By James L. Curtis and Craig B. Simonsen

The Occupational Safety and Health Administration (OSHA) recently announced a new National Emphasis Program (NEP) for chemical facilities.  The NEP is intended to protect workers from catastrophic releases of highly hazardous chemicals. The NEP replaces OSHA’s 2009 pilot Chemical Facility National Emphasis Program (Pilot Program) which established policies and procedures for inspecting workplaces covered by OSHA’s process safety management (PSM) standard. The Pilot Program was very limited in geographic scope whereas this NEP expands the program nationwide, including State Plan States.

The NEP’s inspection process includes detailed questions designed to gather facts related to PSM requirements and verification that employers’ written and implemented PSM programs are consistent. The intent of the NEP is to conduct focused inspections at facilities randomly selected from a list of worksites likely to have highly hazardous chemicals in quantities covered by the standard. Employers with PSM covered ammonia refrigeration processes are the main target of the NEP, along with other covered facilities that OSHA believes to have known risks for potential catastrophic releases.