Back in 2017 I posted on how to answer an OSHA document request from the published NEP.

OSHA’s published CPL-03-00-021 – “PSM Covered Chemical Facilities National Emphasis Program” includes an example document request list that often correlates fairly well to the one that OSHA inspectors provide during an NEP inspection.

Recently, a friend sent me the Document Request they received at the onset of the inspection which was quite a bit different from that PSM ChemNEP. Here’s what I noticed reviewing this new document:

  • It’s quite a bit longer.
  • The information – again – isn’t NH3 Refrigeration Specific. That means you have to interpret some of it.
  • In my opinion, It’s designed to be a huge fishing expedition.

I took that request and modified it to show how I would answer the 110 questions if you were using my PSM programs. You can download the 13 page, 4,500 word Microsoft Word monstrosity through the following link: 0419 OSHA Document Request.

Just a few general warnings about questions and document requests:

  • When in doubt, ask for clarification. Always get clarifications in WRITING.
  • When you are unsure of the appropriate documentation to provide, or what documentation addresses the issue, ask to get back to them and seek quality advice.
  • Always get additional documentation requests and follow-up questions in WRITING.

Remember, you can watch a 30 minute presentation on YouTube regarding preparing for (and surviving) an OSHA / EPA inspection here.