Inspectioneering
Inspectioneering Journal

How to Prepare for an OSHA NEP Audit

By John Reynolds at Intertek. This article appears in the March/April 2008 issue of Inspectioneering Journal

Introduction

OSHA’s National Emphasis Program (NEP) (1) is now well underway, with 17 of 81 targeted refineries having been reviewed so far (2). OSHA launched the NEP in 2007 after the deadly incident at BP Texas City. As of March this year, OSHA claims to have uncovered 146 violations so far and recommended nearly $1 million in fines. This article focuses on preparing for the mechanical integrity (MI), i.e. pressure equipment integrity (PEI) and inspection issues, portion of the NEP directive. As such this article is sort of a “Reader’s Digest” type summary of the PEI aspects of the NEP directive. As you know, the NEP directive covers a much wider scope of PSM issues in addition to MI, including: management of change, operating procedures, operator training, PHA, facility siting, human factors, safe work practices, contractor safety, and basically anything else covered in the PSM regulation OSHA 1910.119. The OSHA NEP directive also focuses on blowdown drums, which played a central role in the TX City event, but will not be covered in this article, as I expect that the industry has already made sure that processes with those drums have been eliminated or at least received their due attention because of all the coverage given to them in the Baker (3) and CSB (4) reports of the incident.

This content is available to registered users and subscribers

Register today to unlock this article for free.

Create your free account and get access to:

  • Unlock one premium article of your choosing per month
  • Exclusive online content, videos, and downloads
  • Insightful and actionable webinars
GET STARTED
Interested in unlimited access? VIEW OUR SUBSCRIPTION OPTIONS

Current subscribers and registered users can log in now.


Comments and Discussion

There are no comments yet.

Add a Comment

Please log in or register to participate in comments and discussions.

Interested in equipment reliability & integrity? Sign up for weekly updates.

Inspectioneering Journal

Explore over 20 years of articles written by our team of subject matter experts.

Company Directory

Find relevant products, services, and technologies.

Job Postings

Discover job opportunities that match your skillset.

Case Studies

Learn from the experience of others in the industry.

Event Calendar

Find upcoming conferences, training sessions, online events, and more.

Industry News

Stay up-to-date with the latest inspection and asset integrity management news.

Blog

Read short articles and insights authored by industry experts.

Acronyms

Commonly used asset integrity management and inspection acronyms.

Asset Intelligence Reports

Download brief primers on various asset integrity management topics.

Videos

Watch educational and informative videos directly related to your profession.

Expert Interviews

Inspectioneering's archive of interviews with industry subject matter experts.