ChemNEP 11 29 OSHA CHEM NEP Instructions

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DIRECTIVE NUMBER: CPL 03-00-014 EFFECTIVE DATE: November 29, 2011
SUBJECT: PSM Covered Chemical Facilities National Emphasis Program
ABSTRACT
Purpose: This instruction describes policies and procedures for a National Emphasis
Program (NEP) to reduce or eliminate the workplace hazards associated
with the catastrophic release of highly hazardous chemicals.
Scope: This Instruction applies OSHA-wide. Both Programmed and
Unprogrammed inspections will take place in all OSHA Regions.
References: See Paragraph III.
Cancellations: 10-05 (CPL 02), PSM-Covered Chemical Facilities National Emphasis
Program.
State Impact: Notice of Intent and Adoption required. See paragraph VIII.
Action Offices: National, Regional, Area, and State Plan Offices
Originating Office: Directorate of Enforcement Programs (DEP).
Contact: Directorate of Enforcement Programs
200 Constitution Avenue, NW, Room 3107
Washington, DC 20210
Phone (202) 693-1850
By and Under the Authority of
David Michaels, PhD, MPH
Assistant Secretary
ABSTRACT-1
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Executive Summary
This instruction provides guidance to Occupational Safety and Health Administration (OSHA)
national, regional, and area offices for implementing and conducting an NEP to reduce or
eliminate workplace hazards associated with the catastrophic release of highly hazardous
chemicals. Both programmed and unprogrammed inspections associated with this NEP will
begin immediately in all Regions.
ABSTRACT-2
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Table of Contents
I. Purpose. .......................................................................................................................................................... 2
II. Scope. ............................................................................................................................................................. 2
III. References....................................................................................................................................................... 2
IV. Cancellations................................................................................................................................................... 3
V. Significant Changes. ....................................................................................................................................... 3
VI. Action Offices................................................................................................................................................. 3
VII. Application. .................................................................................................................................................... 4
VIII. Federal Program Change................................................................................................................................. 4
IX. Background..................................................................................................................................................... 4
X. Acronyms........................................................................................................................................................ 5
XI. Program Procedures........................................................................................................................................ 6
A. Programmed Inspection Site Selection. .......................................................................................................... 6
1. Targeting Sources. .......................................................................................................................................... 6
2. Facility Identification and Master List Generation. ........................................................................................ 6
3.Inspection Scheduling..................................................................................................................................... 8
B. SST and Unprogrammed Inspections (Applies to all OSHA Regions)........................................................... 8
1. SST Inspections. ............................................................................................................................................. 8
2. Unprogrammed Inspections. ........................................................................................................................... 8
C. Inspection Resources. ..................................................................................................................................... 9
1.Inspection Team Personnel........................................................................................................................... 10
3. Utilization of Other OSHA Technical and Enforcement Resources. ............................................................ 13
4.Utilization of OSHA Health Response Team (HRT).................................................................................... 13
5. Industry Reference Material Availability...................................................................................................... 13
D. Inspection Process. ....................................................................................................................................... 14
1. NEP Inspection Process Different from PSM CPL PQV Process................................................................. 14
2. Emphasis on Implementation over Documentation....................................................................................... 14
3.Dynamic List Questions................................................................................................................................ 14
4. Expanding the Inspection.............................................................................................................................. 15
5. Inspect Both Host and Contract Employers. ................................................................................................. 15
6.Review Inspection History and Abatement................................................................................................... 15
E. Inspection Procedures................................................................................................................................... 15
1. Supplemented FOM Procedures. .................................................................................................................. 15
2. Opening Conference. .................................................................................................................................... 15
3. Documentation to be Requested -- General and Process-Related. ................................................................ 18
4. PSM Overview.............................................................................................................................................. 19
5. Personal Protective Equipment (PPE) and Camera/Video Use..................................................................... 19
6. Initial Walkaround. ....................................................................................................................................... 20
7. Selection of Unit. .......................................................................................................................................... 21
8.Inspection of Contractors.............................................................................................................................. 22
9.Compliance Guidelines................................................................................................................................. 22
10.Review Inspection History and Abatement. ................................................................................................ 23
11.Citations. ..................................................................................................................................................... 23
F. Program Evaluation. ..................................................................................................................................... 23
G. Outreach........................................................................................................................................................ 24
H. IMIS and OIS Coding Instructions. .............................................................................................................. 24
Appendix A ………………………………………………………………………………………………….. ...A-
1
ABSTRACT-3
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I. Purpose.
This instruction describes an OSHA National Emphasis Program (NEP) for inspecting
facilities with highly hazardous chemicals (HHCs) in amounts at or greater than the
threshold quantities listed in 29 CFR 1910.119. Programmed inspections1 will be
conducted in facilities that are known to OSHA as having a risk of catastrophic releases.
Unprogrammed inspections2 will take place in PSM-covered facilities as described in this
Instruction. This NEP does not apply to Petroleum refineries (NAICS 32411).
II. Scope.
This notice applies OSHA-wide.
III. References.
A. Federal Register, Volume 57, Number 36, pages 6355 to 6417, (including
Preamble) February 24, 1992, Final Rule, Process Safety Management (PSM) of
Highly Hazardous Chemicals, 29 CFR 1910.119; Explosives and Blasting Agents
standard, 29 CFR 1910.109.
B. CPL 02-02-045 – (formerly CPL 2-2.45A CH-1) - Process Safety Management of
Highly Hazardous Chemicals -- Compliance Guidelines and Enforcement
Procedures, September 13, 1994.
C. 29 CFR 1910.106, Flammable and Combustible Liquids
D. 29 CFR 1910.146, Permit-Required Confined Spaces
E. 29 CFR 1910.147, The Control of Hazardous Energy (Lockout/Tagout)
F. 29 CFR 1910, Subpart I, Personal Protective Equipment
G. 29 CFR 1910.307, Hazardous (Classified) Locations
H. OSHA Instruction CPL 02-00-148, Field Operations Manual (FOM), November
9, 2009.
I. OSHA Instruction ADM 03-01-005, OSHA Compliance Records, August 3, 1998.
1 Programmed inspections are defined in CPL 02-00-148 Field Operations Manual as “inspections of worksites
which have been scheduled based upon objective or neutral selection criteria.”
