CEP October 2012 www.aiche.

org/cep 27
Safety
T
he U.S. Occupational Safety and Health Administra-
tion (OSHA) pursues its overall objective of ensur-
ing the health and safety of American workers in a
variety of ways. Some of its enforcement efforts are based
on special emphasis programs (SEPs), which focus atten-
tion on industries where high injury or illness rates are likely
to occur, as well as those industries where there may be
inherent exposures to health hazards. One type of SEP is a
national emphasis program (NEP).
OSHA initiated the petroleum refnery process safety
management (PSM) national emphasis program (refnery
NEP) in 2007 following the BP Texas City refnery explo-
sion to evaluate the level of implementation of existing
PSM programs within the refning industry (1). These
inspections were very labor-intensive, requiring approxi-
mately 1,000 man-hours per inspection, compared to the 25
man-hours typically needed for routine OSHA inspections.
The refnery NEP inspections found compliance with the
PSM standard (2) throughout the refning industry to be
extremely inconsistent (3).
Before implementing an SEP, OSHA sometimes creates
a pilot program for inspectors to fne-tune their approach
to the SEP, defne the effcacy of an untried compliance
procedure, or determine the true extent of potential hazards
in a particular feld. The fnal program typically has the same
basic format as the pilot program, sometimes with modifca-
tions based on the lessons learned from the pilot (4).
With the introduction of the pilot PSM-covered chemi-
cal facilities NEP, or chemical NEP, OSHA shifted its focus
from refneries to other types of PSM-covered facilities. The
pilot was limited to OSHA Region 1 (CT, MA, ME, NH, RI,
VT), Region 7 (IA, KS, MO, NE), and Region 10 (AK, ID,
OR, WA), and was intended to be less comprehensive and
less resource-intensive than its refnery predecessor.
Many of the safety-related issues found during the pilot
of the chemical NEP were the same as those found during
the refnery NEP. One striking similarity: Employers in both
refnery and chemical facilities may have extensive written
PSM programs, but implementation of these programs is
often incomplete or otherwise insuffcient (5).
On Nov. 30, 2011, OSHA announced that the pilot chem-
ical NEP would be expanded into a formal NEP covering all
OSHA regions of the United States (6). This new chemical
NEP took effect immediately, and includes several modifca-
tions based on the experience gained from the pilot program.
To reach as many facilities as possible, OSHA intends to
complete more, but shorter and less elaborate, inspections
than in the refnery and pilot chemical NEP programs.
The chemical NEP currently has no expiration date, so
chances are good that eventually OSHA inspectors will visit
your facility. This article gives an overview of the chemical
NEP, outlines what to expect during an inspection, and pro-
vides tips that will help your facility to proactively rather
than reactively address any PSM issues.
The basics of the chemical NEP
OSHA performs two main types of inspections unpro-
grammed and programmed; related inspections can be
included in either process (Table 1).
Under the chemical NEP, programmed inspections of
The Occupational Safety and Health Administration
evaluates chemical facilities process safety management
systems through a new national emphasis program.
Follow these tips to reduce your risk of receiving citations,
streamline the inspection process,
and pave the way for future excellence.
Henry Ozog
Heather R. Forgione
ioMosaic Corp.
OSHAs New Chemical NEP:
How to Make the Grade and
Earn Extra Credit
Copyright 2012 American Institute of Chemical Engineers (AIChE)
28 www.aiche.org/cep October 2012 CEP
Safety
facilities within each OSHA region are chosen at random
from two lists. These lists are compiled from facilities that
are known to manufacture explosives; listed EPA Program 3
Risk Management Plan (RMP) facilities (Table 2); the OSHA
Integrated Management Information System (IMIS) data-
base of facilities with previous PSM citations; and facilities
known to have processes covered by the PSM standard. As
with other OSHA programs, sites with an approved Vol-
untary Protection Program (VPP) (see sidebar) or facilities
participating in the Safety and Health Achievement Recogni-
tion Program (SHARP) (see sidebar) are removed from the
list of programmed inspection sites (7).
