The new prgramme replaces OSHA's 2009 pilot Chemical Facility National Emphasis Program (NEP) that covered selected regions around the country. The new NEP is effective immediately and both programmed and unprogrammed inspections of facilities are set to begin immediately.
A few changes have been introduced with the new nationwide programme, including a reduction in the number of facility categories from three to two:
Number of inspections
- Category I: facilities likely to have ammonia used for refrigeration as the only Highly Hazardous Chemical (HHC) and
- Category II: all other facilities
Each OSHA area office is required to carry out 3-5 NEP programmed inspections per year, with about:
- 25% of inspections concerning ammonia facilities
- 75% of inspections concerning other facilities
Moreover, unprogrammed inspections may occur following complaints, referrals or accidents.
10 questions on ammonia refrigeration and 5 on PSM compliance
Inspections will be conducted using a non-publicly disclose dynamic list of questions designed to gather facts related to requirements of the PSM standard, and include guidance for reviewing documents, interviewing workers, and verifying full implementation. For ammonia refrigeration inspections, there will be:
- 10 questions specific to ammonia refrigeration and
- 5 questions about general PSM compliance
Emphasis, however, will be given to verifying implementation of PSM programmes by facilities rather than just documentation.
Recommendations by the International Institute of Ammonia Refrigeration
Following the announcement, the International Institute of Ammonia Refrigeration (IIAR) has recommended its members to read the full directive and review their PSM programmes in view of a potential inspection. To assist facilities, the OSHA Training Institute will develop chemical plant PSM information and training materials. Additional compliance assistance materials are also likely to be developed through the IIAR’s alliance with OSHA.