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OSHA NEP Audits of Refineries and Chemical Plants
Mark Briggs, OSHA Houston South Area provided this information at the 2009 API Inspector Summit:
Refinery Audits
OSHA is conducting National Emphasis Program Audits at all 152 US refineries.
VPP Star plants are exempted initially, but they will be audited
First priority is on Region 6, Gulf Coast, 69 refineries
Chemical Plant Audits
Audits of chemical plants will commence at stand alone NE/NW/N sites
Audit Schedule
Plan to complete audits of all Refineries and Chemical plants by Jan 2011
Audit Questions
OSHA publishes a static list of 95 questions that will be asked
Additionally, OSHA will use a dynamic list of 8-15 questions, not published
Audit Notification
OSHA will not provide advance notice, audits will be an announcement at the gate "We would like to see your plant manager".
Duration of Audits
Audits must be completed within 6 months, most take 3-4 months
Preparation for Audits
Key words for plant management include; Have current knowledge of industry history, events, and issues and application of best technology supported by evidence of due diligence

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