In selecting the facilities to be inspected, OSHA
attempts to assure that all hazardous processes are repre-
sented. Although the pilot chemical NEP focused mainly
on ammonia and chlorine, it also included any other highly
hazardous chemicals (HHCs) at the inspected facilities.
Based on the results of the pilot program, ammonia refrig-
eration facilities were given the highest priority in the fnal
NEP. Approximately 25% of the programmed inspections
will be at facilities in which the only HHC is likely to be
ammonia used for refrigeration purposes (Category 1); 75%
of the inspections will be at facilities that have ammonia
used for processes other than refrigeration or HHCs other
than ammonia (Category 2). In regions where this break-
down does not refect the true distribution of Category 1
and Category 2 facilities, the ratio may be adjusted (8).
Inspectors will arrive onsite, prepared to thoroughly
review every element included in the entire PSM program.
Although they are there to perform an inspection according
to the chemical NEP, if they notice something that could be
an issue based on another OSHA standard, they have the
freedom to issue a citation for that as well. If an inspection at
one company facility results in citations, OSHA is likely to
move other facilities within that company to a higher priority
on its inspection agenda.
As long as a facility has one or more PSM-covered
processes, any incidents there or complaints fled about it
can result in an NEP-based inspection. The complaints do
not have to be related to PSM. Visits initiated under such cir-
cumstances are considered unprogrammed inspections and
are performed at the discretion of the director with respon-
sibility for that regional area. VPP and SHARP facilities
are not exempt from potential unprogrammed inspections
initiated under the chemical NEP.
It is mandatory that states participate in this directive,
Table 1. OSHA conducts inspections in response to incidents and complaints, as well as based on neutral selection criteria.
Type of Inspection Who It Targets For Example
Unprogrammed Inspections conducted as the direct result of an
accident report, a complaint, or a referral. Includes
follow-up inspections. Applies to single-employer or
multi-employer sites. May include multiple employers
at the site if they are directly involved in the reason for
the inspection.
A worker fatality at a multi-employer job site is
reported, and OSHA arrives to perform an inspection
of all employers who may have been directly involved
in the incident.
Unprogrammed
Related
Inspections of additional employers on a multi-
employer work site who were not involved in the
issues that brought about the unprogrammed
inspection.
Another employer who is installing equipment at
the multi-employer work site is inspected, although
it was in no way involved in the fatality.
Programmed Inspections that are based strictly on neutral selection
criteria according to current emphasis programs.
Applies to single-employer or multi-employer sites.
A facility with no previous OSHA record of injuries
or citations is included on a list of scheduled
inspections because it meets the basic qualications
for the chemical NEP.
Programmed Related Inspections of additional employers on a multi-
employer work site that were not identied in the
selection criteria for the programmed inspection.
A PSM-covered employer is working on a multi-
employer site. Another employer at this work site
is inspected even though its work does not involve
any PSM-covered processes.
Table 2. Any facility that processes, handles, produces,
distributes or stores certain toxic or ammable chemicals
is required to submit a Risk Management Plan to the EPA.
Program 1
Processes
No accidental releases resulting in offsite impacts
within ve years of RMP submittal
No public receptors in worst-case scenario zone
Emergency response procedures coordinated
with local emergency organizations
Program 2
Processes
Not eligible for Program 1, not subject to
Program 3
Program 3
Processes
Not eligible for Program 1
Subject to OSHA process safety management
standard
OR
In North American Industry Classication System
(NAICS) Code 32211, 32411, 32511, 325181,
325188, 325192, 325199, 325211, 325311 or
32532
Copyright 2012 American Institute of Chemical Engineers (AIChE)
CEP October 2012 www.aiche.org/cep 29
which was not the case with the pilot program. A state may
opt out only if it effectively demonstrates that it already has
an existing program that meets or exceeds the scope of the
OSHA chemical NEP directive.
