PSM system upgrade in response to an Occupational Safety and Health Administration NEP inspection

This article presents a brief analysis of the Occupational Safety and Health Administration (OSTIA) Petroleum Refinery Processes Safety, element National Emphasis Program (NEP) citation results ass of early 2009. It included 5 trends distilled from the OSHA inspections pergormed to dale. Recommendations for preparing for PSM NTP level inspections are provided. A proven approach to designing and implementing an upgrade project for OSHA process safety management systems and EPA risk management program is described. The model presented can be targeted to facility's NEP specific citations or used for a general PSM system effectiveness upgrade. This article includes recommendations for improveing PSM as a result of an NEP inspection. The recommendations are for the PSM elements that routinely have major OSHA citations; that is : O[erating Procedures, mechanical integrity, process hazards analysis, process safety information, management of change, and incident investigations. (C) 2009 American Institute of Chemical Engineers Process Saf Prog 28: 338-342, 2009