2 Unprogrammed inspections are defined in CPL 02-00-148 Field Operations Manual as “inspections scheduled in
response to alleged hazardous working conditions that have been identified at a specific worksite.”
2
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J. CPL 02-00-025 - CPL 2.25I - Scheduling System for Programmed Inspections,
January 4, 1995.
K. OSHA Instruction CPL 02-01-037 (CPL 2-1.037), Compliance Policy for
Emergency Action Plans and Fire Prevention Plans, July 9, 2002.
L. OSHA Notice 10-06 [(CPL 02)] Site-Specific Targeting 2010, August 18, 2010.
M. OSHA Instruction CPL 02-00-094 (CPL 2.94), OSHA Response to Significant
Events of Potentially Catastrophic Consequences, July 22, 1991.
N. OSHA PSM Safety and Health Topics web page,
www.osha.gov/SLTC/processsafetymanagement/index/html
O. Accidental Release Prevention Requirements - Risk Management Programs
Under the Clean Air Act, U.S. Environmental Protection Agency’s (EPA)
standard, 40 CFR Part 68, Chemical Accident Prevention Provisions.
P. Chemical NEP Dynamic Lists, OSHA Intranet website
Q. OSHA Instruction CPL 03-00-010, Petroleum Refinery Process Safety
Management National Emphasis Program, August 18, 2009.
IV. Cancellations.
This Instruction cancels OSHA 10-05 (CPL 02) PSM-Covered Chemical Facilities
National Emphasis Program.
V. Significant Changes.
This Instruction expands the PSM-Covered Chemical Plants National Emphasis Program
nationwide to all OSHA Regions and State Plans. Facility categories have been reduced
from three in the pilot NEP to two: facilities likely to have ammonia used for refrigeration
as the only Highly Hazardous Chemical (HHC) and all other facilities. The number of
programmed inspections required per Area Office has been reduced. Significant industry
and/or OSHA experience has been recognized for CSHO qualifications to conduct PSM
inspections. A requirement to verify abatement of previous OSHA PSM citations has
been added. Instructions for preparing targeting lists have been clarified, and program
evaluation requirements have been reduced.
VI. Action Offices.
National, Regional, Area, and State Plan Offices.
3
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VII. Application.
OSHA compliance officers shall follow the procedures contained in this notice when
inspecting the facilities selected under this NEP. This NEP does not apply to facilities
with a 32411 NAICS code. For facilities with a 32411 NAICS code, please refer to the
Petroleum Refinery Process Safety Management NEP.
VIII. Federal Program Change. Notice of Intent and Adoption Required.
This instruction describes an NEP for inspecting facilities with PSM-covered processes.
Because the seriousness and prevalence of the hazards addressed are nationwide, States
are required to participate in this emphasis program. All such inspections and related
compliance assistance activity should be coded CHEMNEP as directed in paragraph
XI.H.
States are required to notify OSHA within 60 days whether the State’s emphasis program
will be identical to or different from the Federal program. If a State is already
implementing an emphasis program in this area, or if it adopts a new initiative in response
to this Federal program change, its implementing policies and procedures are expected to
be at least as effective as those in this instruction.
If a State adopts or maintains an emphasis program on PSM-covered Chemical Facilities
which differs from the Federal program, the State must identify the difference and may
either post its different procedures on its State Plan’s website and provide the link to
OSHA, or provide an electronic copy to OSHA with information on how the public may
obtain a copy. If the State’s emphasis program is identical to the Federal program, it must
provide the date of adoption to OSHA. State adoption must be accomplished within six
months, with posting or submission of documentation within 60 days thereafter. OSHA
will provide summary information on the State to this instruction on its website.
OSHA’s Office of Statistical Analysis will work with the States to provide the data
necessary to develop their own targeting lists according to the instruction in section XI.A.
OSHA will make the dynamic list of questions available to the States. States must code
any inspections (programmed or unprogrammed) and related compliance assistance
activity conducted under this NEP as directed in Section XI.G. States using the
procedures in this instruction are asked to provide the feedback set out in section XI.F to
the Directorate of Enforcement Programs through their Regional Offices in order to assist
OSHA in evaluating this program.
IX. Background.
OSHA promulgated the PSM standard in 1992 in response to a number of catastrophic
incidents that occurred worldwide (See Process Safety Management of Highly Hazardous
Chemicals, 29 CFR 1910.119). These incidents spurred broad recognition that releases of
highly hazardous chemicals could lead to incidents that may occur relatively infrequently,
but, due to their catastrophic nature, often result in multiple injuries and fatalities.
4
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On September 13, 1994, OSHA issued Instruction CPL 02-02-045, Process Safety
Management of Highly Hazardous Chemicals – Compliance Guidelines and Enforcement
Procedures. This instruction established policies, procedures, clarifications, and
compliance guidance for enforcement of the PSM standard. The instruction
acknowledged that Program Quality Verification (PQV) inspections were resource
intensive, and, therefore, OSHA would perform only a limited number each year.
Consequently, very few PQV inspections have been conducted since Instruction CPL 02-
02-045 was issued in 1994.
In July 2009, OSHA implemented a pilot NEP for PSM-covered chemical facilities. The
pilot outlined a new approach for inspecting PSM-covered facilities that allowed for a
greater number of inspections using better allocation of OSHA resources. Under the
pilot, OSHA was able to increase the number of PSM facilities inspected with relatively
limited resources.
Based on data collected and feedback from OSHA personnel, this Instruction outlines a
slightly modified Chemical NEP that will be launched OSHA-wide.