Preparation strategies
While every company faces unique challenges, there are
strategies that any facility can implement to better prepare
for an NEP inspection. To provide a solid foundation for suc-
cessfully navigating the experience:
develop a method for handling an inspection
determine the personnel involved and their
responsibilities
ensure that all records are complete and well organized
formulate a plan for how to document proceedings
establish a strategy for promptly responding to any
negative fndings.
Above all, if your facility is chosen as an inspection site
for the chemical NEP, treat your inspectors with courtesy
and tact. Be cooperative and ready to provide any informa-
tion they request.
The frst step in developing an overall approach to
organizing your documentation is to methodically review
the most recent PSM compliance audit for the facility.
Any action items cited during the audit should have been
addressed, or there must be thorough tracking of the correc-
tive measures currently underway, either of which should be
fully documented.
Next, systematically review the items listed in the check-
list on p. 30. This checklist is not intended to be an exhaus-
tive resource to meet the needs of every situation; it does,
however, provide a thorough foundation on which to base
your preparation tactics.
For each category on the checklist, it is vital that docu-
mentation of procedures is complete, up-to-date, easily
understood, and readily accessible to company personnel
and OSHA inspectors at any time. You should feel confdent
that inspectors will fnd that this documentation is properly
managed, regularly reviewed, and fled correctly.
The following sections, gleaned directly from the NEP
directive (6), outline what you can expect during each of
the ten sections of the inspection. Once you are familiar
with what will be expected of you, developing a strategy to
prepare your team should come more easily.
Step 1: The opening conference
The opening conference is an opportunity for inspectors
to become familiar with the facility and its daily operations.
Include the PSM program expert in this initial conference
and ensure that he or she is comfortable explaining the
program. Provide an overview of the processes and units
at the facility, including process fow diagrams (PFDs)
that identify the chemicals and processes involved. Briefy
describe emergency alarms and response procedures, as well
as worst-case release scenarios and any controls currently in
place to prevent or mitigate them. During this step, OSHA
evaluates the nature of the facilitys PSM-covered processes
to determine which questions to ask later.
TIP: Once the plants documentation and procedures
have been reviewed, even if your facility has not been noti-
Voluntary Protection Program (VPP)
What it is
The VPP is a voluntary program through which OSHA can
ofcially recognize companies that have already made
extraordinary efforts toward improving occupational safety
and health. VPP facilities are exempt from programmed
OSHA inspections, although they are still subject to unpro-
grammed inspections.
How to participate
A facility must ll out an application for review. A meticulous
onsite assessment will be completed by an OSHA team of
health and safety experts. Approved sites will be categorized
as follows: Star (excellent hazard prevention); Merit (good
safety and health management systems requiring some
additional improvements); and Demonstration (effective
safety systems, but which meet different requirements than
the current VPP).
For more information
Go to www.OSHA.gov and search for VPP. You will get a
list of links with information on the elements of the program,
the application process, potential interview questions, etc.
Safety and Health Achievement
Recognition Program (SHARP)
What it is
This program was initiated to recognize small businesses that
are operating with exceptional safety and health manage-
ment systems in place. SHARP facilities are exempt from
programmed OSHA inspections, although they are still sub-
ject to unprogrammed inspections.
How to participate
A business must request a comprehensive consultation visit
from the states On-site Consultation ofce. Employees must
be involved in the consultation process, and all hazards iden-
tied by the consultant must be addressed. Small businesses
that do not fully meet the conditions of the SHARP mandate
may be approved for pre-SHARP status.
For more information
Go to www.OSHA.gov and search for SHARP. You will get
a list of links with information on how to contact the On-site
Consultation ofce in your state, documentation require-
ments to meet SHARP requirements, the benets of being a
SHARP site, etc.
