How to Prepare for an OSHA NEP Audit

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.