The history and purpose of PSM-NEP

Even with OSHA's good intent, catastrophic incidents were still happening, especially in the petroleum industry.

05/10/2013


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
2. Contractors
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
13. Training
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.



Top Plant
The Top Plant program honors outstanding manufacturing facilities in North America.
Product of the Year
The Product of the Year program recognizes products newly released in the manufacturing industries.
System Integrator of the Year
Each year, a panel of Control Engineering and Plant Engineering editors and industry expert judges select the System Integrator of the Year Award winners in three categories.
June 2018
2018 Lubrication Guide, Motor and maintenance management, Control system migration
May 2018
Electrical standards, robots and Lean manufacturing, and how an aluminum packaging plant is helping community growth.
April 2018
2017 Product of the Year winners, retrofitting a press, IMTS and Hannover Messe preview, natural refrigerants, testing steam traps
June 2018
Machine learning, produced water benefits, programming cavity pumps
April 2018
ROVs, rigs, and the real time; wellsite valve manifolds; AI on a chip; analytics use for pipelines
February 2018
Focus on power systems, process safety, electrical and power systems, edge computing in the oil & gas industry
Spring 2018
Burners for heat-treating furnaces, CHP, dryers, gas humidification, and more
April 2018
Implementing a DCS, stepper motors, intelligent motion control, remote monitoring of irrigation systems
February 2018
Setting internal automation standards

Annual Salary Survey

After two years of economic concerns, manufacturing leaders once again have homed in on the single biggest issue facing their operations:

It's the workers—or more specifically, the lack of workers.

The 2017 Plant Engineering Salary Survey looks at not just what plant managers make, but what they think. As they look across their plants today, plant managers say they don’t have the operational depth to take on the new technologies and new challenges of global manufacturing.

Read more: 2017 Salary Survey

The Maintenance and Reliability Coach's blog
Maintenance and reliability tips and best practices from the maintenance and reliability coaches at Allied Reliability Group.
One Voice for Manufacturing
The One Voice for Manufacturing blog reports on federal public policy issues impacting the manufacturing sector. One Voice is a joint effort by the National Tooling and Machining...
The Maintenance and Reliability Professionals Blog
The Society for Maintenance and Reliability Professionals an organization devoted...
Machine Safety
Join this ongoing discussion of machine guarding topics, including solutions assessments, regulatory compliance, gap analysis...
Research Analyst Blog
IMS Research, recently acquired by IHS Inc., is a leading independent supplier of market research and consultancy to the global electronics industry.
Marshall on Maintenance
Maintenance is not optional in manufacturing. It’s a profit center, driving productivity and uptime while reducing overall repair costs.
Lachance on CMMS
The Lachance on CMMS blog is about current maintenance topics. Blogger Paul Lachance is president and chief technology officer for Smartware Group.
Electrical Safety Update
This digital report explains how plant engineers need to take greater care when it comes to electrical safety incidents on the plant floor.
Maintenance & Safety
The maintenance journey has been a long, slow trek for most manufacturers and has gone from preventive maintenance to predictive maintenance.
IIoT: Machines, Equipment, & Asset Management
Articles in this digital report highlight technologies that enable Industrial Internet of Things, IIoT-related products and strategies.
Randy Steele
Maintenance Manager; California Oils Corp.
Matthew J. Woo, PE, RCDD, LEED AP BD+C
Associate, Electrical Engineering; Wood Harbinger
Randy Oliver
Control Systems Engineer; Robert Bosch Corp.
Data Centers: Impacts of Climate and Cooling Technology
This course focuses on climate analysis, appropriateness of cooling system selection, and combining cooling systems.
Safety First: Arc Flash 101
This course will help identify and reveal electrical hazards and identify the solutions to implementing and maintaining a safe work environment.
Critical Power: Hospital Electrical Systems
This course explains how maintaining power and communication systems through emergency power-generation systems is critical.
click me