X. Acronyms.
A. AAD – Assistant Area Director (OSHA)
B. AD – Area Director (OSHA)
C. AO – Area Office (OSHA)
D. CSHO – Compliance Safety and Health Officer
E. DEP – Directorate of Enforcement Programs (OSHA National Office)
F. DEA Directorate of Evaluation and Analysis (OSHA National Office)
G. EPA - U.S. Environmental Protection Agency
H. FOM – Field Operations Manual
I. HAZWOPER – Hazardous Waste Operations and Emergency Response
J. HHC – Highly Hazardous Chemical
K. LEL – Lower Explosive Limit
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L. NAICS – North American Industrial Classification System
M. NEP – National Emphasis Program
N. NO – National Office (OSHA)
O. RA – Regional Administrator (OSHA)
P. RAGAGEP – Recognized and Generally Accepted Good Engineering Practices
Q. RMP – Risk Management Plans (U.S. EPA)
R. RO – Regional Office (OSHA)
XI. Program Procedures.
A. Programmed Inspection Site Selection.
1. Targeting Sources.
OSHA will use four sources for targeting:
a. U.S. Environmental Protection Agency’s (EPA) Chemical Accident
Prevention Provisions, Program 3 Risk Management Plans (RMP) 3,
b. Explosives manufacturing NAICS codes,
c. OSHA’s IMIS database, and
d. OSHA Area Office knowledge of local facilities.
2. Facility Identification and Master List Generation.
a. OSHA’s National Office will use the following procedure to create
two National Chemical Targeting Lists:
• DEP will obtain a list of facilities that submitted EPA Program 3
RMP;
• DEA will provide DEP with a list of facilities identified in the
IMIS or OIS databases as having being previously cited under
PSM, sorted by NAICS Code;
3 Facilities covered by EPA’s Risk Management Program are considered to be Program 3 if they are covered by
OSHA’s PSM 1910.119. 6
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• DEA will provide DEP with a list of facilities with NAICS codes
identified as explosives manufacturing;
• DEP will combine these lists and sort them into two lists:
Category 1 – NAICS Codes for facilities likely to have ammonia
used for refrigeration as the only HHC; Category 2 –NAICS Codes
for facilities likely to have ammonia used for other than
refrigeration, or HHCs other than ammonia.
These lists will be divided by OSHA Region and posted on the OSHA
DEP Intranet website. The national list will be updated annually.
b. The Office of Statistics shall create a list of all known establishments
with NAICS codes identical to those identified in the IMIS database as
having received prior PSM citations sorted by Area Office jurisdiction.
This list, the Potentially PSM-Covered Facilities List, will be posted
on the DEP Intranet website. These facilities will not be automatically
added to the targeting list, but used by the OSHA Regions to consider
when adding facilities based on local knowledge.
c. Each OSHA Region shall prepare local Category 1 and 2 master lists
of facilities. Based on their familiarity with local facilities, OSHA
Regions shall:
• Add any facility that is not on the national list, are known by the
Region to operate in their jurisdiction, and are known as likely to
be PSM-covered.
OSHA Regions should note that because EPA’s RMP and OSHA’s
PSM cover different chemicals, the national list may be missing
PSM covered facilities – particularly those that use flammable
liquids. Therefore, OSHA Regions should consult the Potentially
PSM-Covered Facilities List and add any listed facility that, based
on local knowledge is likely to be PSM-covered.
• Delete any facility that is known to be out of business,
documenting the basis for such determinations;
• Delete any facility that is an approved participant in OSHA’s
Voluntary Protection Program (VPP) or OSHA Consultation’s
Safety and Health Achievement Recognition Program (SHARP);
• Delete any facility that has already received an inspection under
this NEP in the last two years or is a facility with NAICS code
32411 (petroleum refineries); and
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• Delete any facility that has received a comprehensive PSM
inspection within the last two years.
The OSHA Regions must update their master lists annually and maintain
the lists for three years after the completion of all of the inspections
conducted under this NEP. (See OSHA Instruction ADM 03-01-005,
OSHA Compliance Records.)
Note: OSHA Regions may choose to have the lists created and maintained
by the AO at their discretion.
3. Inspection Scheduling.
a. Programmed inspections will take place immediately in all regions.
b. Regions should each complete an average of 3-5 programmed
inspections per AO per year using this NEP. In situations where an
AO has fewer than three PSM-covered facilities in its jurisdiction, the
Region should schedule more Chem NEP inspections in area offices
with a greater number of PSM-covered facilities. Each Region shall
randomly select inspection sites from its master lists.
c. In order to ensure that inspections are appropriately allocated across all
hazardous processes, inspections should consist of approximately 75%
from the Category 2 Master List and approximately 25% from the
Category 1 Master List. In a Region where this is not possible due to
the types of facilities in its jurisdiction, the mix of facilities may be
adjusted as necessary.
B. SST and Unprogrammed Inspections (Applies to all OSHA Regions).
1. SST Inspections.
Some establishments may also be selected for inspection under the current
Site-Specific Targeting (SST) Plan. CSHOs must use this NEP for the
comprehensive inspection of the selected PSM-covered process(es) at the
facility. CSHOs may, after consulting with the Area Director, expand the
PSM portion of the inspection beyond this notice if they determine that
PSM deficiencies may exist either outside of the selected unit or beyond
the scope of the dynamic list questions.
2. Unprogrammed Inspections.
The following guidelines shall be used for all unprogrammed inspection
activities related to PSM-covered processes nationwide:
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a. Complaint or referral. If a formal complaint or referral is received
relating to a PSM-covered process and it:
• involves an application of the PSM standard - the AD shall
evaluate the complaint or referral item(s) in the usual manner (CPL
02-00-148 – Field Operations Manual) and conduct an inspection
using this notice.
• does not involve an application of the PSM standard (for example,
there is a complaint about fall protection hazards in a PSM-
covered process) - the inspection or inquiry will normally be
limited to the complaint and referral item(s)/subject(s) only.
However, if the facility has not already been inspected, a
concurrent inspection using this NEP may be conducted at the
AD’s discretion.
b. Accidents and Catastrophes. Responses to accidents and catastrophes
in facilities that contain PSM-covered processes shall follow the
guidelines contained in CPL 02-00-148 – Field Operations Manual
and, where appropriate, in OSHA Instruction CPL 02-00-094, OSHA
Response to Significant Events of Potentially Catastrophic
Consequences in addition to this Notice’s guidelines.
When an accident or catastrophe occurs in a facility that contains a
PSM-covered process, and it:
• involves an application of the PSM standard – the inspection will
include the accident investigation item(s)/subjects and a Chemical
NEP inspection using this notice.
