The 14 elements of OSHA inspections: How they affect maintenance processes

In the second of three parts, John Ross examines OSHA's 14 elements from their National Emphasis Program (NEP)


In the first part of our series looking at OSHA’s Process Safety Management (PSM), and specifically the National Emphasis Program (NEP), in the March issue of Plant Engineering, we learned the history and purpose of both PSM and NEP.

Horrific and catastrophic incidents were occurring around the world as a result of unintended releases of highly hazardous chemicals (HHCs). To stem the nature and effect of these accidents, the Department of Labor, through its OSHA agency, initiated PSM in 1992 and NEP for refineries in 2007. A few short years after that, riding on the success of the refinery NEP, OSHA initiated a CHEMNEP (Chemical National Emphasis Program) to lay a level of oversight on the other HHC facilities, in line with what was accomplished in the petroleum industry.

It should come as no surprise that the readiness of the petroleum industry, and now the industries that work with or produce other HHCs, weren’t really “ready” for the level of inspection that OSHA was going to bring. If the physical nature of the work to be demonstrated was adequate, the documentation was most likely missing or not ready for inspection. There was a lot of work to do around the country for HHC-related companies to improve on the management of their processes; and there still remains a good bit of work to be accomplished.

To review from part 1, OSHA’s NEP inspectors will review your programs and processes around 14 major elements: 

Here in part 2, we are going to discuss all 14 elements in detail and examine how maintenance is affected. 

1. Employee participation

The employee participation element is perhaps the one with the shortest number of mandates, but with one of the largest impacts. Right from CFR 1910.119, “Employers shall develop a written plan of action regarding the implementation of the employee participation….” The stated intent of this element is for employees, production, maintenance, and staff to be involved in all aspects of the PSM program at your site, and to have representation in the development, discussion, and eventual solution to issues around the process hazard analysis.

Simply put, your employees need to know what’s going on that might affect their safety. Your employee participation program must be written and all meetings well documented.

Here is a question from the 100 “static” questions list that was developed for the refinery NEP: “Does the employer’s written employee participation plan-of-action (see document request XLE.3.e) include information on how employees will be consulted on the development of ALL PSM standard elements?”

As mentioned in part 1, the situation isn’t that facilities don’t have written processes; in fact, many of the companies dealing with HHCs have these written programs but just fail to execute them as written. Employee participation is a process that has to be thought out, and followed as written, to ensure that the workers have a clear and documented path of communication for these important PSM discussions.

Maintenance has a significant impact under this element because it has such a significant impact on the success of the PSM effort. Maintenance technicians are involved in the complex task of testing and repairing the production equipment, and their well-being is on the line with every turn of the wrench. When any aspect of the system involving HHCs is involved, maintenance must be involved in the discussion. This process of including maintenance (and operators) must be documented and followed, with an extensively objective, evidence-laden path.

2. Process safety information

This element contains one of the most highly concentrated, maintenance-specific listings of all the elements. CFR 1910.119 states our obligation as maintenance leaders very clearly: “the employer shall complete a compilation of written process safety information before conducting any process safety hazard analysis required by the standard.

The compilation of written process safety information is to enable the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. This process safety information shall include information pertaining to the hazards of the highly hazardous chemicals used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process.”

In this text, “operators” includes maintenance insomuch as maintenance works on and around the HHCs. The CFR text above indicates that your MSDS (material safety data sheets) information needs to be accessible and current, as do your P&IDs, component information listing, electrical classification, ventilation systems, and safe operating limits, and much, much more. This is a very intense element.

It should be obvious what the impact on maintenance is in regard to the PSI element. Our maintenance technicians have to have access to and understand all the technical data around our production systems, including the component particulars and information on the hazards of the HHC involved. 

3. Process hazard analysis (PHA)

This element is extremely technical in nature and includes a comprehensive what-if evaluation. The CFR reads, “The process hazard analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process.” In this element engineers and maintenance leaders hone their Failure Mode and Effects Analysis (FMEA) skills, as well as exploring the consequence of failure. This process analysis will be conducted as a team and includes a review of the facility siting for possible hazards.

The PHA really affords a tremendous opportunity to get both operators and maintenance technicians involved. In fact, the standard requires this team has both “engineering and process operations” expertise. The team makeup also includes at least one person “who has experience and knowledge specific to the process being evaluated.” Additionally, there has to be one person on the team that is “Knowledgeable in the specific process hazard analysis methodology being used.”

After an initial PHA is conducted, the process hazard analysis is required to be updated and revalidated by a team no less than every five years. 

4. Operating procedures

At first blush it might not seem that there would be a maintenance impact under the heading of operating procedures, but this element has a few items of interest.

Startups following a turnaround, and after an emergency shutdown is included in this element has a control measure to be taken if physical contact or airborne exposure occurs. If you’ve ever been at a plant during an emergency shutdown or a release, then you can attest to the fact that maintenance is heavily involved in addressing the situation. 

5. Training

This element does specifically address the needs for those operating a process. To be sure, though, maintenance technicians need to be fully trained for all the functions they are performing, and that training needs to have been accomplished through a competent source and very well documented. 

6. Contractors

There are a lot of opportunities in this element to trip up an otherwise healthy and well-executed maintenance strategy. Contractors are perhaps unfairly known to do what they can get away with to get a job done. Under the auspices of PSM-NEP, there are some very unforgiving rules: “The employer, when electing a contractor, shall obtain and evaluate information regarding the contract employer’s safety performance and programs. The employer shall inform contract employers of the known potential fire, explosion, or toxic release hazards related to the contractor’s work and the process.” This element continues with other very hefty requirements.

The need to document and cross-reference information, and further document meetings, discussions, etc., with contractors is vital to successfully addressing this element. Many times the supervision of a contractor will fall under the office of the maintenance manager; the impact on plant maintenance should be obvious for this fact. 

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