CHEM NEP Competencies

GCAP CHEMNEP Competencies 


Prerequisites: PSM/RMP course or 2 years PSM/RMP Experience

National Emphasis Program (NEP)
Chemical National Emphasis Program (CHEMNEP)


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 that was also investigated by the CSB (Chemical Safety Board).  Programmed inspections for ammonia and other HHC’s have taken place in Region I, VII and X for the year 2009, 2010, and 2011.  CHEM NEP is nation wide as of November 2011 including state plans having to adopt.


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.”

Course Outline:

Definitions and Acronyms

Inspection Resources

Inspection Process: Refinery and Chemical

Inspection Procedures

Inspection Results


Pilot NEP


Documentation to be Requested

PSM overview


Walk around visit

Selection of Components

Compliance Guidance

NEP Citations



Static List of Inspection Questions from Refinery NEP

Management of Change

Relief Systems

Relief System Designs

Relief System Standards




Operating Procedures

Normal Operations

Emergency Operations

Emergency Shutdown

Normal Startup

Normal Shutdown

Start up following a turnaround

Process Hazard Analyst

Incident Investigation

Compliance Audits

Facility Siting

Human Factors

Employee Participation

P&ID Verification

Contractor Safety

Safe work Practices

Pre Start up Safety Review

Hot work Permits

Incident Investigation reports

Emergency Planning and Response

Course Book:

GCAP created their own NEP book in 2010 and has evolved every class we teach due to more information being available to the industry regarding this emphasis.  The book is a fifteen chapter index.

Chapter 1

OSHA NEP Overview

Power Point Prepared by George Yoksas whom is the area director of Milwaukee area office

Chapter 2

OSHA PSM Resources

Chapter 3

PSM CFR 1910.119

Preamble to the Final Rule – Chapter “C”

Chapter 4

Chemical NEP, Directive Number 10-05

Chemical NEP, CPL 03-00-014

Power Point Jim Lay: OSHA Directorate of Enforcement Programs

Chapter 5

Refinery NEP Inspections

Outline for OSHA Inspections

GCAP took every question, related it to ammonia and reference particular RAGAGEP that could affect our industry regarding these questions.

Chapter 6

Saving Lives and Transforming Workplaces

Chapter 7

Refinery NEP Inspection Results

Chapter 8

OSHA Refinery NEP Slides

Chapter 9

Ammonia Operator Training Requirements

IIAR Guidelines

GCAP Reference to the IIAR Guidelines

Chapter 10

Operator Questions

Chapter 11

OSHA Field Operation Manual (FOM)

Chapter 12

OSHA and EPA Citations

Chapter 13

OSHA and EPA Press Releases

Chapter 14

ANSI/IIAR 2, 2008 Addendum A

Chapter 15


Contact us for more info

Garden City Ammonia Program
2405 E. Fulton Plaza
Garden City , KS 67846
620-271-0484 FAX

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