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Keywords:

  • OSHA;
  • NEP;
  • MOC;
  • corrective actions;
  • inspections;
  • procedures;
  • RNEP;
  • VPP;
  • CNEP;
  • RAGAGEP;
  • PSM;
  • National Emphasis Program

Abstract

While developing responses to help a client respond to occupational safety and health administration (OSHA) citations, we discovered that little or nothing has changed in 14 years at many facilities. OSHA is still finding the same gaps today. Chemical plants generally know how to complete a process hazard analysis (PHA), management of change (MOC), an incident investigation, etc. What is incomplete are the work processes to ensure continuity and completion.

It is imperative that you have a functional process safety management (PSM) program. For example, OSHA states that the best defense against a National Emphasis Program (NEP) inspection is a strong PSM program. Failures can result in citations and incidents, which can lead to repeat or egregious citations, financial losses, public disgrace, and fatalities. Once your company has been cited for minor offenses, it becomes a target for repeat inspections.

The teachings of this article will reduce failures by designing, implementing, and using complete work processes for PSM-related activities. Many failures can be addressed by (1) improving the documentation of what you already do, (2) promptly resolving PSM-related recommendations of all types, and (3) dealing with the challenge of keeping track of the ever-changing recognized and generally accepted good engineering practices (RAGAGEP) that apply to many aspects of your PSM program. In addition, management support/involvement and systems that follow-up to ensure all work activities are complete and adequately documented are essential. Instituting complete work processes will improve your PSM program, improve your efficiency, and reduce the chance of citations. © 2011 American Institute of Chemical Engineers Process Saf Prog, 2011