Copyright 2012 American Institute of Chemical Engineers (AIChE)
30 www.aiche.org/cep October 2012 CEP
Safety
OSHA Chemical NEP Inspection Preparation Checklist
Additional action is recommended for any No answers
Compliance
Category and
PSM Element* Issue Yes No
Mechanical
Integrity Program
(Section j)
Are written procedures based on Recognized and Generally Accepted Good Engineering
Practices (RAGAGEPs), and are they available for inspectors?
Are regular inspections performed, and are they scheduled in keeping with RAGAGEPs
standards?
Have deciencies in equipment been addressed?
Process Safety
Information (PSI)
(Section d)
Are piping and instrumentation diagrams updated to reect the current conditions onsite?
Are relief-system design analyses properly documented, and do they take reactivity into
consideration?
Is there documentation to verify that equipment meets the standards of RAGAGEPs for each
process?
Have all chemical reactivity hazards been identied, evaluated, and documented?
Is process safety information (PSI) properly managed, led correctly, and accessible?
Electrical
Classication
(Section d)
Has the OSHA standard covering electrical equipment (29 CFR 1910.302308) been
reviewed?
Does electrical equipment, particularly in hazardous areas, meet OSHA electrical standards?
Are electrical classications documented and well understood by personnel?
Prior Process
Hazard Analysis
(PHA) Results
(Section e)
Was the ve-year revalidation of the PHA performed on schedule?
Are facility siting and human factors included, and do they comply with current design
standards?
Have all action items been closed?
Have closed action items, as well as any ongoing corrective measures underway, been
thoroughly documented?
Operating
Procedures
(Section f)
Is each phase of operation detailed in the documentation?
Are temporary operations included in the procedures?
Do the details of emergency shutdown procedures include when they are to be initiated and
who is responsible for each task?
Facility Safe Work
Practices
(Section f)
Is documentation of this program up to date and complete?
Are practices used consistently by personnel and contractors?
Use of Personal
Protective Equipment
(PPE)
(Section f)
Are personal protective equipment (PPE) procedures and requirements fully documented?
Are training records complete and readily accessible?
Is there documentation to demonstrate that employees and contractors are correctly and
adequately following the procedures?
Management of
Change Procedures
(Section l)
Are management of change (MOC) procedures documented?
Are written procedures up to date and being implemented properly?
Employee
Participation Plan
(Section c)
Is there a written employee participation plan regarding PSM?
Is documentation of this plan complete and readily available for inspectors?
Incident
Investigations
(Section m)
Have investigations been performed correctly and in a timely manner?
Have resulting action items been addressed, and is there documentation to that effect?
* OSHA Process Safety Management of Highly Hazardous Chemicals, 29 CFR 1910.119
Copyright 2012 American Institute of Chemical Engineers (AIChE)
CEP October 2012 www.aiche.org/cep 31
fed of an upcoming inspection, perform a trial run of the
opening conference to prepare the PSM manager for the
possibility of an inspection. Although it could be months
or years away, requiring personnel to prepare notes and
presentations as if the meeting were a certainty can go a long
way toward boosting confdence and profciency. It will also
provide the PSM manager with a template that should be
fairly simple to update as necessary in the future.
If your facility is chosen for an inspection, make sure a
representative of the company is with the inspector(s) at all
times from this point forward to answer questions and to
verify what information and documentation the inspection
team received. You need to know what they know.
Step 2: Documentation to have ready
Table 3 lists the types of documentation that need to be
updated and ready for viewing by OSHA inspectors. Such
documents are often kept on fle in PSM-covered facili-
ties, and even though the PSM standard does not require an
employer to retain all of these records, OSHA representa-
tives may request any or all of them during the inspection.