• does not involve an application of the PSM standard - the
inspection will normally be limited to the accident investigation
item(s)/subject(s) alone. However, if the facility has not already
been inspected using this notice, a concurrent inspection using this
NEP may be conducted at the AD’s discretion.
C. Inspection Resources.
Appropriate levels of staff experience, training, and preparation are essential for
compliance activities relating to the PSM standard. Inspections using this NEP
may be conducted by either a single OSHA employee or a team. At least one
member of the team or the OSHA employee must be qualified to Level 1 as
described below. For inspections that fall into Category 1 – Facilities that use
only ammonia for refrigeration, Level 1 requirements are specified under
Ammonia Refrigeration Level 1.
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Notes on training:
OTI Course 3430 covers issues particular to the types of industries covered
by this NEP. Given the wide variety of processes found in chemical
processing industries, Level 1 personnel are strongly encouraged to attend
Course 3430.
Due to a significant change in course content, completion of Course 330
prior to Fiscal Year 1991 does not meet this requirement for Level 1
training.
1. Inspection Team Personnel.
a. Inspections of Ammonia Refrigeration Processes Only - Level 1.
OSHA personnel may be assigned as Level 1 team members under this
notice for inspections of ammonia refrigeration facilities, if:
• They have completed OSHA Training Institute’s (OTI) Course
3300, Safety and Health in the Chemical Processing Industries,
Course 3400, Hazard Analysis in the Chemical Processing
Industries.
and,
• They have completed advanced training such as OTI Course 3410,
Advanced Process Safety Management, OTI Course 3430,
Advanced PSM in the Chemical Industries, or a specialized course
on ammonia refrigeration.
and,
• They have prior experience including:
− accident investigations in chemical, petrochemical
or refinery plants involving fires, explosions, and/or
toxic chemical releases, or,
− previous chemical inspections involving process
safety management evaluations, or
− previous chemical industry employment, or
− participation in a PSM inspection of an ammonia
refrigeration facility.
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b. Level 1. OSHA personnel may be assigned as Level 1 team members
under this notice, if they meet the criteria for any of the following
options.
• Option 1:
− They have completed OSHA Training Institute’s (OTI) Course
3300, Safety and Health in the Chemical Processing Industries,
Course 3400, Hazard Analysis in the Chemical Processing
Industries, and advanced training including either OTI Course
3430, Advanced PSM in the Chemical Industries or Course
3410, Advanced Process Safety Management.
and,
− They have prior experience (OSHA, other government agency,
or industry) with chemical industry safety including: accident
investigations in chemical, petrochemical or refinery plants
involving fires, explosions, and/or toxic chemical releases,
or,
− They have previous (OSHA, other government agency, or
industry) chemical inspection experience involving process
safety management evaluations, or previous chemical industry
employment involving process engineering, operations, safety,
or maintenance.
• Option 2:
− They have completed OSHA Training Institute’s (OTI) Course
3430, Advanced PSM in the Chemical Industries or Course
3410, Advanced Process Safety Management.
and,
− They have 3 years experience working in a PSM-covered
manufacturing facility (chemical, petrochemical, refining) in a
process engineering, operations, safety, or maintenance
position.
• Option 3
− They have completed OSHA Training Institute’s (OTI) Course
3430, Advanced PSM in the Chemical Industries or Course
3410, Advanced Process Safety Management.
and,
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− They have 7 years Federal or State OSHA experience.
and,
− They have participated in greater than 20 PSM and/or chemical
plant inspections where they were the team leader equivalent in
at least two of these inspections.
c. Level 2. OSHA personnel may be assigned as inspection team
members under this notice, if:
• Option 1:
− They have completed OTI Course 3300, Safety and Health in
the Chemical Processing Industries (including offerings of this
course prior to fiscal year 1991) and OTI Course 3400 Hazard
Analysis in the Chemical Processing Industries.
and,
− They have two years of OSHA inspection experience or the
equivalent, such as State OSHA experience, EPA RMP
experience, U.S. Chemical Safety Board experience.
• Option 2:
− They have 3 years experience working in a PSM-covered
manufacturing facility (chemical, petrochemical, refining) in a
process engineering, operations, safety, or maintenance
position.
• Option 3
− 7 years of Federal or State OSHA experience.
and,
− They have participated in more than 20 PSM and/or chemical
plant inspections where they were the team leader equivalent in
at least two of these inspections.
d. Level 3.
OSHA personnel who do not have the training and experience to
qualify as Level 1 or 2 may be assigned to an inspection team under
this notice, in the following circumstances:
• Level 3 team members must be under the direction of a Level 1 or
2 team member.
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• Level 3 team members experienced in evaluating other
programmatic standards such as hazard communication,
lockout/tagout, confined space entry, and respiratory protection
programs may evaluate compliance with programmatic sections of
the PSM standard.
• Level 3 team members may evaluate compliance with the
following elements of the PSM standard:
− (c) employee participation
− (g) training
− (h) contractors
− (k) hot work permits
− (m) incident investigation
− (n) emergency planning and response
2. ROs will determine, document, and provide to DEP-Office of General
Industry the PSM qualification level for each CSHO conducting PSM
inspections based on the options listed above. DEP-Office of General
Industry will keep this information in a central file. ROs will update this
documentation annually for each CSHO whose PSM qualification level has
changed in the previous year.
3. Utilization of Other OSHA Technical and Enforcement Resources.
CSHOs and other inspection team members will fully utilize RO and NO
(DEP, DSG, and DTSEM) technical and enforcement support resources
when making decisions regarding compliance or noncompliance.
4. Utilization of OSHA Health Response Team (HRT).
AOs may include technical experts from the HRT OSHA Salt Lake City
Technical Center (SLTC) as circumstances warrant.
5. Industry Reference Material Availability.
OSHA’s PSM Safety and Health Topics web page lists documents that
will be useful for PSM inspections in addition to the list of documents
found in Appendix D of CPL 02-02-045. ROs should consult with their
Regional PSM Coordinators to identify which industry documents are
necessary to support their enforcement activities.
