NEP Compliance Support all Industries

The chemical facility National Emphasis Program (NEP) is a focused inspection program by OSHA to verify compliance with OSHA’s Process Safety Management (PSM) standard (29 CFR 1910.119) at covered facilities. 

The chemical NEP began in November, 2011 and follows on from a pilot chemical facility NEP initiated in July, 2009 and a petroleum refinery NEP that began in June 2007 and is now concluded.  OSHA conducted Program, Quality, Verification (PQV) inspections but few such inspections were possible as they are resource intensive. PQV inspections are broad and open-ended, while chemical NEP inspections rely on specific investigative questions. The goal of the chemical NEP is to conduct a large number of focused inspections. The chemical NEP inspections will focus on whether companies have properly implemented their PSM programs. Companies perform a triennial audit under OSHA’s PSM program but such audits usually do not achieve the depth of chemical NEP inspections. Consequently, facilities that have passed a triennial audit may not pass a chemical NEP inspection. Therefore, covered facilities should take steps to prepare for the possibility of a chemical NEP inspection. OSHA inspectors likely will arrive unannounced at chemical plants. Preparation for a chemical NEP inspection will not only assist in reducing regulatory liability but also help to ensure a safe and productive workplace.

Details

Assistance in preparing for a chemical NEP inspection

We assist you in assembling and executing a plan for managing OSHA’s inspection. We help to ensure your PSM records are in order and readily accessible. We review documents and records to ensure they demonstrate you are implementing your PSM program as designed. We advise on recognized and generally accepted good engineering practices (RAGAGEP) that are a key focus of the chemical NEP.

Performance of a gap analysis

We review key parts of your PSM program against OSHA requirements and identify deficiencies so they can be corrected in advance of a chemical NEP inspection.

PSM program improvements and gap closure

We advise and assist in improving any part of your PSM program to meet anticipated OSHA requirements.

Process safety studies

We conduct projects to complete items that may be missing from your PSM program such as facility siting studies.

On-site support

We provide experienced process safety personnel on a temporary basis to assist in closing out PSM action items and improving PSM practices.

Management and employee briefings

We orient your staff to the chemical NEP so they will be prepared for OSHA’s arrival.

Support during inspections

We assist you in responding to OSHA feedback and citations resulting from the chemical NEP inspection.

Support after inspections

We can assist you in addressing OSHA findings and correcting deficiencies in your PSM program.