA inspections and training. Some of our key qualification include:
- Provided PSM and RMP auditing services to a large number of chemical facilities. Additionally, many of our staff members have extensive auditing experience in their backgrounds prior to joining AcuTech.
- AcuTech has delivered training seminars on PSM to Federal US OSHA compliance officers at the OSHA Training Institute and has conducted public training nationwide on PSM and auditing.
- The most significant accident in the recent history of the US was the BP Texas City refinery explosion incident that occurred in November, 2005. In accordance with the Settlement Agreement between OSHA and BP for the Texas City incident, AcuTech was nominated by BP and approved by OSHA to serve as the “PSM Expert” to carry out a comprehensive PSM audit at the Texas City Refinery and perform various other activities aimed at reviewing and evaluating the robustness of PSM and related programs and management systems. AcuTech also performed a PSM audit of BP’s Chemical Plant at Texas City at the same time.
- In conducting PSM compliance audits, AcuTech is familiar with a number of different protocols including the OSHA refinery NEP protocol, OSHA’s CPL 2-2.45A, “Process Safety Management of Highly Hazardous Chemicals – Compliance Guidelines and Enforcement Procedures”; the EPA “Guidance for Auditing Risk Management Plans/Programs Under Clean Air Act Section 112(r)”, state protocols , protocols supplied by our clients, and our own “Continuous Safety Improvement” (CSI) audit approach.
- AcuTech’s PSM audit protocol contains a number of questions that probe beyond strict compliance to determine if the PSM program is really functioning properly. It also performs a thorough review of the PSM applicability of a facility, which is also part of an NEP inspection. Many of these additional audit questions have been included in the about to be published CCPS Guidelines for Auditing Process Safety Management Systems.
- We have provided expert consultation during OSHA Inspections and technical assistance with citation management .
- We provide Process Safety Training, including Best Practices in Process Safety Management, PHA Team Leader, and Auditing for Process Safety and Risk Management. Click HERE to review current training catalog.
AcuTech has a long and successful history as industry advocates supporting strong working relationships with our industry clients as well as with government regulators.