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Each RO library must have industry reference documents accessible for
CSHOs to use during the inspection. AO jurisdictions that conduct a large
number of PSM inspections should have these industry reference
documents in their own libraries. CSHOs may also access documents
available online through OSHA’s Technical Data Center.
D. Inspection Process.
1. NEP Inspection Process Different from PSM CPL PQV Process.
This NEP differs from the program-quality-verification (PQV) approach in
PSM CPL 02-02-045. Inspections done using the PQV are broad and
open-ended, while inspections using this notice rely on specific
investigative questions. The investigative questions are designed to gather
facts related to requirements of the PSM standard, and include guidance
for reviewing documents, interviewing workers, and verifying full
implementation.
2. Emphasis on Implementation over Documentation.
Based on inspection history at refineries and large chemical plants, OSHA
has found that employers may have an extensive written process safety
management program, but insufficient program implementation.
Therefore, CSHOs should verify the implementation of PSM elements to
ensure that the employer’s actual program is consistent with their written
program.
3. Dynamic List Questions.
CSHOs will select one or more units and use a dynamic list(s) of questions
(referred to in this document as the dynamic list) to review PSM
compliance.
a. DEP continuously develops dynamic lists in three categories: PSM
General, Ammonia Refrigeration, and Chemical Processing. DEP will
periodically issue new dynamic lists.
b. For inspection integrity purposes, OSHA will not publicly disclose the
dynamic lists. The dynamic lists will only be posted on OSHA’s
DEP/PSM intranet website. CSHOs must download and use the
dynamic list(s) listed as “Effective” at the time of the opening
conference. For inspection preparation purposes, DEP will post the
dynamic list(s) about 7 days before they become effective.
Example: The most recent dynamic list posted on the DEP intranet
site has an “Effective Date” of August 17, 2010. The previous
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dynamic list has an “Effective Date” of August 1, 2010. The
inspection opening date is August 15, 2010. In this case, CSHOs will
use the August 1 dynamic list for the inspection because the opening
date of the inspection is before the “Effective Date” of the August 17th
dynamic list.
Note: Please contact DEP if you have difficulty downloading the
dynamic list.
c. CSHOs must evaluate compliance with each item on the dynamic list.
4. Expanding the Inspection.
If, during the compliance evaluation, CSHOs determine that PSM
deficiencies may exist outside of the selected unit or dynamic list
questions, the inspection may be expanded after consultation with the Area
Director. CSHOs shall document the basis for this determination.
5. Inspect Both Host and Contract Employers.
CSHOs must inspect both the host employer and contract employers, if
any.
6. Review Inspection History and Abatement.
CSHOs shall review the employer’s history of OSHA inspections and any
abatement verification submitted for citations resulting from those
inspections.
E. Inspection Procedures.
1. Supplemented FOM Procedures.
The procedures given in OSHA Instruction CPL 02-00-148, Field
Operations Manual, Chapter 3, shall be followed except as modified in the
following sections.
2. Opening Conference.
Where possible, the facility safety and health director, process safety
manager, or other person capable of explaining the company’s process
safety management program shall be asked to attend the opening
conference.
The opening conference must include the following:
a. Verify PSM Applicability. CSHOs shall confirm that the facility has a
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PSM-covered process.
• CSHOs shall request a list of the chemicals on site and their
respective maximum intended inventories. CSHOs shall review
the list of chemicals and quantities, and determine if there are
HHCs listed in 1910.119 Appendix A or flammable liquids or
gases at or above the specified threshold quantity. CSHOs may ask
questions, conduct interviews, or conduct a walkaround to confirm
the information on the list of chemicals and maximum intended
inventories. If CSHOs determine that there are no HHCs,
flammable liquids, or flammable gases present in sufficient
quantities and the facility is not manufacturing explosives or
pyrotechnics as defined in 1910.109, then, after updating the AO,
they shall document the finding and end the inspection.
• CSHOs shall confirm that the facility is not a retail facility, oil or
gas well drilling or servicing operation, or normally unoccupied
remote facility (1910.119(a)(2)). If the facility is one of these types
of establishments, CSHOs should document their findings and end
the inspection.
• CSHOs shall determine if other exemptions apply. According to
1910.119(a)(ii), a process could be exempt if the employer can
demonstrate that covered chemical(s) are:
− Hydrocarbon fuels used solely for workplace
consumption as a fuel (e.g., propane used for
comfort heating, gasoline for vehicle refueling), if
such fuels are not a part of a process containing
another highly hazardous chemical covered by the
standard, or
− Flammable liquids stored in atmospheric tanks or
transferred which are kept below their normal
boiling point without the benefit of chilling or
refrigeration.
If management believes that the process is exempt, CSHOs shall
ask the employer to provide documentation or other information
that demonstrates why the process is exempt.
• CSHOs may ask questions, conduct interviews, or conduct a
walkaround to confirm that the exemption applies. If, at this point,
they determine that the facility is either not covered or covered but
exempted, then, after updating the RO, they shall document their
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finding and end the inspection.
b. During the opening conference, CSHOs shall familiarize themselves
with the establishment’s emergency response procedures and
emergency alarms.
c. CSHOs shall also request that the management representative(s)
provide them with an overview of the processes/units at the facility,
including block flow and/or process flow diagrams indicating
chemicals and processes involved.
d. To understand the basics of the employer’s processes and the possible
catastrophic scenarios that could occur, the team should ask the
management representative to explain worst-case catastrophic release
scenarios that might occur and what controls are in place to prevent
them from happening.
e. During the opening meeting, CSHOs should determine the nature of
the PSM-covered process.
If the process is: Then use:
Ammonia Refrigeration Only Ammonia Refrigeration dynamic
list – the first 10 questions
PSM General dynamic list– the
first 5 questions
Storage Only PSM General dynamic list – all
questions
Chemical Processing and all other
categories not listed above Chemical Process dynamic list -
the first 10 questions
PSM General dynamic list – the
first 5 questions
Each dynamic list contains approximately 10-15 primary and 5
secondary questions. CSHOs will choose the appropriate number of
primary questions according to the table above. Questions that are
deemed not appropriate should be replaced with secondary questions
from the appropriate list. CSHOs should use the secondary list
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questions in the order that they are listed.
