Special Topics in Safety Management

OSHA to “NEP” 28,000 Chemical Plants


OSHA has instituted an intense inspection effort called a National Emphasis Program (NEP) on 28,000 U.S. chemical plants. And it’s mobilized more than a third of its inspection force to carry out that effort.


Memo to some 28,000 American chemical plants: You’re about to get “NEP’d” by OSHA.


NEP stands for National Emphasis Program, which is agency-speak for an intense, all-out effort to inspect and enforce regulations in a given industry or for a given class of accidents or illnesses.


Past NEPs have focused on lead exposure, amputation injuries, and combustible dust. And last year, one NEP that received wide attention involved worker exposure to diacetyl, a chemical used in making butter-flavored microwave popcorn. The chemical has been implicated in bringing on severe obstructive lung disease.



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As part of the program, OSHA inspectors fanned out across the industry, taking air samplings and checking workers in plants under its direct control. The 24 states with their own occupational inspection programs were encouraged to do the same.


Other NEP efforts have been sparked by particularly tragic incidents somewhere in the U.S., which usually received widespread media coverage. Such an incident occurred at a Texas oil refinery in 2005.


Outgrowth of Refinery Inspection Program


OSHA’s response was a NEP focusing on refineries. As reported by Chemical & Engineering News, OSHA has already inspected 52 of the 101 refineries in its jurisdiction. Some 212 violations were found, with 89 percent considered serious. Fines levied were $700,000 over the first 6 months of inspections. And that, says the agency, is just the beginning.


NEPs have gone on for up to 5 years, explains Richard E. Fairfax, director of OSHA enforcement, and the refinery program is far from over. “We still have a long way to go,” he added.


The chemical plant NEP was born when, working on the refinery effort, the government’s Chemical Safety & Hazard Investigation Board looked at how many process safety management (PSM) inspections had been done at refineries in the past 10 years. The board found, very likely to its surprise, that the answer was none. Coincidentally, they also found that only four such inspections had been done in the chemical plant sector. In their opinion, a NEP involving both industries was called for.


How intense will the inspection effort be? There’s a hint in how many of OSHA’s 1,000 inspectors are being trained for it. Nearly one-third of the entire inspection force was put behind the refinery effort, and the push on chemical plants will involve a greater number. “The same inspectors and more will be trained for the chemical plant program,” Fairfax reports.



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NEP efforts often receive union support, and such is the case with the new chemical plant program. One supporter, the United Steelworkers, has members in both the refinery and chemical industries. Steelworkers safety specialist Kim Nibarger expressed concern, however, that even one-third of the OSHA inspection force may not be enough to fully cover an industry of this size. She also raised questions about the amount of training inspectors will get in the complex PSM inspection procedure.


OSHA replied that each inspector will undergo three separate training regimens, and that each team will be led by someone who has done PSMs in the past. The chemical plant safety NEP will begin sometime this year.


Chemical plant safety is not the only NEP that OSHA has announced for 2008. Look for news about another such effort in tomorrow’s Advisor.


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