The Occupational Safety and Health Administration (OSHA) instituted a “National Emphasis Program” to conduct both targeted and random inspections of facilities subject to the Process Safety Management (PSM) regulations. OSHA has responded to several high profile incidents by initiating a program to help assure that facilities handling highly hazardous chemicals are meeting the PSM regulations in an effort to reduce incidents. OSHA is currently inspecting or auditing facilities believed to require PSM and will indeed issue citations if the facility does not meet all of the standard’s requirements. Below are the most common deficiencies at facilities inspected and information that can be used to make sure that a facility’s PSM program will indeed pass an OSHA inspection under the National Emphasis program.
OSHA initiated the “PSM Covered Chemical Facilities National Emphasis Program” in 2011. Since then, many facilities have undergone PSM compliance reviews. Industry has been able to learn not only where common deficiencies exist in their programs from these reviews, but also about what OSHA is looking for in terms of compliance and how to improve PSM efforts.
Will my facility be inspected?
• Focus is on Level 3 facilities designated by the EPA Risk Management Program (RMP) program.
• There is a 4 to 6% chance per year you will be audited if your facility is part of the RMP program.
What is OSHA’s dynamic list?
• OSHA will generate a list of protocols from its Directorate of Enforcement with the goal of attempting to shorten the length of these inspections. These audit protocols allow for easy one-word answers: Yes, No, or NA.