The history and purpose of PSM-NEP
Even with OSHA's good intent, catastrophic incidents were still happening, especially in the petroleum industry.
Author's note: I recommend that you read John Ross' article, Making Sense of Process Safety, before reading this blog post.
Process Safety Management was initiated by the Occupational Safety & Health Administration (OSHA) in 1992 as a way to respond with government oversight of industries using highly hazardous chemicals (HHCs). Events prior to that date, involving the infrequent release of HHCs had sometimes resulted in catastrophic damage, injuries, and even death. Clearly, unchecked processes added to a volatile situation sometimes making things worse; much worse.
In September 1994, OSHA issued Instruction CPL 02-02-045, Process Safety Management of Highly Hazardous Chemicals-Compliance Guidelines and Enforcement Procedures. This instruction ceded that the program quality verification (PQV) inspections required great resources and limited the number of inspections that could be accomplished. This was a program that didn't have the effect that was desired.
Even with OSHA's good intent, catastrophic incidents were still happening, especially in the petroleum industry:
— 2004: Gallup, NM - 6 injured
— 2005: Texas City, TX - 15 killed, 170 injured
— 2005: Bakersfield, CA - 1 killed
— 2007: Dumas, TX - HHC release and fire
— 2008: Big Spring, TX - LPG release and explosion
In 2007, OSHA initiated the Refinery National Emphasis Program (NEP) to zero in on the factors that most affected process safety in refineries. By all standards the program was successful. There were certainly still incidents in the refinery industry, but the nature and the resulting damage were greatly decreased. Still more work and inspections would need to be done.
Due to the success of the NEP in the refinery industry, OSHA initiated a pilot program in the other facilities that dealt with HHCs. This pilot program became official, nationwide in 2011 through OSHA Instruction CPL 03-00-14, PSM Covered Chemical Facilities National Emphasis Program; CHEMNEP for short.
The refinery NEP and the CHEMNEP are two different programs, but each involves a closer look and scrutiny of 14 major elements:
1. Employee participation
3. Incident investigation
4. Process safety information
5. Pre-start-up review
6. Emergency planning and response
7. Process hazard analysis
8. Mechanical integrity
9. Compliance audits
10. Operating procedures
11. Hot work permit
12. Trade secrets
14. Management of change
More to come on this topic in the following weeks. What do you think? Leave a comment below!
John L. Ross is a senior consultant at the Marshall Institute.