The Chemical Industry National Emphasis Program (NEP) Top Ten

The National Emphasis Program (NEP) for chemical facilities established by OSHA was designed to protect workers from catastrophic releases of highly hazardous chemicals. This initiative targeted chemical facilities’ compliance and implementation efforts related to Process Safety Management (PSM) and other workplace safety standards associated with chemical hazards.

Judy A. Perry, CCPSC, a professional with over 30 years of experience in process safety and operations management, developed the list of high-priority items below based on a thorough analysis of publicly accessible data. The list is intended to assist facility managers in their preparation. Each facility and each individual PSM coordinator has the best sense of existing gaps at a particular facility, but this list can serve as a good starting point.

Top 10 List

• Review operating procedures to ensure that each phase of operation is covered, as outlined in the PSM standard.
  (a) Validate that emergency shutdown procedures (ESPs) clearly outline when they should be initiated and who (i.e., what position or job title) is assigned to specific shutdown tasks.
  (b) Validate that temporary operations are included in the operating procedures.

• Review the available process safety information (PSI) for each process. Ensure that the information is being properly filed and managed, and is readily available.
  (a) Ensure that piping and instrumentation diagrams (P&IDs) are being red-lined and are current to existing operations.
  (b) Document relief system design and the design basis, and ensure that it addresses reactivity concerns.
  (c) Ensure that documentation includes the equipment’s compliance with recognized and generally accepted good engineering practices (RAGAGEPs).
  (d) Ensure that electrical classifications are documented and well understood.
  (e) Document evaluations of chemical reactivity hazards.

• Review process hazard analysis (PHA) reports in detail.
  (a) Validate that the 5-year revalidation has occurred on time.
  (b) Validate that closure of action items has occurred and that closure is documented.
  (c) Validate that human factors and facility siting are included in the PHA report.
  (d) Ensure that the facility siting is based on current design codes and standards.

• Review the implementation and documentation of the mechanical integrity program.
  (a) Validate that written procedures related to the ongoing integrity of the process, based on industry standards (RAGAGEPs), are available.
  (b) Validate that inspections are occurring, and that the inspection frequency is based on industry standards (RAGAGEPs).
  (c) Correct any deficiencies in equipment, i.e., operation outside of safe operating limits, before further use (or in an otherwise safe and timely manner).

• Monitor that incident investigations are being done correctly and that resulting action items are addressed.
• Make available a written employee participation plan.
• Review OSHA compliance standards related to electrical equipment (1910.302-308) and conduct a general site inspection of electrical equipment in hazardous areas.
• Validate that personal protective equipment (PPE) procedures and current training documentation are in place and are being followed by employees.
• Validate that safe work practices are in good order (e.g., for lockout/tagout, confined space entry, line breaking) and being followed by employees and contractors.
• Validate that the plant’s management of change (MOC) procedure is current. Audit areas of recent changes to validate proper implementation.

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