(82f) A Practical Approach to Implementing a Process Safety Management System Upgrade in Response to An OSHA Refinery PSM NEP Audit

This paper will open with a brief analysis of the OSHA Petroleum Refinery Process Safety Management National Emphasis Program (NEP) citation results (current to the date of the paper's submission). Some interesting trends and data convergences will be presented as well as the primary messages the compiled results will have transmitted to the refining industry. Charts will be provided.

A proven approach to designing and implementing an upgrade project for OSHA process safety management systems and EPA risk management program ? prevention programs will be described. The model presented can be targeted to a facility's NEP specific citations or used for a general program effectiveness upgrade. This model will include typical Gantt charts showing the project's design.

A case study of an actual refinery PSM program upgrade in response to the NEP will be presented. It will address: upgrade activities in preparation for the unannounced audit, response techniques for supporting the OSHA inspection team in a timely and responsive manner during the inspection, and abatement upgrade activities ? including enhancing site safety culture.

One key aspect of implementing an effective process safety management system that the OSHA PSM NEP has already shown at the time of this abstract's development is a need for a corporate and facility culture that supports operational excellence in all four primary areas:

? Safety (personnel and process),

? Environmental Responsibility,

? Quality and

? Profitability.

Methods will be presented for developing the characteristics of high performing organizations throughout an organization ? from corporate management to site management to staff, teams, and hourly employees.