The History and Purpose of PSM-NEP
|It is recommend that you read John Ross' article "Making Sense of Proces Safety" posted by Plant Engineering before reading this blog post.|
Process Safety Management was initiated by 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 make 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 CHEM NEP are two different programs, but each involves a closer look and scrutiny of 14 major elements:
- Employee Participation
- Process Safety Information
- Process Hazard Analysis
- Operating Procedures
- Pre-Start Up Review
- Mechanical Integrity
- Hot Work Permit
- Management of Change
- Incident Investigation
- Emergency Planning and Response
- Compliance Audits
- Trade Secrets
In the following blog posts I will go in to more detail in all of the 14 elements. If you have experience with NEP and/or CHEM NEP let me know what you think of your PSM program and how you've improved your safety and process of HHC.