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OSHA to Hold Meeting on Process Safety Management Rulemaking

In the August 30, 2022 Federal Register the Occupational Safety and Health Administration published a notice of an informal stakeholder meeting on its Process Safety Management (PSM) standard rulemaking. OSHA will provide an overview of its work on the rulemaking and will accept public comments related to potential changes to the PSM standard. The meeting will be held on WebEx on September 28, 2022, and requires registration. Written comments will be accepted through October 28, 2022.

OSHA is currently considering the following potential changes to the scope of the PSM standard:

  • Clarifying the exemption for atmospheric storage tanks;
  • Expanding the scope to include oil- and gas-well drilling and servicing;
  • Resuming enforcement for oil and gas production facilities;
  • Expanding PSM coverage and requirements for reactive chemical hazards;
  • Updating and expanding the list of highly hazardous chemicals in Appendix A;
  • Extend PSM to cover dismantling and disposal of explosives and pyrotechnics;
  • Clarifying the scope of the retail facilities exemption; and
  • Defining the limits of a PSM-covered process.

Other changes OSHA is considering are:

  • Adopting a definition of “Recognized and generally accepted as good engineering practices” (RAGAGEP);
  • Defining critical equipment;
  • Requiring more employee participation and include stop work authority;
  • Requiring evaluation of updates to applicable RAGAGEP;
  • Requiring continuous updating of information related to the hazards of the highly hazardous chemicals in the process;
  • Requiring formal resolution of Process Hazard Analysis (PHA) team recommendations that are not utilized;
  • Requiring safer technology and alternatives analysis;
  • Clarifying that the PHA must consider natural disasters and extreme temeperatures;
  • Requiring critical equipment be covered under the mechanical integrity requirements;
  • Better explain “equipment deficiencies”;
  • Clarifying that organization changes must be covered in management of change;
  • Requiring root cause analysis;
  • Requiring coordination of emergency planning with local emergency-response authorities;
  • Requiring third-party compliance audits;
  • Requiring the development of a system for periodic review of and necessary revisions to PSM management systems (previously referred to as “Evaulation and Corrective Action”); and
  • Requiring the development of written procedures for all elements specified in the standard and to identify records required by the standard along with a records retention policy (previously referred to as “Written PSM Management Systems”).

Sources :

OSHA, Notice of stakeholder meeting, Process Safety Management (PSM); Stakeholder Meeting, 87 FR 53020, Aug. 30, 2022

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