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

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