PSM system upgrade in response to an Occupational Safety and Health Administration NEP inspection

This article presents a brief analysis of the Occupational Safety and Health Administration (OSHA) Petroleum Refinery Process Safety Management National Emphasis Program (NEP) citation results as of early 2009. It includes trends distilled from the OSHA inspections performed to date. Recommendations for preparing for PSM NEP level inspections are provided. A proven approach to designing and implementing an upgrade project for OSHA process safety management systems and EPA risk management program is described. The model presented can be targeted to a facility's NEP specific citations or used for a general PSM system effectiveness upgrade. This article includes recommendations for improving PSM as a result of an NEP inspection. The recommendations are for the PSM elements that routinely have major OSHA citations; that is: Operating Procedures, Mechanical Integrity, Process Hazards Analysis, Process Safety Information, Management of Change, and Incident Investigations. © 2009 American Institute of Chemical Engineers Process Saf Prog 2009