TIP: Make sure that all PSM-covered chemicals handled
onsite are listed in the PSM Program Manual, even if they
are exempt. Thoroughly document the rationale for any
exemptions of chemicals. Perform a detailed review of all
of the documents on this list. Ensure that the latest revi-
sion of each document is available, and that older versions
are archived or clearly separated so you dont pull up an
outdated version of a document during the inspection. Avoid
the anxiety of rushing to locate the correct version of an item
and getting your inspection off to a bad start.
Step 3: Presentations to prepare
Have brief presentations ready on the following topics:
overview of the PSM program and how it is
implemented
personnel responsible for each PSM element
descriptions of compliance documents currently in use
at the facility
review of the written summary description of the PSM
program.
TIP: Make these presentations short and to the point. The
OSHA inspectors need to review and make sense of numer-
ous items during their visit. Lengthy or rambling presenta-
tions may cause confusion or generate more questions. Keep
it simple.
Step 4: Personal protective equipment and cameras
Inspectors will review the facilitys procedures for
selecting personal protective equipment (PPE). They will
also inquire about the presence and use of any still or video
cameras onsite to ensure they are intrinsically safe where
necessary.
TIP: Inspectors may want to verify that all cellular
phones and portable electronic devices in sensitive areas
are turned off and that the plant has a training module that
covers this safety issue. Preparation for an inspection is a
good time to review safety protocol regarding electronic
devices with all personnel at the facility. Provide a refresher
training course on this topic, or include it regularly in routine
safety briefngs (e.g., toolbox chats or tailgate meetings) for
applicable units.
Step 5: The walk-around
The inspectors will perform a quick walk-around of the
facility to get a feel for the units and processes involved.
They will be looking for any disparities between what you
have just presented to them and what is actually happening
in the feld. This is an opportunity for them to take note of
any potential hazards, such as leaking equipment, atmo-
spheric relief devices, or control room siting issues. Inspec-
tors may approach personnel and contractors at any time for
input regarding potential PSM defciencies.
TIP: Prepare your personnel. This does not mean pres-
Table 3. OSHA inspectors are likely to request these documents during a chemical NEP inspection.
From the Facility From the Inspected Unit(s)
Summary description of the facilitys PSM program
List of all PSM-covered processes
Process descriptions (narrative)
Unit process ow diagrams and plot plans
List of maximum intended inventories of chemicals (in pounds) for
each unit
List of PSM incident reports organized by unit
OSHA 300 Log of Work-Related Injuries and Illnesses for the
previous three years for the employer being inspected and for
process-related contractors
Contract employee injury and illness logs
Piping and instrumentation diagrams (P&IDs), including legends
Electrical classication diagrams
Design codes/standards employed for process and equipment
Safe upper and lower operating limits
Descriptions of safety systems (interlocks, suppression systems)
List of all current personnel (name, title, shifts, start date in unit,
supervisor)
Initial process hazard analysis (PHA) and most recent revalidation
(reports, worksheets, follow-up action schedules, etc.)
All PSM incident reports
Copyright 2012 American Institute of Chemical Engineers (AIChE)
32 www.aiche.org/cep October 2012 CEP
Safety
suring them or training them in appropriate responses to
questions. It does mean explaining to them the potential
for an inspection, and informing them that anyone may be
stopped during the course of their work for an impromptu
chat. Employees should be open and honest, but stick strictly
to the questions being asked.
Step 6: Selecting the unit to inspect
At this stage, the OSHA personnel will decide which
unit(s) at the facility will be the focus of the inspection. They
can select more than one unit if they feel this is warranted
by the information they have received or what they have
observed thus far. Many factors are considered for each unit:
the nature of the chemicals involved
records regarding incident reports, emergency shut-
down history, and compliance audits
unit operator and worker input
observations made during the walk-around
current hot work or maintenance activities
the number of personnel and the presence of
contractors
the age of the unit.
TIP: You cannot change details such as the age of a unit,
what chemicals are in use, or the number of employees
required to run a process. You can control and should be
diligent about the completeness of your records and the
quality of work currently being performed in the unit. For
instance, have action items been handled and documented?
