The Occupational Safety and Health Administration ("OSHA") recently issued an updated version of the Process Safety Management ("PSM") Covered Chemical Facilities National Emphasis Program ("Chemical Facilities NEP") directive. As we previously alerted, the revised directive makes several significant changes. These include expanding the Chemical Facilities NEP to all PSM-covered facilities, including petroleum refineries, and targeting facilities with processes subject to the requirements of the U.S. Environmental Protection Agency's Risk Management Plan ("RMP") Program Levels 1 and 2. The Chemical Facilities NEP is intended begin immediately in all regions....