In July 2009, the US Department of Labor Occupational Safety and Health Administration (OSHA) launched the pilot National Emphasis Program for chemical facilities (CNEP) directive (CPL 02-09-06), which calls for programmed inspections of facilities covered by the PSM or EPA RMP regulations in regions 1, 7 and 10. OSHA recently extended the CNEP until publication of a permanent directive for PSM-covered chemical plants.

The directive also includes unprogrammed inspections in all regions. Although facilities 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 CNEP questions.

The latest numbers from OSHA show an average of 7.5 violations per inspection with 44 percent of inspections outside the pilot region.

Our Services

NEP Guidance/Preparation

ABS Consulting can provide customized services to help prepare you for the NEP inspection for chemical facilities, including:

Presenting Webinars in which we share our insights and knowledge on what to expect in the NEP inspection and provide tools to help you prepare
Visiting a facility or central location to understand their PSM programs, systems and 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 PSM element requirements and best practices along with recognized and generally accepted good engineering practices (RAGAGEP), a CNEP emphasis area

Documentation and Program Assessments

We can help with assessments of varying scope or level of detail to review your documentation against NEP requirements and provide guidance on addressing potential issues. These can be either standalone CNEP assessments, or added on 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 CNEP inspection.

For more information...

Contact ABS Consulting directly via e-mail, telephone or fax...

info@absconsulting.com | Tel: 1-281-673-2800 | Fax: 1-281-673-2950

OR submit a question or request and we'll get back to you...