MSDS MGT: OSHA’s New NEP for Chemical Facilities, HazCom by the Numbers and Other News

Three items caught our attention this week that we wanted to share with you, starting with OSHA’s announcement that it issued a new National Emphasis Program (NEP) for chemical facilities. The NEP is specifically targeting worker protection against highly hazardous chemical releases. The new National NEP is essentially an upgrade of a 2009 pilot NEP that targeted chemical facilities in several regions.

Covered in the NEP are those facilities covered by OSHA Process Safety Management (PSM) standard. According to OSHA’s Web page on PSM (29 CFR 1910.119), the standard “contains requirements for preventing or minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.”

Under the NEP, facilities with highly hazardous chemicals (HHCs) in sufficient quantities covered under PSM, could be subject to random inspections to ensure those facilities have plans in place and that the written plan matches implementation. During inspections, facilities should be prepared to provide inspectors with the following (not a complete list):

  • OSHA 300 logs for the previous three years for the employer and the process related contractors
  • A list of all PSM-covered process/units in the complex
  • A list of all units and the maximum intended inventories of all chemicals (in pounds) in each of the listed units
  • A summary description of the facility’s PSM program.

If you are covered under the PSM, be sure and review the NEP for more details.

Top 10 Most Cited Violations, With Numbers

The second story we’re sharing this week comes from the National Safety Council’s Safey+Health Plus which has detailed numbers to go with OSHA’s top 10 most cited violations. For instance, in the article we learn that under the Hazard Communication Standard, most violations are for failure to have a written plan, followed by training and information failures, labeling issues, and MSDS management problems.

In all, OSHA issued over 6500 citations in 2011 for Hazard Communication, not far off the number one and two spots, Fall Protection and Scaffolding, which had about 7100 and 7000 total violations respectively.

According to the article, Patrick Kapust, OSHA’s deputy director of the Directorate of Enforcement Programs, recommends employers use the list “as a tool to improve safety at their worksites.”

OSHA Year in Review

Our final story is from attorney Lindsay Rakers who asks in her blog post Safety News You Can Use, how did OSHA do on its top priorities this year? She offers up five items identified by the American Industrial Hygiene Association as top OSHA initiatives for 2011:

  1. Updating Permissible Exposure Limits
  2. Injury and Illness Prevention Program
  3. Material Safety Data Sheets/Globally Harmonized System (GHS)
  4. Professional Recognition/Title Protection
  5. OSHA Reform

Two of the items we’ve been following closely here at MSDSonline are GHS adoption and I2P2. Regarding GHS, OSHA has missed a few deadlines but still managed to make significant progress with GHS adoption expected in early 2012. I2P2 on the other hand moved from the legislative front seat to the back seat in 2011, with OSHA conceding the regulatory environment in Washington was forcing it to put on the breaks.

Add your two cents to the conversation on Rakers’ blog.

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