Oil & Gas
OSHA NEP for Refineries (RNEP)
In 2007, the US Department of Labor, Occupational Safety and Health Administration (OSHA) launched a National Emphasis Program for petroleum refineries (RNEP), which includes inspections of all refineries for compliance with the Process Safety Management Regulations. The current directive (CPL 03-00-010) extends the time for completing inspections for Regions VI and VIII.
According to OSHA, the RNEP is needed because:
- The large number of fatal or catastrophic incidents in the petroleum refining industry indicates the need for a national emphasis program.
- Since the PSM standard was promulgated by OSHA in 1992, no other industry sector has had as many fatal or catastrophic incidents related to the release of highly hazardous chemicals as the petroleum refining industry.
Under the directive, inspections can continue two to six months, including one to three months on-site. Inspectors focus on checking PSM implementation and records targeting specific process units and strategically sampling equipment, records and personnel.
Although refineries in OSHA's Voluntary Protection Program (VPP) are exempt from programmed inspections, they are not exempt from unprogrammed inspections. Their VPP recertification audits now include evaluation against the demanding RNEP questions.
ABS Consulting can provide customized services to help you prepare for the RNEP audit for refineries, including:
- Visiting a refinery or central location to understand the PSM program, system or philosophy and providing guidance on closing any gaps found
- Customizing NEP document or question guidance based on your organization's PSM programs
- Providing public or on-site training for Regulatory Inspection Planning, PSM Program Management/Compliance and PSM element requirements and best practices, as well as recognized and generally accepted good engineering practices (RAGAGEP), a RNEP emphasis area
Documentation and Program Assessments
We can review your documentation against NEP requirements and provide guidance on addressing potential issues identified. These can be standalone RNEP assessments or added to a three-year PSM compliance audit.
PSM Program Support and Improvements
ABS Consulting can assist you in improving your PSM program by conducting your PSM audits or Process Hazard Analysis (PHA), performing facility siting studies or assisting in completing other PSM requirements. We can also provide experienced personnel on a temporary basis to aid facilities in completing old recommendations from PHAs, incidents and audits or to assist with day-to-day PSM program activities while facility personnel are tied up with a RNEP inspection.
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