3. Documentation to be Requested -- General and Process-Related.
CSHOs shall request access to the documents listed below.
Compliance Guidance: The list below is not intended to limit the type and
number of documents to be requested. The OSHA inspection team may
request additional documents as necessary.
Some requests require the employer to provide a list of information. The
intent of first requesting a list versus complete documentation is to limit
the amount of documents that the employer may have to produce.
The following list represents documents typically compiled by employers
with PSM-covered processes at their facilities. The PSM standard
requires the employer to maintain some, but not all, of these documents.
Therefore, the employer may not have all of these documents. Documents
specifically required by an OSHA standard or regulation are identified
(*). Documents identified (##) are documents that will be requested after
the Selected Unit is determined. In some cases, documentation may have
been produced by a consultant or contractor.
a. OSHA 300 logs for the previous three years for the employer and the
process related contractors*.
b. All contract employee injury and illness logs as required by
1910.119(h)(2)(vi)*.
c. A list of all PSM-covered process/units in the complex.
d. A list of all units and the maximum intended inventories* of all
chemicals (in pounds) in each of the listed units.
Compliance Guidance: 1910.119(d)(2)(i)(C) requires the employer to
have process safety information (PSI) for the maximum intended
inventories of chemicals that are part of their PSM-covered processes.
e. A summary description of the facility’s PSM program.
f. Unit process flow diagrams*.
g. Piping and instrumentation diagrams (P&IDs) including legends*##.
h. Unit Plot plans*.
i. Unit Electrical classification diagrams*##.
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j. Process narrative descriptions*.
k. Descriptions of safety systems (e.g., interlocks, detection or
suppression systems)*##.
l. Design codes and standards employed for process*## and
equipment*## in the Selected Unit (s).
m. A list of all workers (i.e., hourly and supervisory) presently involved in
operating the Selected Units(s) including names, job titles, work shifts,
start date in the unit, and the name of the person(s) to whom they
report (their supervisor)##.
n. The initial process hazard analysis*(PHA) and the most recent
update/redo or revalidation* for the Selected Unit (s); this includes
PHA reports*, PHA worksheets*, actions to address findings and
recommendations promptly*, written schedules for actions to be
completed*, and documentation of findings and recommendations*##.
Compliance Guidance: Any PHA performed after May 25, 1987 that
meets the requirements of 1910.119(e) may be claimed by the employer
as the initial PHA for compliance purposes, see 1910.119(e)(1)(v).
o. Safe upper and lower operating limits for the Selected Unit(s)*##.
p. A list by title and unit of each PSM incident report*; all PSM incident
reports for the selected unit*##.
4. PSM Overview.
Prior to beginning the initial walkaround inspections, the team shall
request an explanation of the company’s PSM programs including, but not
limited to:
a. A briefing on the PSM program components and how the facility
implements them;
b. Identification by name and position of personnel responsible for
implementing the standard’s various elements;
c. A description of company records used to verify compliance with
standards; and
d. A review of the written summary description of the PSM program.
5. Personal Protective Equipment (PPE) and Camera/Video Use.
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In addition to normal inspection protective equipment, CSHOs conducting
these inspections shall be provided with flame-retardant coveralls for
protection from flash fires.
a. CSHOs shall wear flame-retardant coveralls in all areas of the plant
where there is potential for flash fires and as may be required by
company policy.
Clothing made of hazardous synthetic fabrics may melt, causing severe
burns, and should not be worn underneath flame-retardant coveralls.
All garments worn under flame-retardant coveralls shall be made of
100% cotton or other non-synthetic fibers.
b. Prior to the initial walkaround inspections, CSHOs must review the
employer’s procedures for PPE selection and allowable electronic
equipment in the Selected Unit (s) and/or areas of the facility CSHOs
will be inspecting. CSHOs shall ensure that these procedures and the
associated PPE selection have been prepared in accord with the PSM
standard as well as 1910, Subpart I, Personal Protective Equipment.
The facility-required PPE and flame-retardant coveralls (where flash
fires are possible) are the baseline PPE requirements for CSHOs
conducting walkaround inspections.
• If the facility requires a respirator, or in a CSHO’s judgment, a
respirator should be worn, then each CSHO must receive proper
training and qualification prior to using their respirator.
• For electrically classified areas, CSHOs shall ensure that cameras
(still or video) are intrinsically safe.
Note: CSHOs may use non-intrinsically safe cameras equipped
with a telephoto lens from outside classified areas and/or still
cameras without batteries or a flash.
If the employer allows the use of non-intrinsically safe cameras in
hazardous (classified) locations, CSHOs may use this type of
equipment when: (1) the employer issues a hot work permit for the
use of the camera; and (2) continuous combustible gas metering,
which has been calibrated prior to use, is provided in the areas
where the camera will be used.
• CSHOs must ensure that all electronic devices such as cell phones,
PDAs, etc., are turned off.
6. Initial Walkaround.
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After the opening conference, the inspection may begin with a brief initial
walkaround inspection of those portions of the facility within the scope of
the PSM standard. During the initial walkaround CSHOs should:
a. look for differences between what was presented in the PSM overview
discussion and actual conditions;
b. gather information to aid in the selection of the process unit(s) to be
inspected;
c. obtain a basic overview of the facility’s operations;
d. observe potential hazards including, but not limited to, pipe work at
risk of impact, corroded or leaking equipment, unit or control room
siting and trailer location, relief devices and atmospheric vents that
discharge to atmosphere, and ongoing construction and maintenance
activities;
e. solicit input from workers and their representatives and contract
employees concerning potential PSM program deficiencies.
Compliance Guidance: Additional walkaround activity will be necessary
after the Selected Unit(s) is identified.
7. Selection of Unit.
The Team Leader shall select a PSM-covered process or processes to
evaluate for compliance with the standard. For large continuous
processes, the Team Leader may select a portion of the covered process,
for example, a unit operation within the covered process. The selected
process or portion thereof shall be referred to as the Selected Unit.
