PSM Covered Chemical Facilities National Emphasis Program

Earlier this week the Occupational Health and Safety Administration (OSHA) published guidelines for the implementation of a new chemical facilities national emphasis program (NEP). The guidelines replace those issued in 2011 for a similar NEP.

There are two interesting programmatic changes in the new NEP. First, OSHA is expanding the list of eligible EPA’s Risk Management Program facilities that will be included in the Process Safety Management (PSM) NEP inspection list from just Program 3 facilities to facilities from Programs 1, 2 and 3. Finally, the NEP encourages OSHA inspectors to review reports submitted for the RMP to familiarize themselves with facility processes before the inspection. Both of these changes are almost certainly an outgrowth of chemical safety program coordination requirements from Obama’s Chemical Safety and Security Executive Order (EO 13650).