The PSM National Emphasis Program schedules comprehensive inspections at covered facilities regardless of complaint history or incident record. If your industry is on the list, an inspection is a matter of when, not if.
The PSM National Emphasis Program (CPL 03-00-021) directs OSHA area offices to conduct comprehensive inspections at covered facilities — regardless of complaint history or incident record. This is scheduled enforcement, not reactive.
The NEP focuses inspection resources on industries with the highest potential for catastrophic PSM incidents. Primary target industries receive the most inspection activity.
NEP inspections follow a defined protocol — OSHA's PSM inspection procedure. Every element is reviewed. Here is what inspectors examine in each phase.
P&IDs current and accurate. Hazard information complete for all HHCs above TQ. Technology and equipment documentation on file — relief system sizing basis, design codes and standards, material and energy balances.
PHA completed using an approved methodology (HAZOP, What-If, FMEA, Checklist, or combination). PHA current — revalidated within 5 years. Findings addressed and documented. Team qualifications verified.
Procedures cover all operating phases: startup, normal, temporary, emergency shutdown, emergency operations. Annually certified as current and accurate. Accessible to operators in the field.
Written MI procedures exist for all covered equipment categories. Inspections conducted at RAGAGEP-required frequencies. Deficiencies documented and resolved. Equipment fabrication records on file.
MOC procedure documents: reason for change, safety/health impact, modifications to procedures, time period authorized, authorization requirements. All changes since last inspection reviewed. No undocumented permanent changes.
All 9 remaining elements are reviewed: Training certifications, Contractor safety programs, PSSR completion records, Incident investigation reports and action item closure, Emergency planning, Compliance audit records (within 3 years), Hot work permits, Employee participation plan, and Trade secrets procedures.