CSHOs may select more than one unit if they feel it is necessary to get a
representative sample of the facility’s covered processes based on the size
and complexity of the facility. The selection should be based on the factors
listed below, and shall be documented in the case file:
a. Nature (e.g., risk of releasing flammables, high toxicity substances
present, high operating pressures and temperatures) and quantity of
chemicals involved;
b. Incident investigation reports, near-miss investigation reports,
emergency shutdown records, and other history;
c. Lead operator’s input;
d. Age of the process unit;
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e. Factors observed during the walkaround;
f. Worker representative input;
g. Number of workers present;
h. Current hot work, equipment replacement, inspection, test and repair
records, or other maintenance activities;
i. Compliance audit records, including open and pending items;
j. List of contractors.
Compliance Guidance: It is not intended that the unit selection be a
resource-intensive activity. The criteria listed above are intended to be
used as a guide. The Team Leader should attempt to identify the most
hazardous process using these criteria; however, he/she can use discretion
in choosing the Selected Unit.
8. Inspection of Contractors.
If the facility is using contractors in PSM covered operations:
All contractors (including subcontractors) working on or adjacent to the
Selected Unit shall be inspected. CSHOs shall use the applicable
questions in the dynamic list when evaluating contract employer
compliance.
If there are no contractors working on or adjacent to the Selected Unit
throughout the course of the inspection, the Team Leader will choose an
additional PSM-covered process where contractors are known to be
working and inspect those contractors.
9. Compliance Guidelines.
Guidelines for assessing and verifying compliance with PSM standard
provisions are provided in the dynamic list. When conducting PSM
compliance evaluations of the Selected Unit:
a. CSHOs must use the guidance given in the dynamic list. The dynamic
list-based evaluation of this NEP is a mandatory gap analysis
formatted in a series of questions to facilitate the evaluation of various
requirements of the PSM standard. Instructions for using the dynamic
list are provided in Appendix A.
b. Expanded Inspection. If, during the course of the evaluation, the
Team Leader determines that deficiencies outside of the selected unit
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or dynamic list questions may exist in the employer’s PSM
compliance, he/she shall consult with the Area Director (AD) and may
expand the inspection to other units or areas. CSHOs shall document
the basis for this determination and include the supportive
documentation in the case file.
c. Hazardous Conditions or Violations Not Addressed by Dynamic List.
CSHOs may recommend citations for hazardous conditions or
violations of OSHA standards or the General Duty Clause found
during the inspection regardless of whether they are specifically
addressed in this Notice.
10. Review Inspection History and Abatement.
During the course of the inspection, the CSHO shall review abatement for
all PSM citations issued within the previous 6 years to determine whether
the hazard still exists. If a hazard exists, the CSHO shall determine
whether there has been a failure to abate in accordance with CPL 02-00-
148 – FOM, and issue a notice for failure to abate as appropriate.
In cases where a follow-up inspection has been completed since the
abatement was in place, it is not necessary for the CSHO to review the
abatement.
11. Citations.
Citations for violations shall be issued in accord with CPL 02-00-148 –
FOM. The following additional directions shall be used for citations of
PSM violations:
a. The requirements of the PSM standard are intended to eliminate or
mitigate catastrophic releases of HHC. The provisions of the standard
present closely interrelated requirements, emphasizing the application
of management controls when addressing the risks associated with
handling or working near HHC.
b. Any violation of the PSM standard is a condition that could kill or
seriously harm workers.
c. Violations of the PSM standard shall not normally be classified as
“other-than-serious”.
F. Program Evaluation.
This NEP will be evaluated using data collected from case files and follow-up site
visit reports submitted by each AO, through the Region, to the Office of General
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Industry Enforcement (GIE) in the DEP. After one year, the NEP will be
evaluated to determine the effectiveness of this Instruction. After three years, the
NEP will be evaluated to determine its effectiveness in enforcing OSHA
standards.
The AO will submit the information listed below through OSHAPedia on its
respective Region’s Chemical NEP Inspection Information Page. The Region
should report this information at least every six months.
Information to be provided in the AO reports includes:
1. A list of the facilities inspected including:
a. The facility category as defined in XI.A.2.a;
b. The facility NAICS code, process type, and covered chemical and
quantity, or reason for exemption from PSM coverage;
2. A list of all inspections (including employer name, address, and NAICS
code) that were closed because there was no PSM-covered process.
3. A list of any dynamic list questions that were difficult for CSHOs to use or
inappropriate, and an explanation of why this was the case.
G. Outreach.
The OSHA Training Institute, in conjunction with the DEP and the Office of
Public Affairs, will develop chemical plant PSM information and training
materials. This information will be made available to the ROs for distribution to
the AOs and Consultation Program offices. Each AO and RO is encouraged to
develop outreach programs that will support its enforcement efforts. Suggested
outreach products and activities include the following:
1. Letters and news releases announcing the implementation of this Notice.
2. Seminars on chemical plant process safety topics tailored for specific
audiences, such as employers, worker groups, local trade unions,
apprentice programs, equipment manufacturers, and material suppliers.
3. Working with OSHA’s cooperative program participants, including
Voluntary Protection Programs, Strategic Partnership, and Alliance
Program participants, to share success stories and technical information
concerning effective means of controlling and reducing or eliminating
potential catastrophic releases of HHCs.
H. IMIS and OIS Coding Instructions.
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1. The instructions that follow are for inspections under this NEP.
2. All enforcement activities--inspections, complaints, accidents, referrals,
and compliance assistance (OSHA 55)--conducted under this NEP must be
coded with the NEP code “CHEMNEP” entered in the appropriate NEP
field/item # on the respective forms.
a. All inspections of contractors initiated as a result of a Programmed
inspection of the host employer will be identified as Program Related.
b. For IMIS, the OSHA Form 1 for the contractor must indicate
“CHEMNEP” in block 25d and the Optional Information must indicate
in Item 42: Type = N; ID = 01; and Value = (the OSHA Form 1
inspection number of the host employer).
3. All consultation activities (Forms 20, 30, and Form 66) conducted in
response to this NEP must include “CHEMNEP” in the National Emphasis
code field on the forms.
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Appendix A
CSHO Instructions for the Dynamic Lists
Background and Description. CSHOs must use the appropriate Dynamic List as
described in Section XI.D.3 of this notice. The Dynamic Lists are found on the DEP
intranet website, and contain a series of dynamic questions which will be periodically
changed while this NEP notice is active.
