NEP “National Emphasis Program”

Pre-requisites: PSM Experience

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NEP course has been developed for the need of understanding OSHA’s regulations regarding 1910.119.  It was developed for the petroleum industry after numerous accidents in recent past including the BP explosion in Texas .  Programmed inspections for ammonia and other HHC’s have taken place in Region I, VII and X for the year 2010.  

Purpose:  To understand and describe the policies and procedures that will take place with a NEP inspection.  The NEP is designed to reduce or eliminate the workplace hazards associated with the catastrophic release of highly hazardous chemicals.  

Emphasis on Implementation over Documentation:  “Based on past OSHA inspection history at refineries and large chemical plants, OSHA has typically found that these employers have extensive written documentation related to process safety management, but the implementation of the written documentation has been inadequate.   Therefore, CSHO’s should focus on the implementation of the various PSM elements and ensure that employers do what they have committed to do in their PSM documentation.” Osha.gov

Outline of NEP Course:

-Definitions and Acronyms

-Inspection Recourses

-Inspection Process: Refinery and Chemical

-Inspection Procedures: Inspection Results

-Documentation to be requested

-PSM overview

-PPE

-Walkaround

-Selection of Components

-Compliance Guidelines

-All NEP Citations

-Static List of Inspection Questions: Priority Items

            : Management of Change

            : Relief System

            : Compressors

            : Vessels

            : Piping

            : Operating Procedures

                        : Normal Operations, Emergency Shutdown, Emergency Operations

            : PHA

:           : Incident Investigation

            : Compliance Audits

            : Facility Siting

            : Human Factors

            : Employee Participation

            : P&ID Verification

            : Contractor Safety

            : Safe Work Practices

            : Pre-Startup Safety Reviews

            : Hot Work Permits

            : Incident Investigation Reports

            : Emergency Planning and Response