OSHA National Emphasis Programs — Status and future

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Courtesy of ABS Consulting

As reported in a previous article (“The NEP may prove costly to process safety,” BIC magazine, August 2007), OSHA published a refinery National Emphasis Program (NEP) under compliance directive CPL 03-00-004 in June 2007, and began inspections. As of mid-April, a compilation of industry data showed seven NEP inspections complete with citations issued, two more complete and waiting on citations and 13 under way. It also showed two state NEP inspections.

According to the data, the average fine associated with the citations for the completed NEP inspections thus far is more than $150,000 per refinery. Although not all of OSHA’s press releases on NEP inspections have disclosed the number of citations, it appears these are averaging about 20 per refinery. In comparison, Richard Fairfax, director of OSHA Enforcement Programs, told the “Houston Chronicle” (“OSHA uncovers slew of refinery violations,” March 9) that OSHA had found 146 violations after reviewing 17 refineries in a dozen states, but it appears these violations are only from the completed inspections.

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