Effective January 17, 2017, the Occupational Safety and Health Administration (OSHA) issued new instructions concerning its National Emphasis Program (NEP) as it relates to chemical process subject to Process Safety Management (PSM). See Directive Number CPL-03-00-021. PSM requirements are codified at 29 CFR 1910.119.   Prior NEPs were implemented for Petroleum Refining in 2007 and