OSHA Using ‘Pop Quiz' Approach In Emphasis Program for Chemical Facilities

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In contrast to the comprehensive inspections the Occupational Safety and Health Administration relied on in its process safety reviews of oil refineries, the agency is taking a “pop quiz” approach for its National Emphasis Program for chemical facilities, a process safety management consultant said in a Dec. 11 BNA webinar.

OSHA inspectors use a set of 15 questions that are constantly changing and not available to the public, said Joe Baker, a senior consultant with Environmental Resources Management, a training and consulting group. The questions, which are aimed at both the host company and any on-site contractors, probe the design and implementation of a chemical facility's process safety management system, he said.

“That's not to belittle or diminish the program,” Baker said about comparing the program, known as Chem NEP, to a pop quiz. “It's not possible to inspect all those [chemical] facilities.”

OSHA's now-defunct Refinery NEP covered just 75 facilities and involved inspectors spending weeks on-site, compared with Chem NEP's coverage of thousands of locations, he said.

Standard to Prevent Catastrophes

Chem NEP is one part of OSHA's effort under its 20-year-old process safety management standard to prevent disasters at facilities that use highly hazardous chemicals. The standard is dynamic and flexible, shaped by court and agency interpretation, and used to initiate new programs.

Chem NEP started as a pilot program in July 2009 and went national in November 2011 (41 OSHR 1023, 12/1/11).

The program, Baker said, has three categories of emphasis:

• Category 1 covers facilities likely to use ammonia for refrigeration;

• Category 2 covers facilities likely to use chlorine for water treatment as the only highly hazardous chemical; and

• Category 3 covers facilities likely to use ammonia or chlorine for purposes other than refrigeration or water treatment, or highly hazardous chemicals other than ammonia or chlorine.


OSHA partially exempts facilities in its Safety and Health Achievement Recognition Program and Voluntary Protection Programs from site inspections, Baker said.

In addition to Chem NEP, consultants in the Dec. 11 webinar discussed other aspects of process safety management.

RAGAGEPs Covered

Steve Hawkins, a partner with ERM, detailed how to develop proper Recognized and Generally Accepted Good Engineering Practice (RAGAGEP) programs. Hawkins said RAGAGEPs contain documentation on engineering, operating, or maintenance activities for equipment based on established code standards, published technical reports, recommended practices or similar documents.

For example, Hawkins said RAGAGEPs for piping are based on American Society of Mechanical Engineers standard B31.3 or American Petroleum Institute standard 570, while those for atmospheric tanks are based on API standard 653.

But sometimes facilities will use equipment that does not have corresponding industry standards, and OSHA will expect process safety managers to have the expertise to define RAGAGEPs for the equipment used, he said.

Common Markers

Hawkins and Baker also noted some common markers of failing process safety management cultures. These include becoming complacent after an extended period without incident, failing to deal with the impact of personnel changes, and thinking about a process safety management program as if it was a manual that goes on the shelf rather than a process that is continually practiced.

Baker said some companies have hired him only to put together manuals. “That's a road to real disappointment if a system isn't in place,” he said.

By Robert Iafolla  

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