Have incidents been thoroughly investigated? Verify that
mechanical integrity documentation is complete and that
chemical inventories are consistent with reported maximum
intended inventories. Concentrate on what you can correct,
not the things that are out of your control.
Step 7: Inspecting contractors
Next, the inspection switches to a unit-specifc agenda.
OSHA will inspect all contractors who are currently work-
ing within the targeted unit(s) or adjacent areas. If there are
no contractors within the specifed unit(s), the inspectors
reserve the right to select another PSM-covered unit and
inspect the contractors working there. As mentioned earlier,
inspectors may ask for the OSHA Form 300 logs of contrac-
tor injuries and illnesses. They may also request an employ-
ers own injury and illness records for any contractors
that have performed work onsite. During the walk-around
described in Step 5, contractors may be asked for input
regarding any potential PSM issues they may have observed.
TIP: Double-check your contractor documentation. You
need to feel confdent that every contractor who is work-
ing at the facility has been appropriately trained regarding
unit-specifc hazards, PPE, general facility information, safe
work practices, emergency procedures, and health and safety
policies. Thoroughly check that contractor permits for hot
work, lockout/tagout, etc., are properly completed. It is also
a good idea to periodically observe contractor work practices
and even inquire as to any PSM-related concerns they may
have. This may enable you to correct any red-fag items
before they become problematic.
Step 8: Time for questions
The inspectors will ask questions that fall into three
categories general PSM information, ammonia refrig-
eration, and chemical processing. The actual questions
(which are changed periodically and not published outside of
OSHA (9)), depend on the types of processes in the chosen
unit(s). Questions are quite specifc and generally require a
Yes/No/Not Applicable response; No answers usually
result in a citation. If inspectors have concerns that there
may be PSM-related compliance issues outside of a chosen
unit, they can expand the inspection to include other units
after obtaining the area directors permission.
TIP: OSHA is at the facility to check compliance with
the PSM Standard, but do not get complacent during your
preparation. OSHA inspectors have the ability to issue cita-
tions for any concerns that violate any of their directives.
During the pilot program, citations referred to more than 60
OSHA standards. Get your ducks in a row now.
Step 9: Reviewing previous PSM citations
The inspectors will review any PSM citations within the
chosen unit(s) issued during the past six years to determine
whether the cited hazards still exist. If a follow-up inspection
has occurred since a particular citation was issued, then that
citation does not need to be reviewed.
TIP: OSHA can issue failure-to-abate citations based
on the review of past PSM citations. Take the extra time to
ensure that corrective actions for any PSM-related action
items from previous inspections have been meticulously
documented.
Step 10: Issuing citations
Double-check that you have provided the inspectors with
all relevant documentation that could impact their decision
to issue a citation. There is not much else you can do at this
point. Citations are based on the fndings the inspectors have
gathered throughout the frst nine steps of the inspection.
TIP: If you have thoroughly and conscientiously pre-
pared your personnel and your PSM program for the even-
tuality of an OSHA inspection, you have most likely caught
some issues and corrected them before OSHA ever appeared
at your door. Position yourself and your supervisors to con-
sider this as a learning experience rather than an opportunity
to punish or criticize. There are opportunities for appeals and
future conversations built into the inspection process.
Copyright 2012 American Institute of Chemical Engineers (AIChE)
CEP October 2012 www.aiche.org/cep 33
But I object!
Notices regarding citations or proposed penalties are sent
to the facility via certifed mail. It is imperative that you do
two things:
1. Post each citation in the area where that particular
violation was observed.
2. Begin the appeals process.
To set the process in motion, contact the area director for
your OSHA region and request an informal meeting to dis-
cuss the inspection results. He or she is authorized to amend
citations and discuss settlement options. The area director
must also receive a written notice of contest within 15 days
of the date you receive the certifed letter.