This list-based evaluation is a gap analysis formatted in a series of questions that have been
developed to assess and verify the employer’s PSM compliance with specific issues such as
design, fabrication, installation, start-up, operation, maintenance, change, controls
(engineering and administrative), safe work practices, contractor safety, etc., at the facility
by examining a Selected Unit.
CSHO Instructions. The questions are designed to elicit “Yes”, “No”, or “N/A” for
determination of PSM compliance by CSHOs. CSHOs shall mark
•“Yes” when the employer has met the requirements of the question,
•“No” when the employer does not meet the requirements of the question, or
•“N/A” if the question is not applicable.
A determination of “No” for any question may indicate noncompliance if the employer
does not have an acceptable alternative in place. Therefore, any “No” shall normally result
in a citation for a violation of the indicated provisions provided that the other prima facie
elements (a hazard exists, an OSHA standard applies, employer knowledge of the hazard,
and worker exposure to the hazard) of a violation are established. Each question lists one or
more possible citations. However, CSHOs are not limited to this list. Based on the fact
finding, other citations for violations may be more appropriate. CSHOs shall thoroughly
document each “No” determination in the case file.
Because of the interrelationship of the PSM elements, CSHOs may find that under some
circumstances more than one provision of the standard may be applicable. The following
excerpt from CPL 02-02-045 demonstrates the interrelationship of the PSM elements:
“Interrelationship of Elements.
An essential part of verifying program implementation is to audit the flow of
information and activities among the elements. When information in one element
is changed or when action takes place in one element that affects other elements,
CSHOs shall review a sample of the related elements to see if the appropriate
changes and follow-up actions have taken place.
The following example demonstrates the interrelationship among the elements:
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During a routine inspection of equipment (Mechanical Integrity), the maintenance
worker discovers a valve that no longer meets the applicable code and must be
changed. Because the type of valve is no longer made, a different type of valve
must be selected and installed (Management of Change). The type of valve
selected may mandate different steps for the operators (Operating Procedures)
who will require training and verification in the new procedures (Training). The
rationale for selecting the type of valve must be made available for review by
employees and their representatives (Employee Participation).
When the new valve is installed by the supplier (Contractors), it will involve
shutting down part of the process (Pre-startup Safety Review) as well as brazing
some of the lines (Hot Work Permit). The employer must review the response
plan (Emergency Planning) to ensure that procedures are adequate for the
installation hazards.
Although Management of Change provisions cover interim changes, after the new
valve is in place, the Process Safety Information will have to be updated before
the Process Hazard Analysis is updated or revalidated to account for potential
hazards associated with the new equipment. Also, inspection and maintenance
procedures and training will need to be updated (Mechanical Integrity).
In summary, 11 PSM elements can be affected by changing one valve. CSHOs
would check a representative number of these elements to confirm that the
required follow-up activities have been implemented for the new valve.”
Given the catastrophic nature of the hazards associated with PSM, the interrelationship of
the PSM elements work together to help ensure that if the employer is deficient in one PSM
element, the other elements, if complied with, prevent or mitigate a catastrophic incident.
Consequently, the PSM standard uses a one hazard-several abatement approach to ensure
that PSM-related hazards are adequately controlled.
Abatement requirements include:
• management system/program requirements – e.g., the employer must develop
mechanical integrity program procedures that include piping inspection procedures,
1910.119(j)(2), and
• specific employer action/task abatement requirements - e.g., the employer must
inspect the piping, 1910.119(j)(4).
Therefore, to assure that all the employer’s process safety management systems/elements are
being fully implemented, CSHOs should consider citing all applicable violations. Grouping
these violations may be appropriate, see CPL 02-00-148, FOM, Chapter 4 Section X.
In some cases, CSHOs may determine that the answer to a question is “No” because the
employer uses other means to comply with the specific standards. In this case, the employer
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must demonstrate that its performance meets the requirements of the standard.
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32411 NAICS code, 4
abatement, 27
accident, 3, 6, 9, 10, 11, 25
Alliance Program, 25
ammonia refrigeration, 10, 11, 14, 17
Ammonia Refrigeration Level 1, 10
atmospheric tanks, 16
camera, 20, 21
catastrophe, 9
chemical processing, 10
CHEMNEP, 25
complaint, 9, 25
contract employee injury and illness logs, 18
contract employers, 15, 22
contractor, 13, 18, 22, 25, 26
Course 330, 10, 11, 12
Course 3300, 10, 11, 12
Course 3400, 10, 11, 12
Course 3410, 10, 11, 12
Course 3430, 10, 11, 12
CPL-02-02-045, 2, 14, 26
DEP Intranet, 15, 25
documentation, 14, 17, 18, 19
dynamic list, 3, 9, 14, 15, 17, 18, 22, 23, 25
electrical classification, 19
emergency planning, 13, 26
employee participation, 13, 26
Field Operations Manual (FOM), 2, 5, 9, 15, 23, 27
GIE, 24
hot work permit, 13, 21, 26
IMIS, 6, 25
incident investigation, 13
Level 1, 10, 11, 13
Level 2, 12
Level 3, 13
management of change, 26, 27
master list, 6, 7, 8
maximum intended inventories, 16, 18, 19
mechanical integrity, 26, 27
normally unoccupied remote facility (NURF), 16
oil or gas well drilling or servicing operations, 16
operating procedures, 20
operation procedures, 20, 26
petroleum refineries, 4, 8
PHA, 19
PPE requirements, 9, 20
PQV, 14
pre-startup safety review, 26
PSM general, 14, 17, 18
referral, 9
Refinery NEP, 4
retail facility, 16
Risk Management Program (RMP), 6
safe upper and lower operating limits, 19
selected unit, 9, 15, 18, 19, 20, 21, 22, 23, 25
SHARP (Safety and Health Achievement Recognition
Program), 7
storage, 14, 17
Strategic Partnership, 25
targeting, 3, 6, 8
training, 10, 11, 12, 13, 20, 24, 26, 27
VPP (Voluntary Protection Program), 7, 25
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