If, after meeting with the area director, you still want to
appeal the citations, the case can be forwarded to the Occupa-
tional Safety and Health Review Commission (OSHRC), an
independent body that assigns the case to an administrative
law judge. Once this judge makes a decision, you can ask for
an additional review of your case by the OSHRC. The fnal
appeal would be to the U.S. Court of Appeals. If the citation
has been escalated to this level, you should obtain legal repre-
sentation to ensure you receive appropriate guidance.
When good enough isnt aim for excellence
As you prepare for the possibility that your plant might
be chosen for a chemical NEP inspection, your philosophy
should not be, Lets hope we dont get picked. Instead,
imagine your facility has already been notifed that you will
be inspected, and proceed accordingly.
Once you have developed a basic strategy, consider how
to get the greatest possible beneft out of the tasks you need
to complete. This is a hidden opportunity it could be the
motivation for your team to strive for PSM excellence, and
thereby accrue all of the resulting benefts.
Review the preparation checklist. Your team should
already be working to ensure that the requirements of each
category are met. Consider how each of these areas could
be improved upon beyond mere compliance. In many cases,
going that one step further may not require much more effort.
Suppose that temporary operations or emergency
shutdown procedures have a minor mention in the operat-
ing procedures, or are not included at all. This may be a
good time to institute a regular training program on special-
ized operating circumstances. Consider initiating a mentor
program in which veteran operators regularly train and quiz
younger employees about the protocols for atypical operat-
ing conditions.
Management of change (MOC) procedures typically
involve the administration of any physical or procedural
changes within the facility. Although not required by OSHA,
companies on the leading edge of process safety also apply
the MOC process to organizational changes for example,
broader issues such as reorganization of plant management
and policy revisions, or more-specifc issues such as person-
nel retirement and changes in a positions responsibilities.
Including organizational change management in your MOC
procedures goes beyond what is required for the chemical
NEP and is an outstanding addition to an already-compliant
PSM program.
Final thoughts
With no expiration date yet announced by OSHA,
chances are good that your facility will undergo a chemi-
cal NEP inspection at some point in the future. The steps
involved in preparing for this eventuality provide an oppor-
tunity to effect lasting change throughout your organization.
Many methods for improving your overall PSM system
require minimal effort, although some involve more coordi-
nation and commitment from executives. It is essential that
all levels of management not only buy into this philosophy,
but also effectively sell it to their employees if this atmo-
sphere is to endure and thrive.
Updating and improving an existing PSM system
requires the commitment of resources, and the company can
Literature Cited
1. U.S. Occupational Safety and Health Administration, Petro-
leum Refnery Process Safety Management National Emphasis
Program, Directive CPL 03-00-004 (effective Jun. 7, 2007).
2. U.S. Occupational Safety and Health Administration,
Process Safety Management of Highly Hazardous Chemicals,
29 CFR 1910.119, www.osha.gov/STLC/processsafetymanage-
ment/index.html.
3. Steinway, D., et al., Before OSHA Comes Knocking ,
Chem. Eng. Progress, 105 (3), pp. 2831 (Mar. 2009).
4. U.S. Occupational Safety and Health Administration,
OSHAs Field Operations Manual (FOM), Directive CPL
02-00-150 (effective Apr. 22, 2011).
5. U.S. Occupational Safety and Health Administration, PSM
Covered Chemical Facilities National Emphasis Program,
Directive CPL 03-00-014 (effective Nov. 29, 2011).
6. U.S. Occupational Safety and Health Administration, PSM
Covered Chemical Facilities National Emphasis Program,
Directive CPL 02-09-06 (effective July 27, 2009).
7. U.S. Environmental Protection Agency, RMPs Are on
the Way! EPA 550-B99-003, EPA Offce of Solid Waste and
Emergency Response (5104) (Nov. 1999).
8. Marshall, M., OSHAs Refnery & Chemical National
Emphasis Programs, presented at the United Steelworkers 2012
Health, Safety, and Environment Conference, Pittsburgh PA
(Mar. 12, 2012).
9. Hager, M., OSHA Refnery and Chemical NEP Findings,
presented at the Mary Kay OConnor Process Safety Center
International Symposium 2012, Houston, TX (Nov. 9, 2011).
10. Center for Chemical Process Safety, The Business Case
for Process Safety, 2nd ed., American Institute of Chemical
Engineers, New York, NY (2006).
Copyright 2012 American Institute of Chemical Engineers (AIChE)
34 www.aiche.org/cep October 2012 CEP
Safety
quickly reap tangible returns on this investment. A vibrant
culture of process safety inherently leads to a reduction in
the risk of not only major disasters, but also worker injuries,
environmental impact, and the costs associated with mitigat-
ing these issues. These reductions, in turn, lead to benefts
like less time lost investigating incidents, fewer regulatory
penalties, lower insurance premiums, and higher productiv-
ity. Investors, employees, prospective clients, and the local
community will recognize that these enhancements give you
a natural advantage over your competitors, improve your
reputation within your industry, and ultimately make your
company a safer place to work (10).
The approaches you implement at your plant must
be determined based on your particular facilitys needs
and capabilities. Developing an atmosphere of continual
improvement whether in the offce, in the feld, or in the
control room is fundamental to the success of your com-
pany and to the effective execution of your PSM program.
Satisfying the mandates of the OSHA chemical NEP should
be your minimum objective. Challenge your company to
excel beyond what is expected and become a true industry
frontrunner in process safety.
HENRY OZOG is the general partner at ioMosaic Corp. (93 Stiles Rd.,
Salem, NH 03079; Phone: (603) 893-7009; Email: ozog.h.nh@
iomosaic.com), a provider of safety and risk-management consulting
services, training, and software solutions. He is an expert in process
safety management (PSM); risk management; process hazard analy-
sis (PHA), including hazard and operability (HAZOP) studies, failure
mode and effect analysis (FMEA), fault tree analysis (FTA), layer of
protection analysis (LOPA), and quantitative risk analysis (QRA); and
facility siting. He has audited companywide and plant-level PSM
programs relative to regulatory requirements and company standards
and has developed implementation plans to achieve compliance. He
has helped numerous companies and government agencies identify
process risks and implement cost-effective mitigation measures. He
teaches courses in these areas. A member of the AIChE, Ozog holds a
BS and an MS in chemical engineering, both from the Massachusetts
Institute of Technology.
HEATHER R. FORGIONE was a safety and risk management consultant at
ioMosaic Corp. when she wrote this article. There, she focused on
pressure-relief and are systems analysis and PSM auditing in the
petrochemical, chemical, and pharmaceutical industries in the U.S.
Previously, she worked in environmental, health, and safety, industrial
hygiene, and mechanical engineering consulting, and has provided
OSHA-required training to clients for a variety of health and safety
topics. Forgione is a member of the American Society of Mechanical
Engineers and holds a BS in aerospace engineering from Boston Univ.
She is now employed as a hazardous materials specialist and project
manager at Ransom Environmental Consultants.
Attendees receive CCPS
Guidelines for Risk Based
Process Safety
For more information and to register visit
www.aiche.org/ilt
Your process safety program has to meet OSHA PSM Regulation 29CFR 1910.119 and
the EPA Prevention Program requirements. Take this CCPS course and make sure
your program meets them.
Youll leave ready to effectively implement, evaluate and audit an OSHA or EPA
process safety management program for your organization.
Meeting in Orlando, FL
December 57, 2012
2013 Dates Also Available
Your PSM Program Meets
All Your Internal Requirements.
Does it Meet OSHAs?
This December attend CCPS The OSHA Regulatory Approach
to Process Safety Management Course and Make Sure.
2012 AIChE 7909 10.12
CEP
Copyright 2012 American Institute of Chemical Engineers (AIChE)